Healthcare Provider Frequently Asked Questions

• The new requirements for advanced registered nurse practitioners, osteopathic physicians, osteopathic physician assistants, and podiatric physicians become effective on November 1, 2018.
• The requirements for allopathic physician assistants and medical doctors will become effective January 1, 2019.
• Due to substantial changes in the proposed rules the Dental Commission is holding a hearing date of December 7, 2018 to potentially adopt the new requirements. We anticipate the Dental requirements will go into effect early 2019.

The new rules expand the 2011 rules to include treatment of acute non-operative, acute perioperative (post-surgical), and subacute pain. The new rules also cover other topics, such as patient notification, alternative treatments, co-prescribing and special populations.

Yes, they don't apply when treating patients with cancer-related pain, palliative, hospice, end-of -life care, inpatient and observation hospital patients, or procedural pre-medications.

Yes. Any provider who intends to prescribe an opioid in Washington State must individually register with the Prescription Monitoring Program. This doesn't mean you have to maintain your registration if you can access PMP records via your system's electronic health record (EHR).

Any provider who intends to prescribe an opioid in Washington State is required to adhere to the individual board or commission requirements of the profession. The rules typically require some continuing education in the opioid rules and in opioid prescribing best practices.

Nursing

• All ARNPs who prescribe opioids in Washington State must complete a one-time four-hour continuing education on best practices in prescribing opioids.
• Continuing education hours count toward license renewal requirement and must be completed no later than the first full license renewal period beginning January 1, 2019.

Medical

• See https://wmc.wa.gov/ for CE information for medical providers

Osteopathic

• All osteopathic physicians and osteopathic physician assistants must complete a one-time one-hour continuing education on best practices in prescribing opioids and the current opioid prescribing rules.
• Continuing education hours count toward license renewal requirement and must be complete after the first full license renewal period after January 1, 2019.

Dental

• Dentists must complete a one-time three-hour continuing education on best practices in prescribing opioids and the new opioid requirements.
• Continuing education hours count toward license renewal requirement and must be complete after the first full license renewal period after January 1, 2019.

Podiatry

• All podiatric physicians must complete a one-time one-hour continuing education on best practices in prescribing opioids.
• Continuing education hours count toward license renewal requirements for Category 1 and must be complete after the first full license renewal period after January 1, 2019.

No. Providers may delegate mandatory PMP queries to an authorized healthcare designee, in line with the PMP requirements.

Yes. It may be advisable to run PMP checks before seeing that day's patients.

An authorized healthcare designee is a current healthcare provider credentialed with the Washington State Department of Health. Any healthcare provider credentialed with the state may be a designee to perform PMP queries.

You may use any available technology, including face-to-face. No specific methods must be used.

The disciplinary authorities may conduct random audits on providers to ensure they meet CE requirements. You may be asked to provide copies of completed CE and should always retain these records.

Yes. The continuing education must be completed within the past two years for physicians, dentists, ARNPs and podiatrists. Osteopathic physicians must complete the CE every three years, which is the CE cycle for this profession.

All professions included in the rules require 12 hours on chronic pain management within the past four years in order to be exempt from the consultation requirement. At least two of these hours must be dedicated to substance use disorder.

If you prescribe opioids, yes. Depending on your profession, there is mandatory, one-time continuing education requirement. Depending on your profession, the requirement is one to four hours. Check your profession's rules for the specific requirements.

The consultation requirement is in the requirements. The purpose for the requirement is to make sure the care patients are receiving on higher doses of opioids is carefully supervised. The requirements described in rule include:

• The dosage amount that must not be exceeded without a consultation;
• The conditions under which the dosage may be exceeded without a consultation; and
• Qualification requirements about providers specializing in pain management.

Yes. The rules describe the specific criteria to be an exempt provider or to be considered a pain specialist.

Not necessarily. The rules provide exemptions for urgent or special circumstances. You must document adherence to all standards of practice defined in the rules for your profession.

They affect pain management using opioids medications.

Licensees of the:

• Medical Commission
• Nursing Commission
• Podiatric Medical Board
• Dental Commission
• Board of Osteopathic Medicine and Surgery
• Pharmacy Commission, as well as pharmacists and other healthcare practitioners.

The rules include a generally accepted definition for MED. The boards and commissions determined not to include a conversion table in the rules. Technology, knowledge and medication changes occur frequently. Conversion tables could quickly become outdated. The boards and commissions believe providers should be able to decide which conversion table to use. The Washington State Agency Medical Directors Group (AMDG) provides information on dosing guidelines. Please see the Resources webpage for more information.

The mandatory consultation threshold for adults is 120mg MED. A consultation with a pain specialist is required if the prescribed dosage amount exceeds 120mg MED orally per day, unless the consultation is exempted. The exemptions are listed in the rules. Please see your specific professions requirements for details.

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