Some portions of the rule are inconsistent with Chapter 488 and the anticipated amendments to Chapter 488. These should be amended to conform to the law.

By adopting the principle of Universal Precautions and proposing to delete the current language in Chapter 21 which states that the Boards will not take disciplinary action against a prescriber for deviating from the rule when contemporaneous medical records document reasonable cause for deviation, the proposed rule removes the critical element of judgment from medical practice insofar as the prescribing of opioid medical is concerned.  

The obligation for clinicians to offer or arrange evidence-based treatment for patients with opioid use disorder is unrealistic in some parts of the state where services are sparse or non-existent.

In many portions of the proposed rule references are made to controlled substances when the reference should be to the narrower term opioids.

The requirement of Universal Precautions removes the critical element of medical judgment and is overly broad.

The obligation regarding managing withdrawal or referring to an addiction specialist is unrealistic given the short supply of such specialists in the state.

There should be reasonable exceptions to the universal requirements for treatment agreements, urine drug screens and random pill counts.

Continuing Medical Education requirements should be consistent among the boards.