A Pennsylvania bill signed into law on Nov. 2, 2016 — Act 124 of 2016 — requires dispensers or prescribers applying for an initial license and those applying for re-licensure to complete opioids continuing education. For MDs and DOs, the requirement is effective beginning with the current 2017-2018 licensure period.
The Pennsylvania Medical Society (PAMED) has heard from members who are wondering how to complete the new opioids education requirement. Here are answers to frequently asked questions.
Q. What are the education requirements that physicians must complete?
A. These are the specific requirements for initial applicants and for those seeking re-licensure:
- Initial applicants—They must submit, no later than 12 months after obtaining an initial license or certification, documentation acceptable to the licensing board of the completion of at least two hours of education in pain management or identification of addiction and at least two hours of education in the practices of prescribing of opioids. The education may occur as part of the individual's professional degree educational program or continuing education program.
- Physicians seeking re-licensure—They must complete at least two hours of continuing education in pain management, identification of addiction, or the practices of prescribing of opioids. These two hours count as part of the 100-hours required for continuing education, not in addition to the 100-hour requirement. To clarify, these hours must be completed during the 2017-2018 licensure period as part of the re-licensure process for 2019-2020, and each licensure period thereafter.
- Prescribers who do not have their own DEA registration number—For physicians seeking re-licensure, the two-hour CME requirement does not apply to a prescriber who 1) is exempt from the Drug Enforcement Administration’s (DEA) requirements for registration under its applicable laws and regulations, as well as any state law; and 2) does not use the registration of another person or entity as permitted by law to prescribe controlled substances in any manner. The exemption applies unless a physician has a DEA registration number or prescribes under another individual or entity’s DEA registration number.
Q. Do the continuing education requirements apply just for physicians or does it also apply to other clinicians as well?
A. The requirements apply to all prescribers and dispensers of controlled substances.
Q. Does the opioids continuing education need to be Category 1 or Category 2?
A. PAMED has received confirmation from the Pennsylvania Department of State that both the State Board of Medicine and the State Board of Osteopathic Medicine will accept continuing education courses in either Category 1 or Category 2 for the purpose of compliance with the requirements of Act 124 as long as the content meets the Board-required subject matter noted above.
Q. Are there specific courses that will meet the required hours?
A. You can choose your own opioids education courses provided you meet the number of required hours and the approved content requirements.
Q. How will the Commonwealth of Pennsylvania verify my compliance with the opioid education requirement?
A. PAMED was advised by the Pennsylvania Department of Health (DOH) that the current process is that, if audited, licensees will have to produce documentation verifying the courses they've completed, and the title of the course(s) on the documentation should be clear that the content addressed Board-required subject matter.
The Pennsylvania Department of State (DOS) is currently developing a continuing education tracking system which, when completed, will allow licensees to track their own continuing education requirements. PAMED will advise members when that tracking system is available.
Q. Will PAMED's opioids CME programs help meet these opioids education requirements?
A. Yes, the below opioids education programs offered by PAMED can help you meet the requirements:
- Addressing PA's Opioid Crisis: What the Health Care Team Needs to Know—Includes sessions on opioid prescribing guidelines for non-cancer pain, naloxone, referral to addiction treatment, the Pa. Prescription Drug Monitoring Program (PDMP), and alternatives to opioid therapy. Take the CME
- The Use of Opioids to Treat Chronic Pain—Includes sessions on interdisciplinary pain, opioid therapy, patient monitoring during care, treatment failure, and managing pain in high risk patients. Take the CME
Important note on PAMED's opioids CME programs: If you already completed one or both of the courses noted above previous to Jan. 1, 2017, those courses you completed prior to Jan. 1, 2017, will NOT count toward the 2017-2018 licensing requirements. However, you may complete one of these courses again in order to meet requirements for the 2017-2018 licensing period.
Act 124 is one of four laws on opioids and the Pa. Prescription Drug Monitoring Program (PDMP) that were signed by Gov. Wolf on Nov. 2, 2016. Get details on the PDMP at www.pamedsoc.org/PDMP
To access PAMED's CME and education resources, visit www.pamedsoc.org/cme.