Controlled Substances CME requirement
How do I let the Board know I have completed the required controlled substances CME?
Licensees are not required to notify NCMB they have completed the required CS CME. Please DO NOT email, fax or send CME certificates to the Board. NCMB recommends that licensees keep documentation of CME courses completed. If selected for a CME compliance audit, you will be asked to provide documentation at that time.
During annual license renewal, licensees who prescribe controlled substances are asked to acknowledge that they have been informed of the CS CME requirement and that they understand they are responsible for complying.
NEW! I am a physician or PA who only orders or administers controlled substances to hospitalized patients, patients at an ambulatory care surgery or procedure center, or similar facility (e.g., anesthesiologist, radiologist, hospitalist, etc.), and I do not "prescribe" controlled substance by means of a written or electronic prescription. Am I required to obtain the required controlled substance CME?
Yes. Licensees who prescribe, order, supply, administer, or otherwise provide controlled substances to patients under their care must complete the mandated CME.
While there may be a semantic and possibly even practical distinction between prescribing to patients by writing a prescription and ordering medications to hospitalized patients, the Board has determined that hospital or institutional based licensees (with the exception of physicians holding only a Resident Training License) who order and/or administer any controlled substance to a patient using either their own DEA registration or by means of an institutional DEA registration, directly or indirectly, are required to obtain the CME.
Who is subject to NCMB’s CS CME requirement?
Physicians, including residents who hold a full NC medical license, and physician assistants who prescribe controlled substances.
What is the CS CME requirement for physicians?
Physicians must complete three hours of CS CME that cover educational topics specified by NCMB during each three-year CME cycle.
What is the CS CME requirement for physician assistants?
Physician assistants must complete two hours of CS CME that cover educational topics specified by NCMB during each two-year CME cycle.
How do I find out when my CME cycle ends, so I will know how long I have to complete CS CME?
In most cases, the CS CME cycle is the same as the licensee’s general CME cycle. If a physician does not know his or her cycle year, he or she can email the renewal coordinator at .(JavaScript must be enabled to view this email address) to inquire about the CS CME cycle year.
PAs may follow their two-year NCMB CME cycle or, if certified through NCCPA, they may follow that organization’s two-year certification cycle. PAs should pick one method for determining their CS CME cycles and follow it consistently.
Is the CS CME requirement a one-time requirement or are licensees be required to earn CME in controlled substances prescribing on an ongoing basis?
The CS CME requirement is ongoing. Licensees who prescribe controlled substances must earn CS CME during each new CME cycle.
May I claim credit for CME hours I have already completed if the course content fulfills the requirements stated in the rule?
Yes. If the CME course is completed during a cycle that renews on or after July 1, 2017, then the credit can be claimed even if the course was taken prior to July 1, 2017 (Note: again, the course must have been completed within that CME cycle).
How should a PA determine his or her two-year CME cycle for the purpose of complying with the controlled substances CME requirement?
PAs who maintain NCCPA certification, and are exempt from the general requirement to report CME hours to the Board, may use their current NCCPA two-year cycle.
PAs who currently report CME hours to the Board should use the two-year cycle that started the first birthday after they obtained state licensure.
The most important thing is to obtain the required CME, and to be consistent with the two-year cycle you choose to follow for the purpose of recording and reporting CME.
Are any licensees be exempt from the controlled substances CME requirement and, if so, who?
Yes. Licensees who have not prescribed ANY controlled substances (opioid or non-opioid) since they last renewed and physicians holding a Resident Training License are exempt from the requirement.
How do I request exemption from the requirement if I believe I qualify?
It is not necessary to request exemption. However, NCMB will continue to conduct random CME audits to verify exempt status.
I don’t prescribe any medications in my current clinical role. Do I have to comply with the CME requirement?
No. Only licensees who prescribed controlled substances (including non-opioids) during their most recent CME cycle are subject to the requirement.
I prescribe medications but I do not prescribe any controlled drugs. Do I have to comply with the requirement?
No. Only licensees who prescribed controlled substances (including non-opioids) during their most recent CME cycle are subject to the requirement.
I hold an active NC license and I prescribe controlled substances but I do not practice in NC. Must I comply with the new CS CME requirement?
Yes. There is no exemption for licensees who practice outside of NC. If you prescribe controlled substances and hold a NC license, you must comply with the CME requirement for controlled substances prescribers.
I prescribe medications, including controlled substances (e.g. hormones, stimulants), but I do not prescribe ANY opioids. Do I have to comply with the requirement?
Yes. The requirement applies to physicians and PAs who prescribed ANY controlled substances (including non-opioids) during their most recent CME cycle.
I prescribe controlled substances but only occasionally prescribe opioids to my patients. Do I have to comply with the requirement?
Yes. The requirement applies to physicians and PAs who prescribed ANY controlled substances (including non-opioids) during their most recent CME cycle.
I am retired and do not treat patients or prescribe, but I do maintain an active license and am required to complete CME. Will I need to comply with the new requirement?
No. If you did not prescribe any controlled substances in your most recent CME cycle, you are not subject to the requirement. However, as previously required, retired physicians or PAs who maintain an active license will still need to comply with the general CME requirement currently in place.
How can licensees find CME courses that fulfill the requirement?
There are many existing online and in-person CME courses that appear to meet the requirement. Licensees may select any course that is ACCME Category 1 or similar that covers “controlled substances prescribing practices, recognizing signs of the abuse or misuse of controlled substances, and controlled substance prescribing for chronic pain management,” as stated in the revised rule.
Does the Board publish a list of recommended CME courses?
Yes. The Board provides links to high quality free and low-cost opioid prescribing courses on its website as it becomes aware of them. Check www.ncmedboard.org/prescribingCME.
It would not be possible for the Board to maintain a current and complete list of available courses that meet the CS requirement. Please understand that NCMB does not maintain an exhaustive list of courses that meet the new requirement. Licensees are responsible for ensuring courses meet the content requirements to fulfill the CME requirement.
I prescribe non-opioid controlled substances and therefore must comply with the new requirement. Will the Board accept CME that deals with appropriate prescribing of controlled substances in my area of practice?
Possibly. If the instruction is focused on your specific area of practice, but the primary topic of the instruction is controlled substances prescribing practices, recognizing signs of the abuse or misuse of controlled substances or controlled substance prescribing for chronic pain management, then that instruction will count towards the requirement. However, the total hours of CME taken to fulfill the proposed requirement ultimately must cover all three topics.
There are different types of pain patients (acute pain, chronic pain, cancer patients, hospice), all with different needs. Will NCMB encourage licensees to complete CME that is most relevant to the patient populations they serve?
The total hours of CME taken to fulfill the requirement, not individual courses, ultimately must cover all three topics. As approved, the requirement stipulates only that courses cover “controlled substances prescribing practices, recognizing signs of the abuse or misuse of controlled substances, and controlled substance prescribing for chronic pain management.” As long as the collective CME taken meets these three basic requirements, licensees are encouraged to choose courses they think will be most practice relevant.
I am continuously engaged in a recertification program from an ABMS, AOA or RCPSC specialty board. Am I exempt from the requirement?
No. All physicians licensed by the Board (other than those holding a Residency Training License) who prescribe controlled substances must satisfy the controlled-substance prescribing CME requirement set forth in 21 NCAC 32R .0101.
Any physician who qualifies for the MOC exemption in 21 NCAC 32R .0103 and who, as part of their MOC process, completed CME that specifically satisfies the requirement in 21 NCAC 32R .0101 is not required to take controlled-substance prescribing CME beyond that included in their MOC process.
Licensees whose MOC activities do not include controlled substance prescribing CME as required by 21 NCAC 32R .0101 must complete additional CME that satisfies the requirement. All physicians subject to 21 NCAC 32R .0101 will be asked to affirm that they have completed the required CME, but will not be required to submit documentation of courses completed unless this is specifically requested by the Board.
What education topics must be covered for courses to count towards the new CME requirement?
There are three topics that must be covered:
• Controlled substances prescribing practices
• Recognizing signs of the abuse or misuse of controlled substances
• Controlled substance prescribing for chronic pain management
If multiple courses are taken to reach a total of three hours topics., keep in mind that each course need not cover each education topic. Licensees should just ensure that each education topic is covered at least once during each CME cycle.