Monday, January 22, 2018

Virginia Adopts Emergency Opioid and Buprenorphine Prescribing Rules


Effective immediately, Virginia’s Board of Medicine has adopted emergency regulations governing the prescribing of opioids and buprenorphine. These regulations apply to doctors of medicine, osteopathic medicine, and podiatry, and to physician assistants who are treating acute and chronic pain that is not associated with cancer, hospice, palliative care, inpatient hospitals, inpatient nursing homes, or clinical trials.

Regulations for the management of acute pain include requirements for the evaluation of the patient, limitations on quantity and dosage, and medical recordkeeping. Further, the rule states that non-pharmacologic and non-opioid treatment for pain shall be given consideration prior to treatment with opioids.

Regulations for management of chronic pain include requirements for evaluation and treatment, including a treatment plan, informed consent, urine drug testing, checking the prescription monitoring program, consultation with other providers when prescribing above 120 MME/day, co-prescribing naloxone when prescribing above 120 MME/day, and medical recordkeeping.

Regulations for prescribing of buprenorphine for addiction treatment include requirements for patient assessment and treatment planning, checking the prescription monitoring program, limitations on prescribing the buprenorphine mono-product (without naloxone), pill counts, urine drug testing, dosages, consultation, and medical recordkeeping.

If you are a prescriber in Virginia, we strongly advise that you read the emergency regulations governing the prescribing of opioids and buprenorphine (see pages 23-27) in their entirety so that you may ensure that you and your staff fully understand the new requirements.

If you have specific questions about these emergency regulations, the officially designated agency contact is the Board of Medicine’s Executive Director, William L. Harp, M.D., who can be reached by telephone at (804) 367-4558 or by email at

If you are a member of AIPM and have general questions about this or any other pain-related policy, please feel free to contact me at

2 responses

  1. Jane Abernathy
    May 4, 2017 at 2:21 pm

    “co-prescribing naloxone when prescribing above 120 MME/day, and medical recordkeeping.”
    This is not doable. If a person is taking an opioid and you give them naloxone, they will go immediately into withdrawal and possibly seizures. This is inhumane.
    It just proves that the people who are making up these rules out of thin air have no idea what they are doing.
    Are you TRYING to kill us?

    • Katie Duensing
      May 5, 2017 at 9:38 am

      You have identified a very important point that needs clarification–

      These regulations do not require that a patient actually take the naloxone while taking their opioid medication–you are correct in pointing out that that would be extremely dangerous and inappropriate. Requiring a co-prescription of naloxone means that a prescriber must ensure that any patient being prescribed an opioid (in this case, above 120 MME/day) is also written a prescription for naloxone. This is not so that the patient will take the naloxone along with their opioid medication; rather, it is to ensure that the patient is able to have the naloxone on hand in the event of an unexpected overdose.

      The reasoning behind this is that studies have shown that daily opioid doses over 100 MME are associated with a higher risk of overdose and death. Keep in mind, that even if one is taking their opioid medication exactly as prescribed, an overdose could still be triggered if, for example, that person unknowingly develops a respiratory infection.

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About Katie Duensing, JD, Asst. Director, Legislative & Regulatory Affairs