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Welcome to my blog, a place to explore and learn about the experience of running a psychiatric practice. I post about things that I find useful to know or think about. So, enjoy, and let me know what you think.


Wednesday, April 26, 2017

Opioid Training Requirement

New York State recently decided that in order to address the problem of opioid abuse, all physicians (and non-physician prescribers) with a DEA number need to be trained in pain management, palliative care, and addiction. By July 1st of this year. I found out about it in the middle of March.

And it needs to be repeated once every 3 years.

The required course work covers the following eight topics:

(1)        NYS and federal requirements for prescribing controlled substances;
(2)        Pain management;
(3)        Appropriate prescribing;
(4)        Managing acute pain;
(5)        Palliative medicine;
(6)        Prevention, screening and signs of addiction;
(7)        Responses to abuse and addiction; and
(8)        End of life care.


I. Don't. Prescribe. Opioids. Period.

What I'm saying is, this training has no relevance for me, and is another example, aside from MOC, of taking time away from educational or clinical experiences that are useful to me, to do someone else's busywork.

I think whoever came up with this idea is trying to create the impression that something is being done about the opioid problem, without thinking it through. A more reasonable, and respectful approach would have been to say, "If this is relevant to your practice or work setting, then you must get this training. And if you don't have the training and you do prescribe opioids, you're in big trouble."

Here's an indication of just how poorly thought out this program was:

Providers will be required to attest to completion of the required course work or training.  The Department of Health has not yet released instructions for submitting an attestation, but has indicated that more information is coming soon.  

As I mentioned, this was back in March. There is now a way to attest, by going to the HCS portal, then "My content" --> "All Applications" --> "N" --> "Narcotic Education Attestation Tracker (NEAT)".  This is where the directions come from.

And for reference, this is the actual announcement.

There are two currently available courses that satisfy the training requirements (that I know of):

The New York Chapter of the American College of Physicians offers a three-hour online course on the required eight topics in conjunction with the Boston University School of Medicine.  This course is available free of charge to all providers.  You can view the course announcement by clicking here.

The Medical Society of the State of New York is also offering three 1-hour online courses covering the required eight topics.  The courses are free to MSSNY members and will be made available to non-members for a fee of $50 per module.

I couldn't figure out how to access this course without paying dues and logging in to the MSSNY site. But why would I want to pay $150 for a course I can take for free elsewhere?


The statute does provide an exemption from the course work or training requirement for DEA registered providers, but it's not clear to me under what circumstances, or how it can be done:


...The DOH may grant an exemption to the required course work or
training to an individual prescriber who clearly demonstrates to the DOH that there is no need to complete such training. Exemptions shall not be based solely upon economic hardship, technological limitations, prescribing volume, practice area, specialty, or board certification.

When I was making my attestation, there was a button you could press to ask for an exemption, but I didn't press it since I wasn't asking for one, so I don't know what happens when you do.

Now about the course. This is an aside, but one thing that pissed me off is that while the course provides CME credit for everyone who takes it, those certified by the ABIM can use it as SA credit, while those certified by the ABPN cannot. If that's not a scam on the ABPN's part, I don't know what is.

The first two modules were completely useless to my practice, although I found the content interesting. They cover how to:

Determine when opioid analgesics are indicated
Assess for opioid misuse risk
Talk to patients about opioid risks and benefits
Monitor and manage patients on long-term opioid therapy

One thing that struck me is that the course seems to be intended mainly for primary care providers, and it's hard to imagine when someone who is responsible for everything involved in primary care would have time to deal with pain management and potential for misuse.

The third module was useless as well as boring. It was basically just someone rattling off NY State laws governing the safe prescribing of opioids, and how to, "Appropriately document communication with patients about health care proxies and advance directives and describe the appropriate use of advance care planning CPT codes."

I dozed off several times. I still managed to pass.

So if the topic is relevant to your practice, or you're looking for some free CME credits, or if neither of these is the case but you have a DEA number in NY State, then by all means, take these classes.