The original proposal didn’t explicitly say the language would apply only to the treatment of chronic pain, so TMA suggested including a specific refer- ence to chronic pain treatment. The board took that suggestion, inserting the words “for the treatment of chron- ic pain” in the rule. But the board didn’t make any changes based on TMA’s larger con- cerns. One such concern was that the responsibility for PAT would change hands. In June, Gov. Greg Abbott signed a bill transferring responsibil- ity for PAT from the Texas Depart- ment of Public Safety to the Texas State Board of Pharmacy (TSBP). In written comments, TMA asked
the board to delay the requirement until TSBP had taken control of the prescription database and could im- plement anticipated improvements to the system. Once the transition was complete, TMA recommended a “stakeholder process should be under-
taken jointly and the TSBP invited to participate, with the goal of improv- ing the system’s utility and any related rules.”
TMB addressed that concern by writing in the Texas Register, “The board has learned that there will be little interruption to the information system’s operation, if any.” TMA asked whether the rule
should “apply to inpatient acute epi- sodes of care, where there is not the same level of concern regarding di- version. … Can this obligation be del- egated under appropriate supervision? TMA believes that these questions, among others, warrant further discus- sion and consideration by the TMB,” the association wrote.
TMA had the same concerns with another section of the rules that re- quires physicians to periodically re- view a patient’s compliance with the prescribed treatment plan and reeval- uate the patient for any potential sub-
stance abuse or diversion. The doctor would again have to consider review- ing PAT and/or obtaining a baseline toxicology screen, and if the physi- cian didn’t do so, document the reason. (See “Pain Management Course From TMA,” page 52.)
Although almost every state has a
prescription monitoring database like PAT, a minority of states, including Massachusetts and Kentucky, require doctors to check the state database be- fore prescribing dangerous controlled substances. Ms. Robinson says TMB doesn’t see the requirement to con- sider checking PAT as an incremen- tal step toward requiring physicians to check the database outright. She says the board will continue examin- ing other parts of the rule to ensure it reflects the desired standard of care. “The only thing the board is cur-
rently considering is cases of chronic pain treatment only, and they were very clear at the board meeting that they had no intention of opening this up beyond chronic pain,” Ms. Robin- son said.
Another rule change applies to pa- tient pharmacy choice. The old rule stipulated that a patient can fill pre- scriptions only at one particular phar- macy. Updates to the rule now give the patient the choice to designate the pharmacy and add an exception to the one-pharmacy rule if the designated pharmacy is out of stock of the drug the physician prescribes.
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DISCOURAGING TREATMENT?
Plano occupational and sports medi- cine physician James Cable, MD, was the only physician to submit written comment as an individual on TMB’s rule proposal. Dr. Cable’s comments echoed some of Dr. Mehta’s concerns. “It says that the intent of the board is not to impose regulatory burdens on the practice of medicine, but that is exactly what these rules do,” Dr. Cable wrote. “Many of the rules pro- posed are already implemented in my own practice. On the other hand, I fear that even a minor oversight on my
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