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Opioid Emergency Rule Filed Now In Effect Creates New Prescription Regulations Dentists Must Practice Under

In ​a September 19 MDA eNews Update, ​the MDA apprised members that the Missouri Dental Board had approved the promulgation of a new Opioid Rule.

The MDA provided comments to the Dental Board at its August 2018 meeting before the promulgation was approved, and individual members were able to comment on the proposed rule through written comment or at an upcoming Dental Board meeting.

​The MDA recently received the ​opioid emergency rule filing, as seen in the December 17 Missouri Register, page 3759 (page 5 of the PDF). What this means is that Missouri dentists are currently governed through this emergency rule, which became effective November 17, 2018 and will be in effect through May 15, 2019. This means you are now practicing under these new opioid prescription regulations.

The MDA advocates for efforts to combat opioid abuse statewide and nationally, and is supportive of the guidelines that have been established for healthcare providers to do their part in efforts to help fight the country’s opioid epidemic while continuing to help patients manage dental pain. However, the MDA will again be providing comments on this rule at the next Dental Board meeting, similar to those we provided in September.

Then, and now, the MDA notes that while most of what is written in the new rule is based upon ADA policy (which refers to CDC guidelines), concerns still exist because of the requirements placed on dentists through the new rule language that leave practitioners vulnerable to legal implications without the passage or enactment of a prescription drug monitoring program (PDMP).

Additionally, a state statute passed in 2018 (195.010) limited opioid prescriptions to a 7-day supply for acute events like a surgery or dental treatment. This is language in the rule that, while important to have in place, already exists in State statue.

The MDA is not aware of any correspondence or notification about this to licensees from the Dental Board. The MDA will keep members informed regarding participation in any public comment periods through Association communications. If you have questions, you may contact Shantel Smith or Vicki Wilbers