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New investigative criteria for NCMB’s Safe Opioids Prescribing Initiative (SOPI) took effect July 1, expanding the Board’s oversight of licensees who are managing large numbers of patients on high doses of opioids. Specifically, the revised criteria will enable the Board to investigate the top two percent of prescribers authorizing 100 morphine milligram equivalents (MMEs) per patient, per day, as well as any prescriber who meets this criterion and also prescribes in combination with a benzodiazepine.

Prior to July 1, the Board investigated the top one percent of such prescribers, which resulted in 12 licensees being investigated between April 2016, when SOPI was established, and May 2017. The Board determined that prescribing was below current accepted standards of care in about 90 percent of these cases, which led NCMB to conclude that reviewing more high dose, high volume prescribers might reveal more substandard prescribing. Assuming trends remain constant, the Board expects the revised criteria to double the number of investigations opened based on this criterion.

Investigative criteria focused on prescribers who have had two or more patient deaths due to opioid overdose within a 12-month period have also been revised. Effective July 1, the Board will open investigations only when the prescriber is confirmed to have authorized more than 30 tablets of an opioid to the decedent within 60 days of the death. NCMB believes adding these additional filters will result in fewer “false positive” cases – instances where, upon examination of the licensee’s prescribing history, it is determined that the licensee did not prescribe opioids in close proximity to the patient death, or did not prescribe in sufficient quantity to cause an overdose. Between April 2016 and May 2017, the Board opened 50 cases based on the patient deaths criterion. In a majority of cases opened based on the initial “patient deaths” report, the Board found no evidence of prescribing that could reasonably be concluded to have been a cause of the death.

Revised SOPI investigative criteria:
Top two percent prescribing 100 morphine milligram equivalents (MME) per patient per day.

Top two percent prescribing 100 MMEs per patient per day in combination with any benzodiazepine and within the top one percent of all controlled substance prescribers by volume.

Prescribers with two or more patient deaths within a 12–month period due to opioid poisoning AND authorized more than 30 tablets of an opioid to the decedent AND scripts were written within 60 days of the patient’s death.