Joint Committee on Mental Health, Substance Use & Recovery
The Massachusetts Health & Hospital Association, on behalf of our member hospitals, health systems, physician organizations and allied health care providers, appreciates the opportunity to submit comments in strong support of
SB1099, “An Act Relative to Patient Choice to Promote Prescription Safety.”
SB1099 addresses technical and operational challenges surrounding the opioid “partial fill” prescribing requirements of the Substance Use, Treatment, Education and Prevention (STEP) law (Chapter 52 of the acts of 2016). In particular,
SB1099 required a pharmacist to notify a prescriber electronically when a partial fill prescription was administered to a patient. Under the current law, the pharmacist is not required to notify the prescribing provider with information about the fulfillment of a “partial fill” prescription for a patient – thus failing to close the information loop for continuity of care purposes when the patient returns to the prescriber. Given the breadth of the opioid epidemic (and the prescription-seeking behaviors of addicts), it is imperative that providers be notified of the amount of opioids provided to patients.
Furthermore, the full intent of the “partial fill” provisions included in the STEP law were curtailed due to ambiguity in the federal code regarding this subject. Due to the advocacy of the Massachusetts Congressional delegation, the recently passed federal Comprehensive Addiction and Recovery Act (CARA) clears up this ambiguity and explicitly allows states to pass legislation to permit “partial-fill” opioid prescriptions.
SB1099 allows for the ability of practitioners in Massachusetts to appropriately implement "partial fill" for schedule II opioid prescriptions given the provisions that were adopted in the CARA law.
Thank you for the opportunity to offer comments on this important matter. If you have any questions or require further information, please contact MHA's Vice President of Government Advocacy, Michael Sroczynski, at (781) 262-6055 or
msroczynski@mhalink.org.