Prescribing Rules and Guidelines
An overview of rules governing prescribing practices for physicians and
physician assistants in Washington state.
Opioid-Related Prescribing Rules in Washington
Comprehensive rules, required by
House Bill 1427
(2017) and
Senate Bill 5380
(2019) regulate opioid prescribing in our state. The boards and
commissions that regulate prescribers of opioids each created separate
rules. While the rules are largely aligned, there are minor but important
differences across professions.
Key provisions for prescribing physicians and PAs
-
A seven-day pill limit for acute prescriptions and 14 days for acute
operative pain, with an exemption to these limits when clinical judgment
is documented in the medical record (as per
HB 1427).
-
A specific care plan and documentation requirements for each phase of
pain.
-
Mandated registration and targeted checks of the prescription drug
monitoring program.
-
Required continuing medical education on opioid prescribing. The WSMA
offers on-demand training to meet this requirement:
Opioid Prescribing Regulations Post-COVID-19 Public Health
Emergency (WSMA members only—sign-in required).
-
Notification to the patient of the risks of prescription opioids,
including the risk of dependency and overdose, pain management
alternatives to opioids when clinically appropriate, evidence-based
alternatives, and notification that they have the right to refuse an
opioid prescription for any reason (as per
SB 5380).
-
To help you successfully incorporate this requirement into your
workflow, the WSMA has updated its Epic-compatible pain management
rule requirements checklist, available below.
Preparing to prescribe opioids
-
Complete the
one-hour, mandatory CME
on opioid prescribing best practices.
-
Register for the state's prescription monitoring program at the
Washington State Department of Health.
-
Read the prescribing rules relevant to your profession to understand
rules around prescribing, CME, treatment planning, PMP checks,
diagnosis, and ICD documentation. See this
Department of Health chart
for quick reference and see the information directly below.
-
Build increased documentation and other new requirements into your
workflow. The WSMA offers a
WSMA Pain Management Rule Requirements Checklist
to help. Learn more about Bamboo Health's
PMP Gateway
integration option below.
Before prescribing an opioid, you must:
- Perform and document patient evaluation.
- Create and/or document treatment plan.
-
Provide the patient with information on the risks of opioids, their safe
and secure storage and disposal, and the patient's right to refuse the
prescription-the Department of Health offers
patient handouts
meeting this requirement.
-
Consider (and in some cases, document) the use of alternative modalities
for pain treatment when clinically appropriate.
Prescribing board and commission rules
There are instances where prescribing rules vary based on
profession.
For example, with treatment plans, MDs are not required to document them
in the medical record, but DOs are. Additionally, MDs are required to
check the PMP at targeted intervals, but DOs are required to conduct
checks prior to the issuance of any prescription of an opioid or a
benzodiazepine. Review
this Department of Health summary
of differences based on profession and consult the respective board and
commission rules in full to understand the set of rules applicable to your
profession:
Other Prescribing Rules in Washington
Updated June 2023
Schedule II oral prescriptions
The Pharmacy Quality Assurance Commission filed an emergency rule
regarding Schedule II Oral Prescriptions that aligned state regulatory
practice with the ongoing federal Drug Enforcement Administration's
guidance on Schedule II prescribing standards during the COVID-19
pandemic. The duration of time a practitioner had to deliver a signed
prescription of a Schedule II substance to the pharmacy increased from
seven days to 15 days when a prescription is dispensed in an emergency. It
also defined what a "signed prescription" meant and allowed for a
practitioner to accomplish this requirement through paper, electronic
transmission, facsimile, photograph, or scanned copy.
This emergency rule expired in June 2023. Upon expiration, the commission
elected to adopt
this guidance document
addressing the guidelines instead of refiling the emergency rule. This
guidance document will remain in effect until either the DEA's guidance is
withdrawn, or the commission withdraws this guidance document at a future
meeting.
Federal Prescribing Updates
Updated June 2023
DATA 2000 (X) waiver removed
In December 2022, the Substance Abuse and Mental Health Services
Administration and the Drug Enforcement Agency eliminated the requirement
for physicians and other prescribers to obtain a DATA 2000 (X) waiver to
prescribe buprenorphine-containing medication products for the treatment
of opioid use disorder. SAMHSA additionally dropped the limit on the
number of patients to whom physicians may prescribe buprenorphine. The
removal of these barriers to treatment represents a significant victory in
the battle to reduce opioid addiction and overdose, one in which the WSMA
and a coalition of Washington stakeholders played a critical role. Learn
more on our
Medications for Opioid Use Disorder
page, where you'll also find resources to get started prescribing these
life-saving medications.
New DEA registration requirement
The Consolidated Appropriations Act of 2023 requires a new training for
physicians, physician assistants, and health care professionals who need
DEA registration as a condition of employment or to prescribe controlled
substances in Schedule II-V.
Starting in June 2023, upon registration with the DEA or renewal of a DEA
number, physicians will be required to complete eight hours of training on
the treatment and management of opioid use disorder or substance use
disorder. The DEA and the SAMHSA released
guidance around this new requirement.
The WSMA, with the Washington Society of Addiction Medicine, Women and
Addiction Group, and CHOICES Education Group, hosted an education series
in June to help physicians and physician assistants meet this new
requirement. Access the recordings and materials on our
Compassionate Addiction Medicine
page.
CMS releases pain management codes for Medicare physicians
The Centers for Medicare and Medicaid Services rolled out new codes for
bundled care effective Jan. 1, 2023. These codes describe a composite of
services that pain-treating physicians provide to a patient every month.
Rather than billing a la carte for these services, health care
professionals can now report the bundled code monthly as a simpler way to
collect for the care provided.
G3002 includes assessment, diagnosis, and monitoring of the patient's
pain, including working with other clinicians to manage treatment. Note
that this code can only be applied to the first 30 minutes of chronic pain
management care.
For health care professionals who spend more than 30 minutes with their
patient, use the new add-on code, G3003.
Learn more by reviewing the
2023 Medicare Physician Fee Schedule Final Rule
released in November 2022.
WSMA Prescribing Resources
Education to meet state and federal prescribing requirements
Compassionate Addiction Medicine education series
The WSMA, with the Washington Society of Addiction Medicine, Women in
Addiction Group, and CHOICES Education Group, offers comprehensive
on-demand education on the treatment and management of opioid use disorder
and other substance use disorders that meets the eight-hour requirement
for DEA-registered physicians and physician assistants, outlined in the
Consolidated Appropriations Act of 2023. This activity is approved for
AMA PRA Category 1 CreditTM.
Opioid Prescribing Regulations Post-COVID-19 Public Health Emergency
WSMA members only—sign-in required
This on-demand training, available exclusively to WSMA members, meets the
state's one-time, one-hour continuing medical education on opioid
prescribing requirement for MDs, DOs, and PAs. This activity has been
approved for AMA PRA Category 1 CreditTM.
Pain management rule requirements checklist
WSMA Pain Management Rule Requirements Checklist
- updated February 2020
Use this updated document to build prompts into your electronic health
record (e.g., Epic dot phrase) or simply use as a checklist to help you
successfully incorporate opioid prescribing rule requirements into your
practice workflow.
Other Prescribing Resources
DOH handouts to meet state requirement for patient education
The Department of Health offers
patient handouts
(look under Public/Patient) for all categories of pain patients (chronic,
surgical, acute, and subacute) to satisfy a new state requirement for
prescribers to inform patients of the risks, safe storage, and safe
disposal of prescription opioids.
Connecting to the prescription monitoring program
Access prescription drug monitoring program data through the state Health
Information Exchange or directly through the state's PMP vendor, Bamboo
Health:
PMP Gateway.
PMP Gateway integrates multi-state prescription drug monitoring program
intelligence into existing clinical workflows, improving access and saving
time for care team members.
PMP Gateway delivers full transparency into prescription drug monitoring
program data and analytics by integrating directly into the workflows of
500+ clinical systems including electronic health records, pharmacy
management systems and health information exchanges—saving an average of
four minutes per patient search, making it easier to comply and improve
patient safety.
Learn more about the benefits of PMP Gateway and its impact by reviewing
the webpage most applicable to you, below:
More resources
Washington State Department of Health opioid prescribing webpage
Washington Agency Medical Directors' Group prescribing guidelines and
resources
CDC Clinical Practice Guideline for Prescribing Opioids for Pain,
2022