On Friday, September 15, 2017, the Ohio Board of Nursing released draft rule changes.  Among these proposed changes is a change to OAC 4723-9-10 regarding the 30 MED limitations for prescribing opioids.  Of particular concern is the new language found in proposed OAC §4723-9-10(J)(3)(c).  The proposed language prohibits APRNs from prescribing medications in excess of 30 MED for acute pain in most situations.  The Board of Nursing added additional language on Friday, September 15, 2017 that would allow a prescription exceeding 30 MED to be written by an APRN if the patient’s “treating physician” holds a standard care arrangement with the APRN and makes the treating physician “singularly responsible” for the APRN’s prescriptions that exceed 30 MED.

For a multitude of reasons, APRNs across Ohio find this exception unacceptable due to the unnecessary barrier it places on patient care.  As such, OAAPN believes the exception language should be modified to match the language in the rules published by the Board of Medicine which states that a physician (including physician assistants) may exceed the 30 MED limitation for treating acute pain if the physician “determines that exceeding the 30 MED average limit is necessary based on the physician’s clinical judgment and the patient’s needs,” and the physician “document[s] in the patient’s medical record the reason for exceeding the 30 MED average and the reason it is consistent with the patient’s medical condition.”  See Ohio Medical Board Rule – OAC §4731-11-13.

1) Click HERE for a link to the text of the proposed Board of Nursing rule language.

2)  Click HERE for a link to the Proposed Rules submitted by the Board of Nursing to the Common Sense Initiative (CSI)  as “Technical Changes”

3)  Click HERE for a link to the CSI’s Business Impact Analysis of Technical Changes.

To assist you in drafting up your comments to the Board of Nursing and CSI, click HERE to link to a list of common concerns that have been voiced to OAAPN regarding this proposed rule change.

To provide written comments to the Board of Nursing on the proposed 30 MED rule, you must send them by October 2 to the attention of the Ohio Board of Nursing at rules@nursing.ohio.gov AND to the Common Sense Initiative (CSI) at csipubliccomments@governor.ohio.gov. Please send your written comments no later than the close of business on Monday, October 2, 2017.

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