New Opioid Prescribing Policies for Medicare and Medicaid

Kelsey Creehan Featured News

Federal Updates

On Oct. 24, federal legislation to address the opioid crisis – the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act (H.R. 6) – was signed into law. The new law includes grant funding to support improvement of state Prescription Drug Monitoring Programs (PDMPs) and to incentivize continuing education expansions for prescribers. The bill also provides additional support for addiction recovery services and medication disposal programs. Further, this new law requires e-prescribing for all Schedule II opioid prescriptions issued to Medicare patients by January 2021. At this time, it is not clear how this law will impact dentists, who do not typically participate directly with the Medicare program. The ADA is further researching this issue, which will likely be clarified through upcoming rulemaking processes. The CDA will provide updates as information becomes available.

State Updates

In addition, Colorado’s Medicaid program recently enacted new opioid prescribing limitations for dentists. Effective Nov. 15, 2018, dentists may prescribe only four days of short-acting opioids at a time, with a maximum of 24 pills (six pills per day) containing a 200 total daily morphine milligram equivalent (MME). Dentists may issue up to three of these four-day prescriptions.

Prior authorization is required for cases that exceed this allowance. Dentists performing complex dental procedures may be approved for higher, medically appropriate limits after consultation with a pharmacist or pain management physician. After prior authorization, prescribing limits will typically be extended for patients undergoing:

  • traumatic orofacial tissue injury,
  • major mandibular/maxillary surgery,
  • severe cellulitis of the facial planes, and
  • surgery for severely impacted teeth with facial space infection requiring surgical management.

Additional procedures will be considered on a case-by-case basis if additional pain management is justified by the procedure. Long-acting opioids and short-acting fentanyl agents also require prior authorization.

In cases where a complex procedure will require pain management that exceeds the traditional policy, dentists are encouraged to apply for a prior authorization up front, rather than when limits have been reached to streamline the process. Prior authorizations may also be obtained after the initial prescriptions have been exhausted in cases with unusual complications. Dentists needing exceptions to these new opioid prescribing policies should contact the Colorado Pharmacy Call Center at 800-424-5725.  

Additional discussions on opioid prescribing, and specifically e-Prescribing, for all Colorado patients is expected in the upcoming 2019 state legislative session.