Joint Committee on Financial Services
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 HB2180, “An Act Relative to Patient Choice to Promote Prescription Safety.”
HB2180 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,
HB2180 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 known likelihood of prescription-seeking behavior by those afflicted with substance-use disorder, it is imperative that providers be notified of the amount of opioids provided to patients.
While full intent of the “partial fill” provisions included in the STEP law were curtailed due to potential conflict with the federal code regarding this subject, recent federal law has cured all ambiguities. Following strong advocacy by the Massachusetts Congressional delegation, the Comprehensive Addiction and Recovery Act (CARA) explicitly allows states to pass legislation to permit “partial-fill” opioid prescriptions.
HB2180 allows practitioners in Massachusetts to appropriately implement "partial fill" for schedule II opioid prescriptions in line with the provisions that were adopted in the CARA law. MHA respectfully urges the committee to issue this bill a favorable report.
Thank you for the opportunity to offer comments on this important matter. If you have any questions or concerns or require further information, please contact Michael Sroczynski, MHA’s Vice President of Government Advocacy, at (781) 262-6055 or msroczynski@mhalink.org.