october 12,2017 Charles D. Miles, M.D. Missi State Board of Medial censure 1867 Crane Rie Drive ‘eC a TEAONG ne TREES suite 200-8 Jackson, MS 39216, ear Or. Miles and Members ofthe Msissipp State Board of Medial Licensure: On behalf ofthe Misisspp Section American Congress of Obstetricians and Gynecologits, we ack the ‘Board of Atelel Licensure to take ini consideration concerns our phrilan members have with Proposed Rule Pact 2640 Prescribing, Administering and Dispensing, White we ae supportive ofthe Board taking proactive steps to combat the opioid epidemic, we feelthat Proposed Rule art 2640 places an excessive and unrealistic administrative burden on the cial race of medicine Requiring every new patient seen by physician in Mississippi must have a PMP generaton, regardless I the patient is being prescribed a controled substance laces an excessive and unealstc administrative burden onthe practice of medicine Reauiting that documentation be kept athe patient record requires lrfiaton a5 tthe documentation. sufiient to document inthe einial note that a prescnption was provided and \whatinformation needs to be prouded? There ae medicolegal raison placing 2 PMP in 2 Daten’ chart and tis racess would place an excessive and unrealitie administrative burden on the practice of medicine ‘These are jst afew of the lesues our members have cncermed with Proposed Rule Part 2460, We would welcome the opportunity te meet withthe Board to give constructive feedback on how the Board ‘an adopt mare reasonable regulations that elect national standards developed by ou soceties and Regards, yy iy a shannon Carol Se, 0.0 1 Seago, MD. Chair Vice Cie Missing Section, ACOS Mass Section, ACO a Brandy Patterson, M.0. Secretar/Teeasuer Missioi Section, ACOG ses1/0?5/0% mesJACKSON HEALTHCARE FOR WOMEN 201 East Layar Orvo Flonood Mississippi 3232 ‘OFFICE 601) 086-0190 Fax (01) 832-6714 sew peecom ‘Greecouser ‘© SHANNON CARROLL SR, 00} ove COOK. MO {SHADE COOLEY. MD October 12, 2017 “Mississippi State Board of Medical Licensure 1867 Crane Ridge Drive, Suite 200-B Jackson, Mississippi 39216 Dear Members ofthe Mississippi State Board of Medical Licensure: While we are generally supportive of proactive steps to combat the opioid epidemic, we fel the Proposed Rule Part 2640 places an excessive and "unrealistic administrative burden onthe clinial practice of medicine, FFurthemnore, we believe the proposed changes may have unintended adverse consequences. (Our specific concems include: ‘The requirement for all licensees to run a PMP report at each encounter when prescribing opioids for acute or chron pain i an overriding administrative burden and impractical to accomplish in the care of patients and the practice of clinical medicine ‘The requirement that PMP reports be kept in the patient file is duplication of work and an administrative burden. Placing a PMP report in a medical record may have serious medico-legel implications in the future, ‘unintended consequence. ‘Prohibition from prescribing more than a 7-day supply of opioids for weute pain is a vague rule which may have the unintended consequence of | physicians prescribing higher counts to dispense or stronger dosages than ‘usual t avoid eall backs. "Many patients take benzodiazapines chronically and may oqure treatment for acute postsurgical pain and for longer than seven days. "The requirement for “informed consent” prior to presribing opioids is vague, and again, an admnistrative burden. Who isto say what constitutes @ valid informed consent in these situations? ‘Perhaps the most striking omission in this proposed rule is the apparent lack of eoncem and compassion for the post operative patient and, in our practice, the obstetrical patient. All of these patents hurt after their surgery andr procedure. Many, if not most, have contraindications toPage? ‘nonsteroidal medications and other non-opioid methods of pain relief. Many require pin ‘management for longer than seven days and opioids have been, and will remain, the mainstay of management. We implore the Board to waive any preposed rule (or perhaps ‘up to 30 days) forthe pain management of post operative and obstetrical patients *Opicid prescriptions for acute postoperative pain ae written a inpatient or outpatient surgical centers and are recorded inthe facility record. Requiring the physician to maintain an affice PMP report for each ofthese prescriptions ie a impractical and unreasonable administrative burden ‘The requirement that physicians generate a “global” PMP report each year is ‘duplication of work and burdensom. The PMP information i already available tothe MSBML for review. Proposed Rule Part 2640 isa legal document that is detailed, but imprecise, and in many areas quite vague. As a legal document it will likely be open to many differing legal opinions making compliance difficult, if not impossible. Physicians are not lawyers. ‘We take care of patents and administrative burdens from many sources make our job ‘more difficult every day. As these are rules for physicians, we imalore you to simplify this document rather than making it more complex. {In summary, these proposed rules will place a significant administative burden on ‘medical practices, especially those providing acute surgical serves and will bea significant impediment to providing care for these patients. Is Ekelythat obstetricians and gynecologists may simply refuse to preseribe opioids, even for patients who really reed them. We fear public outery should these rules be implemented inthe proposed form, ‘Thank you for allowing us to comment and we hope you take these comments into consideration. Sincerely, (Charles C. Bush, MD. Bra S. Kimmel, MD . Shannon Carroll, DO . Mercer Lee, MD Karen F. Cole, MD Kathryn H. Mallette, MD John W. Cook, MD Kimberly P. Nichols, MD Chad E. Cooley, MD Dardes H. North, MD Layson L. Denney, MD ‘Amanda A. Reeves, MD Lisa T. Gibson-MeKee, MD 4. Martin Tucker, MD Emily B. Johnson, DO Christopher, D. Wiggs, MD Roy B. Kellum, MD