Good Afternoon, I am Dr. Hank Dorkin,
the president of the Massachusetts Medical Society and a physician at
Children’s Hospital. The Medical Society applauds Governor Baker, his
administration, and all of you here today, on continued leadership on this
issue, and on this important piece of legislation.
The Medical Society strongly
supports several important provisions. Providing evidence-based education to
children and young people regarding substance use disorder will be essential to
bending the opioid overdose curve and stopping this epidemic.
With regard to harm reduction, while
the existing naloxone standing order policy has served the state well, the revisions
proposed here would ensure that more patients would have access to naloxone
without a prescription from their doctor. We urge adoption.
In addition, the Medical Society
also supports the “partial fill” provisions, which would clarify that a patient
may return to a pharmacy after receiving a partially filled prescription to
receive the remainder of the prescribed medication, if the patient feels it
necessary. We hope that this revision will significantly increase the uptake of
this option to receive a partially filled medication - thereby reducing the
diversion of extraneous opioids left over when the pain is gone.
The Medical Society shares the
Governor’s goal to increase electronic prescribing of controlled substances. To
be clear, the Society believes that e-prescribing holds the promise to improve
the process for patients and physicians alike and to increase security. We are
working to further improve the underlying federal requirements and regulations.
Once DEA regulations are updated, e-prescribing can be encouraged with less
disruption to clinical workflows, and at less expense. We must, however, have
simple, working systems that do not further impede already over-burdened
physicians. Our submitted written testimony notes some of our remaining concerns
about this mandate, and includes improvement suggestions.
The Medical Society takes issue
with the provisions that would establish a Prescribing Oversight board, for the
purposes of both “prescribing enforcement,” and to dictate prescribing doses or
limits. We have long promoted the importance of assuring best prescribing
practices, and we hold that those who prescribe inappropriately should be held
accountable in order to protect patients. We believe, however, that
professional licensing boards and the DPH’s Medical Review Group are the most
appropriate path toward achieving these aims, and that additional bureaucracy
should be avoided.
The MMS also wishes to note
concerns regarding the provisions that would expand the scope of civil
commitments. We continue to worry that data do not support this, and that the present
lack of treatment infrastructure would lead to boarding involuntarily committed
patients in emergency departments.
In conclusion, the Society hopes to
continue working with the Governor, the legislature, and fellow stakeholders to
combat the opioid crisis. We hope, in recognition of crisis severity, to see additional
evidence-based interventions promoted in this legislation. One such
intervention would be the provision of Medication-Assisted Treatment provided
to eligible patients onsite in emergency departments; another would be the
establishment of a pilot supervised injection facility, under the auspices of
and following a study by the Department of Public Health. We are eager to
discuss any of the above comments, and we look forward to collaborating on
these and other efforts.
