Under 18VAC60-21-102 B. "conduct an assessment of the patient's history and risk of substance abuse" is stated.  That is a nebulous statement.  I'd appreciate more guidance.

Under 18VAC60-21-106 I am against the addition of 2 hours CE for pain management every 2 years.  There are dentists who don't prescribe.  There are those of us who've had a very long history of very few prescriptions filled per month, etc.  Making us take 2 hours every 2 years is only good for PR and will not cause us to write fewer prescriptions.  Remember, it was the DEA that reclassified most Class III to Class II and as a result, a patient who leaves my office after surgery now must get a prescription for a narcotic (if I feel OTC's, etc. will not be sufficient), as they will have to come back to the office to get one and many live an hour away and it's likely to be after hours.  I can no longer call or fax one to their pharmacy.  When I asked at a study club how many dentists were writing more scripts than before the DEA action, all hands of those who prescribed went up.  However, we've done an excellent job in educating our patients and few of the prescriptions are actually filled. 

I personally don't like or tolerate the narcotics and have tried to keep patients away from them.  Don't add 2 hours of CE for every 2 years.  There must be a threshold for it.  Also, unless there is new information or proof that there is a problem with dentists prescribing narcotics, the board of dentistry should not require this additional CE.  They have the ability to revisit this issue if a problem is identified and then they could enact emergency regulations to address the specific problem.