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LARA Updated Michigan Opioid Laws FAQs

LARA Updated Michigan Opioid Laws FAQs

Monday, June 11, 2018

Drafted by the Department of Licensing and Regulatory Affairs (LARA) and the Michigan Department of Health and Human Services (DHHS) to provide clarification to help with implementation of the Michigan Opioid Laws, the frequently asked questions have been updated as follows:

PA 246 of 2017 - Start Talking Form:

Q-5a, Page 6 - Added the word "or unlicensed" to be consistent with what the delegation provision of the Public Health Code, MCL 333.16215.

Q-5b and 6b, Page 6 - Added: "Please note that not all prescribers as defined under the Public Health Code have the ability to delegate under the delegation provision of MCL 333.16215."

Q-7a, Page 6 - Added: "Continuation of the established previous therapy does not require a new form."

Q-7c, Page 6 - Added: "If the prescriber starts to treat the patient with a new opioid the form would need to be signed and saved in the patient file.

Q-7d, Page 6 - Added: "When changing the dosage of the same opioid prescription, in a course of treatment, the form would not need to be signed and saved in the patient file."

Q-8a, Page 7 - Added: "For example, administration of the opioid for inpatient stay within, but not limited to, a hospital, freestanding surgical outpatient facility, skilled nursing facility, hospice, homes for aged, etc."

Q-8c and 8d, Page 7 - Added: Reference about the Public Health Code definition of "Administer" and definition of "Dispense".

PA 248 of 2017 - MAPS Registration & Use:

Q-2b, Page 9 - Added: "This law does not apply to a prescriber who orders a schedule 2-5 controlled substance for inpatient administration."

Q-2c, Page 9 - Added: Clarified when a licensed veterinarian has to review MAPS.

Q-2d and 2e, Page 9 - Added: Reference about the Public Health Code definition of "Administer" and definition of "Dispense".

Q-3a and 3b, Pages 9-10 - Added: New question regarding issuing multiple prescriptions and "do not fill until date".

Q-4a, Page 10 - Added: In addition to the website for MAPS, added reference about training videos also can be found on this site.

Q-9b, Page 11 - Added: "Please note it is important that the prescriber reviews the MAPS report prior to prescribing or dispensing a schedule 2-5 controlled substance that exceeds a 3-day supply.

Q-20b , Page 13 - Added: "Please note, prescribers and dispensers are not required to save a copy of the MAPS report, whether electronic or hard copy, as the software system that MAPS operates on also has audit trail capabilities."

PA 251 of 2017 - Acute Pain:

Q-1c, Page 14 - Added: "This law does not apply to chronic pain."

Q-3a, Page 15 - Added: Question about whether law applies to veterinarians, which it does not.

UPDATE ON REGISTRATIONS:

Thought you would like to know that as of yesterday, May 31, 2018 we had a significant jump in prescribers and dispensers registering to the new system:

April 4, 2017 - 13,150 registered prescribers and dispensers on go-live date when we transitioned from the old system to the new Appriss Health PMP AWARxE platform solution. In addition, we had 1,096 delegate users registered.

May 31, 2018 - 43,116 registered prescribers and dispensers. In addition, we have 12,475 delegate users registered.

Below is the breakdown by profession:

  Approved as of
4/4/2017
Approved as of
5/31/2018
Increase
from Launch
Physician 5,239 18,902 13,663
Dentist 586 2,327 1,741
Nurse Practitioner 1,085 4,092 3,007
Midwife w/ Prescriptive Authority 5 126 121
Physician Assistant 942 3,816 2,874
Podiatrist 83 376 293
Optometrist 28 92 64
Pharmacist 3,009 5,910 2,901
Pharmacist in Charge 985 1,429 444
Veterinarian 548 1,003 455
Medical Resident 624 4,948 4,324
VA Prescriber 4 53 49
VA Dispenser 0 12 12
IHS Prescriber 0 0 0
IHS Dispenser 0 0 0
Dispensing Physician 12 30 18
TOTAL HEALTH PROF 13,150 43,116 29,966
Pharmacist Delegate - Licensed 159 747 588
Prescriber Delegate - Licensed 206 2,904 2,698
Prescriber Delegate - Unlicensed 731 8,824 8,093
TOTAL DELEGATES 1,096 12,475 11,379
GRAND TOTAL HEALTH PROF 14,246 55,591 41,345

 

There are roughly 30,000 registered prescribers and dispensers with more than 15,000 prescribers and dispensers integrated with MAPS, with thousands more to be integrated.

Here is the direct link to the LARA, MDHHS opioid laws FAQs >>