William L. Harp, M.D.                                                                                                    January 18, 2018

Executive Director

Board of Medicine

9960 Mayland Drive, Suite 300

Richmond, VA 23233

RE: Regulations Governing Prescribing of Opioids and Buprenorphine

Dear Dr. Harp:

The Medical Society of Virginia (MSV) appreciates the opportunity to comment on the Regulations Governing Prescribing of Opioids and Buprenorphine (18 VAC 85-21). MSV commends the Board’s work in developing strong regulations that reflect prescribing best practices while ensuring the flexibility of professional judgment in extenuating medical circumstances. 

MSV supported the Board’s development of the initial emergency opioid and buprenorphine prescribing regulations enacted in March 2017.  The emergency regulations provided a comprehensive framework of best practices that included consideration of non-opioid treatments, querying the Prescription Monitoring Program, appropriate strength, length, and quantity supply parameters, family history, treatment plans, and recognition of special considerations and populations.  This multi-faceted approach to opioid and buprenorphine prescribing gave prescribers appropriate guidance for the multiple factors that can contribute to opioid addiction, while preserving an option to treat extenuating medical circumstances.    

These efforts by the Board and other partners to recognize, treat, and prevent opioid addiction have had a positive impact on the Commonwealth.  In the past year, the number of individuals receiving high doses of opioids decreased by 18.6%, opioid doses declined by 40.15%, and multiple provider episodes per 100,000 Virginia residents decreased by 45%.

To continue Virginia’s progress in aligning with prescribing best practices, MSV supports enacting 18 VAC 85-21.  MSV is dedicated to reducing opioid addiction in Virginia by partnering with the Board and other state government agencies and stakeholder groups and by providing prescribing resources to physicians.  MSV’s opioid resource webpage gives physicians access to prescribing tools, best practice guidelines, and continuing education resources: http://www.msv.org/opioids.  

MSV extends its support of the Board in its attention to the opioid crisis and is dedicated to working together. 

Sincerely,

Melina Davis-Martin

Executive Vice President

CC:

David Brown, D.C., Director, Department of Health Professions

Elaine Yeatts, Policy Analyst, Department of Health Professions

Scott Johnson, General Counsel, MSV

Lauren Bates-Rowe, Assistant Vice President of Health Policy, MSV

Ralston King, Assistant Vice President of Government Affairs, MSV