May 2, 2017

William L. Harp, M.D.                                                                                                                          

Executive Director

Board of Medicine

9960 Mayland Drive, Suite 300

Henrico Virginia 23233

RE: Regulations Governing Prescribing of Opioids and Buprenorphine 18 VAC 85-21

Dear Dr. Harp:

The Medical Society of Virginia (MSV) appreciates the opportunity to provide public comment on the Emergency Regulations Governing the Prescribing of Opioids and Buprenorphine (18 VAC 85-21).  MSV greatly appreciates the work of the Board to develop regulations that promote appropriate prescribing of opioids and buprenorphine, while maintaining physician discretion to offer treatment that best meets the medical needs of patients in extenuating circumstances. 

Further, MSV supports the multi-stakeholder approach that incorporated best practices and considered the practical application in clinical settings.  We look forward to continued work with the Board of Medicine, physician experts, and community stakeholders, on the implementation of these regulations, as well as future regulations on these topics.

MSV continues to support the Board in its efforts to reduce opioid addiction in the Commonwealth and is committed to working collaboratively to address the opioid crisis. 

Sincerely,

Bhushan Pandya, M.D.

President

CC:

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

Elaine Yeatts, Policy Analyst, Department of Health Professions

Melina Davis-Martin, Executive Vice President, MSV

Scott Johnson, General Counsel, MSV

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

Ralston King, Assistant Vice President of Government Affairs, MSV