Your “quick start” guide to the STOP Act of 2017Comments: 5 comments
Effective July 1, 2017
Opioid Prescribing Consultations with Supervising Physician
Physician Assistants and Nurse Practitioners prescribing targeted controlled substances are required to personally consult with the supervising physician if (1) the patient is being treated at a facility that primarily engages in the treatment of pain by prescribing narcotic medications or advertises for any type of pain management services, and (2) the therapeutic use of the prescription will, or is expected to, exceed 30 days.
Furthermore, when prescribing to the same patient continuously, Physician Assistants and Nurse Practitioners are required to consult with a supervising physician at least once every 90 days to verify that the prescription remains medically appropriate.
The Board has directed NCMB staff to develop a formal definition of “consultation,” with the intention of eventually adopting rules to guide PAs, NPs and their supervisors. Draft language is expected to be presented to the Board for review at the September 2017 Board meeting.
Streamlined Set Up of Delegate Accounts
This provision streamlines the process of creating delegate accounts for prescribers in emergency departments in the North Carolina Controlled Substances Reporting System (NC CSRS). To register delegates visit www.ncmedboard.org/NCCSRS. Delegate accounts must be linked or associated with the prescriber(s) for whom the delegate will complete queries.
Effective September 1, 2017
Timely and Accurate Prescription Reporting by Pharmacies Pharmacies are required to report prescriptions to NC CSRS by the close of business the day after a prescription is delivered (previously the law required pharmacies to report the prescription within three days of the date it was delivered).
In addition, the STOP Act authorizes NC CSRS to assess monetary penalties against pharmacies that do not supply correct data to NC CSRS after being informed that information is missing or incomplete.
Provisions effective January 1, 2018
Limitations on Prescriptions for Acute Pain Acute pain is defined as pain, whether resulting from disease, accident, intentional trauma, or other cause, that the practitioner reasonably expects to last for three months or less. It does not include chronic pain or pain being treated as part of cancer care, hospice care, palliative care, or medication-assisted treatment for substance use disorder.
Practitioners cannot prescribe more than a five-day supply of any Schedule II or Schedule III opioid ornarcotic upon the initial consultation and treatment of a patient for acute pain unless the prescription is for postoperative acute pain relief for immediate use following a surgical procedure, in which case the prescription cannot exceed a seven-day supply.
Upon subsequent consultation for the same pain, practitioners may issue any appropriate renewal, refill, or new prescription for a targeted controlled substance.
This provision does not apply to prescriptions issued by practitioners ordering targeted controlled substances to be wholly administered in a hospital, nursing home, hospice facility, or residential care facility.
Practitioners acting in accordance with these limitations are immune from civil liability and disciplinary action from this Board.
Provisions effective January 1, 2020
Practitioners must prescribe electronically for all targeted controlled substances. This provision does not apply to:
Provision effective upon completion of NC CSRS technical upgrades* (date TBD) Mandatory Review of NC CSRS
*DHHS will work on various technical upgrades to NC CSRS in order to make the system more user-friendly, improve reporting capabilities, provide inter-state connectivity with other Prescription Drug Monitoring Systems, and connect to the statewide health information exchange. Mandatory NC CSRS registration and use provisions become effective once the State Chief Information Officer confirms the required upgrades to NC CSRS are fully operational within the Department of Information Technology and the system is connected to the statewide health information exchange.
Prior to prescribing a Schedule II and Schedule III opioid or narcotic, practitioners are required to review a patient’s 12-month prescription history in NC CSRS.
For every subsequent three-month period that the Schedule II or Schedule III opioid or narcotic remains part of the patient’s medical care, practitioners are required to review the patient’s 12-month history in the NC CSRS.
Reviews should be documented within the patient’s medical record, along with any electrical or technological failure that prevents such review. Practitioners are required to review the history and document the review once the electrical or technological failure has resolved.
Certain practitioners may, but are not required to, review NC CSRS when prescribing a targeted controlled substance to a patient in any of the following circumstances:
The STOP Act authorizes NC CSRS to conduct periodic audits to determine prescriber compliance with review requirements. NC CSRS shall report to the Board any licensee found to be in violation of the requirement to check the system; violations may result in regulatory action by the Board.
What are targeted controlled substances?
Most of the provisions in the STOP Act apply to licensees who prescribe “targeted” controlled substances. These are select medications listed in N.C. Gen. Stat. § 90-90(1), (2) or 90-91(d).
What’s on the list?
All Schedule II and Schedule III opioids and narcotics; medical professionals who prescribe must comply with STOP Act provisions.
Stimulants and hormones; any other medication that is NOT listed in N.C. Gen. Stat. § 90-90(1), (2) or 90-91(d)
Comments on this article:
I would like to know what the limit is on the number of Physician assistant and Nurse Practitioners for which a physician is responsible.By kurt lauenstein, MD on Aug 29, 2017 at 5:21pm
This article is fairly informative but surely the authors could have included the names of the drugs included and not included. The common list can not be that long.By Laura Berglund on Aug 29, 2017 at 6:17pm
I checked the link to the Gen Stat but that mostly concerns the level of felony charges, not the names of included or excluded drugs.
I don’t prescribe many controlled substances but still like to remain informed. This article was not too helpful in that regard.
Dr. Lauenstein: There is no limit on the number of supervisees a licensee may assume responsibility. However, the Board expects licensees to fully comply with all requirements of supervision, for all supervisees. A licensee should not take on so many supervisees that he or she is unable to properly fulfill these obligations (conducting regular QI meetings, being available to consult on patient care, etc.)By Jean Fisher Brinkley on Aug 30, 2017 at 12:02pm
Dr. Berglund: Thank you for the suggestion. I have created direct links to the relevant statutes that list the targeted controlled substances, at the end of the article above. I hope this helps.By Jean Fisher Brinkley on Aug 30, 2017 at 1:28pm
Dr. Berglund, Thank you for the great suggestion. The article has been modified to link directly to the NC Controlled Substances Act. This should help readers more easily familiarize themselves with “targeted controlled substances.”By Jean Fisher Brinkley on Sep 22, 2017 at 11:19am