May 3, 2017

William L. Harp, M.D.

Executive Director

Board of Medicine

9960 Mayland Drive, Suite 300

Henrico Virginia 23233

Re:       Emergency Regulations Governing the Prescribing of Opioids and Buprenorphine (18 VAC 85-21)

Dear Dr. Harp,

The Virginia Hospital & Healthcare Association (VHHA) supports the efforts of the Board of Medicine to develop these Emergency Regulations Governing the Prescribing of Opioids and Buprenorphine (18 VAC 85-21) with input from stakeholders and other concerned citizens.  The thoughtful approach taken to developing these regulations strikes an appropriate balance in establishing clear guidelines for health care providers without impeding the delivery of effective patient-centered care.  We note that many of the guidelines are consistent with the Virginia Hospital Emergency Department Opioid Prescribing Guidelines jointly developed by VHHA and the Virginia College of Emergency Physicians in January 2016.  Having these accepted practices incorporated into regulation will further promote appropriate prescribing of opioids and buprenorphine and better patient care across the Commonwealth.

There is far more that can and must be done, but these regulations are another important step in attempting to reduce the prevalence and incidence of substance abuse and opioid related deaths.  VHHA and its members are committed to continuing to review and update these regulations as the medical standard and best practices evolve to ensure that Virginians are protected from harm and receive the best patient care possible.                                                          

Sincerely,

R. Brent Rawlings

Vice President and General Counsel