The Medical Quality Assurance Commission (MQAC) adopted its final rules for management of chronic non-cancer pain in June 2011. The new pain management rules took effect for DOs, osteopathic physician assistants, nurses, podiatrists and dentists on July 1, 2011; and took effect on January 2, 2012 for family physicians and other MDs, and physician assistants.
The new rules apply to physicians caring for adult patients experiencing “chronic non-cancer pain” and do not apply to palliative, hospice or end-of-life care, or to acute pain caused by injury or surgical procedure. The rules identify new, detailed requirements for patient evaluation, treatment plans, informed consent and written agreements for treatment. There is a mandatory consultation requirement for any patient that meets or exceeds a per day dosage amount of 120 milligrams morphine equivalent dose (MED). There are some exemptions from the consultation requirement permitted in the rules. Please make time to read the rules and become familiar with the requirements.
Link to MQAC Rules for MD's
Link to MQAC Rules for DO's
MQAC letter to physicians on new rules
DOH Pain Management Section
MQAC Pain Management Resources
The Agency Medical Directors Group has developed free CME including a video on the rules. The AMDG website also has information on opioid dosing guidelines and a conversion calculator as well as other resources that may prove helpful.
University of Washington (UW) Pain Medicine Provider Toolkit:
The University of Washington held a conference on the pain rules, "Legislating Pain Care," on June 18, 2011. The 7-hour conference on the rules include a series of lectures and case-based discussions (including Q & A) of appropriate patient evaluation and treatment of the patient in pain. The conference was recorded and can be accessed on UWTV
The WAFP was engaged in the MQAC rulemaking throughout the process and submitted comments on February 23, 2011, which were largely ignored by the commission. WAFP leaders met with commission members in the spring to discuss its concerns with the rules. MQAC leaders assured WAFP that its concerns would be addressed by the final rules. The WAFP concerns were not addressed.
The WAFP worked to improve the rules throughout the rulemaking process and then formally, along with the WSMA, requested that the MQAC amend the rules after they were published. WAFP/WSMA letter June 1, WAFP/WSMA letter June 7, WAFP/WSMA letter June 20
On July 22, the MQAC addressed the WAFP appeal and denied the request to reopen the rulemaking process. The MQAC will permit the rules to take effect on January 2, 2012 and then monitor the rules effect on patients and physician practices.
The WAFP is considering its options and will continue to monitor how the implementation of the MQAC pain management rules impact members and patients. We are very interested in hearing how the rules will impact your practice whether you are an osteopathic physician or an allopathic physician;please email firstname.lastname@example.org or phone 425-747-3100.
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