Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing Prescribing of Opioids and Buprenorphine [18 VAC 85 ‑ 21]
Action Initial regulations
Stage Proposed
Comment Period Ended on 1/26/2018
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19 comments

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11/29/17  8:34 pm
Commenter: Melissa Messick

Urinalysis Costs
 

I have a problem not with this law but with the cost to me and my insurance company, that I will explain in hopes of finding a solution. A brief Background:

I’m a 62 year old female I have documented cases of Arthritis, Sjogrens Syndrome, I also have had a pelvic sling which went very badly. These left me immobile due to swelling and pain, this was for the best part of two years. I was self-medicating with a lot Excedrin to be able to perform the smallest of daily living. My doctor that did the  pelvic sling told me there was nothing else he could do for me. Two years ago my blood count bottomed out and I was hospitalized with only 4000 platelets which was life threatening.

Since that time several wonderful doctors have given me my life back. The medications and the doses were all trial and error to get to this point. I’m building myself back up and enjoying doing things with my children and grandchildren again. I am able to hold down my job now with the Virginia Employment Commission (pay band three.)

This new law that is in affect that states that I have to take a drug test every so often. I do not mind doing this. I took time off from my job and paid for an office visit that I didn’t need. My doctor did the test and it was sent to Labcorp. The test came back as expected. Then I get a bill for the test at the cost of $221.00 for my part of the test and the insurance had to pay the remainder of the $425.00.  I will still need to purchase the Medication. This something that I cannot afford and I certainly hate to go into debt for. I only take one Tramadol or two a day along with the other medications not on your list.

I hope you can see the issue I take with this Law. There are others I feel sure that are on a fixed income for example the elderly, terminally ill, cancer patients etc. that this will impact greatly. Again the elderly and the lower income population will not be able to received proper care.

I would be happy to speak to someone further.

Melissa Messick

lion6255@aol.com

 

 

 

CommentID: 63289
 

11/30/17  8:46 am
Commenter: Debbie Peters

Urinalysis
 
I am in agreement with Ms. Keswick regarding the need for lab charges for urine testing each time a needed prescription has to be refilled. Who can afford this? I am State employee with insurance and wpykd struggle to make these payments monthly in addition to the cost of the medications. I cannot imagine how a lot of people without insurance or low paying jobs could manage. I think someone needs to reconsider this issue.
CommentID: 63290
 

11/30/17  1:46 pm
Commenter: Sharon Fassold

Testing
 

While I agree with the spirit of the law, please reduce the cost of testing.

CommentID: 63291
 

11/30/17  7:08 pm
Commenter: Susan melton

High cost of testing
 
I feel that this charge is astronomical to those of already struggling to pay for overpriced meds. It is unfair to legitimate people who need these meds.
CommentID: 63293
 

12/3/17  6:16 pm
Commenter: Brenda Crouch

Testing Cost
 
For the average person this testing would be extremely high and time consuming.
CommentID: 63295
 

1/13/18  1:29 pm
Commenter: Tracy Jon

I think patients like see with Sickle Cell should not be limited to pain meds
 

As a teen, my parents have told me that I will not get the same dose or amount of pain meds I had in the past because docs are afraid to help kids like me it's not right.

CommentID: 63366
 

1/16/18  3:45 pm
Commenter: Floence Neal Cooper Smith, Retired Director of The VASCAP,VCU/MCV

Pain Medication or Sickle Cell Patients
 

It is very important that sickle cell patients continue to receive an adequate dosage of pain medications that has previously been recommended by their physician. Recently I have spoken to several relatives of sickle cell patients and they are very concerned about the cut back of much needed pain medication relative to the pain that is experience with this health problem.

CommentID: 63371
 

1/17/18  1:55 pm
Commenter: Sitrena Woodson

Opiod guidelines for chronic pain
 

Please ensure that Sickle Cell Disease be made an exception to the guidelines. 

CommentID: 63373
 

1/17/18  7:05 pm
Commenter: Anthony Lofton

Opioid prescription guidelines
 

Im asking that Sickle Cell Disease be made an exception to the guidelines of  opioid prescriptions.

 

CommentID: 63374
 

1/18/18  10:51 am
Commenter: Sickle Cell Association of Central Virginia, Inc.

Opiod crisis.
 

Please make Sickle Cell Disease an exception to the opiod guidelines.  Thank you.

CommentID: 63376
 

1/18/18  12:02 pm
Commenter: Melina Davis-Martin, Medical Society of Virginia

Medical Society of Virginia Comments Regarding 18 VAC 85 ? 21
 

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

CommentID: 63377
 

1/20/18  11:10 am
Commenter: Ronald Dews Jr

Support of Sickle Cell Exception for Opiod Regulation
 

I have 2 boys with Sickle Cell Disease.  I support regulations to control the abuse of opiods but not at the expense of Sickle Cell patients.  Some, not all require available medication that goes beyond the current allowable limits to support there pain management at home or after a hospitalization.  There pain management is suffering with the limits proposed and will in effect cause more ER visits which could have been avoided.  

Please make Sickle Cell Disease an exception to the opiod guidelines.  I thank you and my children that you.

Ronald Dews Jr.

 

CommentID: 63379
 

1/22/18  11:45 am
Commenter: Mandy M. Atkinson, MD Pediatric Hematologist/Oncologist at Carilion

exception for sickle cell patients
 

I would also like the treatment of pain in patients with sickle cell disease to be an exception.  Many of these patients live with chronic pain with acute exacerbations they can manage at home.  Limitations on dosing would hinder their ability to do this and would send them to the ED, which typically would be either unnecessary or an overtreatment of something they could have handled at home.  Even managing children with sickle cell disease with these limitations is challenging.  I also think it is very important that patients with chronic pain know they have medicine when needed.

CommentID: 63380
 

1/22/18  12:56 pm
Commenter: Kimberly F. Johnson

Support Patients With Sickle Cell
 

Due to the national opioid crisis, last year the Virginia Board of Medicine put emergency guideline/rules in place for doctors to follow when they prescribe opioids to all of their patients.  Those guidelines include limits on dosage and long acting opioids needed by sickle cell patients, but they make NO rule exception for persons suffering from the pain crisis of sickle cell. 

Please make Sickle Cell Disease an exception to the guidelines. 

Thank you,

Kimberly F. Johnson

 

CommentID: 63381
 

1/22/18  7:32 pm
Commenter: Tarin Hampton, Sigma Gamma Rho Sorority, Inc.

Opioid Prescriptions
 

Please make an exception for Sicle Cell Patients to be allowed access to this medication for their health condition.

CommentID: 63382
 

1/25/18  5:41 pm
Commenter: Yvette williams, Delicados Inc,

Sickle cell patients should have access to opioids to ease their episodes of pain .
 
CommentID: 63387
 

1/25/18  6:17 pm
Commenter: Terrill Darling

Sickle cell
 
Hello my name is Terrill Darling I'm a sickle cell patient.I'm 42 years old I have full custody of my son who also lives with sickle cell we are both prescribed opiates. I myself have been taking opiates for over 30 years I cannot live comfortably without opiates because it enables me to function. I was recently told by my provider that he wouldn't be comfortable prescribing my pain medication any longer because of the opiate crisis he offered me methadone as an alternative this will not work for me as I've had a Bad experience in the past I have been interviewing at many local and non-local providers to remedy this problem since I was pushed out of my doctors at VCI Virginia Cancer Institute I have experienced nothing but misery because of pain and fatigue I have been hospitalized 5 times since October 31st of 2017 these days has proven to be the worst days of my life. Every doctor has refused to help me because of the opiate crisis I found a doctor who drastically reduced my quantity in potency of my pain medications to adhere to new policies rather than manage my pain. I'm not considered anymore as my Doctor instructed me to take it or leave it. My world is upside down and unbearable now the stability of my son is also in Jeopardy now because I struggle to manage his care also I'm asking for considering an exception for those of us living with this debilitating disease to continue to receive opiates as it is essential to us being able to live a manageable and more comfortable life and not allow us to be victims of our circumstances. Please hear our plea because now were merely only existing. With adequate care many of sickle cell patients are able to function as active members in society.
CommentID: 63388
 

1/25/18  6:29 pm
Commenter: TONI T BUMPASS

Emergency Guidelines for ER opioid prescribing
 
I'm commenting on behalf of a patient with Sickle Cell disease. My 21 year old daughter battles daily with the pain associated with this debilitating blood disorder. Currently the only medicine prescribed for her to use is oxycodone and morphine. Although these meds are addicting, I plead with this medical board to decide on exceptions for individuals with chronic pain such as Sickle Cell. This is an illness that individuals must attempt to cope with for the rest of their lives and currently there is no medicine readily available. Please consider drawing up exceptional regulations for individuals with Sickle Cell. Thank you.
CommentID: 63389
 

1/25/18  6:40 pm
Commenter: Yahmeshau Veney

Exception for sickle-cell
 
Hi my name is Yahmeshau Vene.I am the mother of a five-year-old child living with sickle cell disease. This is a disease that not only affects my son but our whole family. I have been dealing with Doctors Hospitals and Er visits since my son's birth. I have and currently witnessed the effect this disease has on my child mentally emotionally and physically.The unbearable pain is too much for a parent to witness. I experienced long days and nights in hospitals do to pain crisis because of this disease. When I heard that there wasn't a protocol in place for sickle cell patients to continue taking opiates and or an exception for those suffering with this debilitating disease I was floored. What shall I tell my child why I can't help him anymore he needs to be able to live without suffering constantly. I can't comprehend being let down in such a way as a parent and caregiver of a child living with sickle cell. We are asking that you not turn a blind eye on the population who are suffering and at mercy from this awful disease. Life isn't promised but relief can and should be.
CommentID: 63390