Dear Stakeholders,
First, thank you for being extremely patient as LARA and DHHS worked on updating the attached FAQs regarding the Opioid Laws. Also, you can find these updated FAQs online at our MAPS site:
www.michigan.gov/mimapsinfo
- Laws/Regulations
- Frequently Asked Questions Opioid Laws
Direct link is: https://www.michigan.gov/lara/0,4601,7-154-72600_72603_55478_85991---,00.html
The changes that were made to the FAQs are 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
|
As of last week we had roughly 30,000 registered prescribers and dispensers. Thanks to the hard work and efforts of our vendor, Appriss Health, and our dedicated MAPS team, we are current with the registrations and on Monday I will provide the new count as the teams continued to process more throughout the day.
Also, we have over 15,000 of our prescribers and dispensers integrated with MAPS, with thousands more to be integrated.
Finally, our Board of Pharmacy Rules Committee met earlier in the week and added the proposed language from the attached letter that was provided during the public hearing on May 23, see attached, for the bona-fide prescriber patient relationship and this rule set will go back to the full Board for consideration when they meet on June 13 at 10:00 am.
If I missed anyone on this email, please feel free to forward to others who might be interested. In the meantime, I hope this information is helpful and as always please feel free to contact me if I may be of further assistance.
Best regards,
Kim
________________________ _______________
Kim Gaedeke, Deputy Director
Department of Licensing and Regulatory Affairs
611 Ottawa Street, 4th Floor
Lansing, MI 48909
517.243.5044 Cell
[email protected]
www.michigan.gov/lara