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The Joint
Rules Committee (representing the Fl Board of Medicine and FL Board
of Osteopathic Medicine) met for two consecutive days to further
complete its work on determining rules that apply to physicians who
treat patients by prescribing or dispensing controlled substances
for the treatment of non-malignant pain at a pain management
clinic.
It is
considered that the Standard of Care for the treatment chronic pain
is multidisciplinary and not prescription-based only.
You have
been updated from previous meetings. This note is to update changes
made at this most recent Rules Committee meeting. Your FAPM was in
attendance and participated in the process to represent your needs
as an FAPM member.
Board
Certification: “Board Certified” in Pain Management means anyone
holding an ABMS subspecialty-certification in pain medicine or Board
certification by the American Board of Pain Medicine or Board
Certification by the AOBA with added qualifications in Pain
Management.
Significant
items include:
Physicians suspecting diversion
will not be required to report such diversion to law enforcement
within 48 hours. However, if you do suspect diversion, you must
discharge the patient, and document in your chart results of testing
and your actions.
Urine drug testing is mandated
before starting any treatment with controlled substances, and
randomly throughout treatment. This may be done via:
referral to an outside CLIA-certified
lab, or
in your office in a container
that measures pH, specific gravity, and temperature, and then send
the urine to a CLIA-certified lab.
Each physician’s medical record
must contain the physician’s full name in a legible manner.
Additionally, each clinic must maintain the full name, signature,
and initials of every physician, anesthesiologist assistant, and
physician assistant working in the clinic.
For patients currently in
treatment who exhibit evidence or behavioral indications of
substance abuse, you must refer the patient for consultation to an
addiction medicine specialist, board certified pain medicine
specialist, or a mental health addiction facility. You may continue
to treat within the prevailing standards of care until the
consultant’s report is obtained, and continue controlled substances
beyond that if the report gives written concurrence with such.
Training requirements for Pain
Clinic physicians: there are several routes of qualifications:
Board certification in Pain
Management
Completion of a ACGME/AOA
fellowship within the last three years
Current staff privileges to
practice pain medicine in a licensed FL hospital
Until January 2012, three full
years of pain management practice, attendance and successful
completion of in-person, live participatory Category I CME in pain
management that includes a prescribed set of topics, hospital
privileges in any category, and practice under the direct
supervision of a Board certified (or eligible) physician; or have
the practice reviewed by a Florida licensed risk manager and
document compliance with all recommendations of the risk management
review
After January 2012, if you don’t
qualify under a-d above, then you must take and successfully
complete an 80-120 hour course given by a Fl medical school, and
this must be repeated every biennium.
After the effective date of these
Rules, any newly registering pain clinic shall assure that at any
time the clinic is open and patients are being seen, there is at
least one board-certified pain management physician on the premises.
Any pain clinic, as defined in
these Rules, must register with the state as a pain clinic. All such
registered pain clinics will be subject to annual inspections, which
must include review of between 25-50 charts of patients treated for
pain, selected by the reviewer. The results of the inspections will
be submitted to the state and determinations of how to handle
deficiencies will be made by the state.
These Rules will now be presented
(also included as an email attachment), by the Rules committee, to
the FL Board of Medicine and the FL Board of Osteopathic Medicine
for their consideration. Your FAPM will be in attendance at these
meetings, as well, and it is anticipated that there will be
challenges to the Rules and workshops requested to review them. FAPM
will continue to have input into these rules, as allowed, and keep
you posted on all further developments of interest to our members.
Additionally, FAPM will
also be working
with the Legislature as it works on further legislation. |
