2/21/2020 9:09 am
Date / Time filed with the Register of Regulations
VA.R. Document Number: R____-______
Virginia Register Publication Information

Transmittal Sheet: Response to Petition for Rulemaking
Initial Agency Notice
X
Agency Decision
Promulgating Board: Board of Medicine
Regulatory Coordinator: Elaine J. Yeatts

(804)367-4688

elaine.yeatts@dhp.virginia.gov
Agency Contact: William L. Harp, M.D.

Executive Director

(804)367-4558

william.harp@dhp.virginia.gov
Contact Address: Department of Health Professions

9960 Mayland Drive

Suite 300

Richmond, VA 23233
Chapter Affected:
18 vac 85 - 21: Regulations Governing Prescribing of Opioids and Buprenorphine
Statutory Authority: State: 54.1-2400 and 54.1-2928.2

Federal:
Date Petition Received 12/02/2019
Petitioner Dr. Lee Tannenbaum
 Petitioner's Request
To amend subsection I of 18VAC85-21-150 to allow prescribing of up to the FDA approved limit of 32 mg QD.
 Agency Plan
In accordance with Virginia law, the petition will be filed with the Register of Regulations and published on December 23, 2019 and posted on the Virginia Regulatory Townhall at www.townhall.virginia.gov. Comment on the petition will be requested until January 22, 2020 and may be posted on the Townhall or sent to the Board.   Following receipt of all comments on the petition to amend regulations, the matter will be considered by the full Board at its meeting in February of 2020.  
Publication Date 12/23/2019  (comment period will also begin on this date)
Comment End Date 01/22/2020
 Agency Decision
Take no action
Agency Response Date 02/21/2020
 Agency Decision Text
Opposition to the change noted that the Federal Drug Administration and the American Society for Addiction Medicine support a maximum of 24 mg per day and that there is little evidence of further benefit from increasing the dosage. It was also noted that if a patient is unable to reach full recovery on 24 mg daily, it signals drug failure and other options must be considered.