Subject of Possible Rule Making: Opioid prescribing—General provisions for allopathic physicians (MD) and physician assistants (PA). The Washington medical commission (commission) is considering amending the following opioid prescribing rules to modernize the language, add clarity, and bring the rules more in line with current practice: MD, WAC 246-919-850 through 246-919-985; and PA, WAC 246-918-800 through 246-918-935.

Reasons Why Rules on this Subject may be Needed and What They Might Accomplish: The commission received a petition in July 2024 that requested amendments to the opioid prescribing rules. The petition requested changes to WAC 246-919-850 through 246-919-990 and 246-918-800 through 246-918-835 to ensure that opioid prescribing rules do not impose unnecessary restrictions on stable chronic pain patients or those with rare diseases. The petitioner's requested revisions seek to clarify that stable and compliant chronic pain patients should not have their opioid medications reduced, tapered, or discontinued, as doing so may be harmful and fall below the standard of care. Additionally, the petitioner requested the elimination of predetermined morphine milligram equivalent guidelines in prescribing decisions, emphasizing that neither Washington state nor federal law mandates specific dose, strength, quantity, or duration limitations. Lastly, the petitioner requested an exemption for patients with rare diseases, as defined by the National Organization for Rare Disorders or the National Institutes of Health, ensuring they are not subject to restrictive opioid prescribing policies.

The commission reviewed the petition in July 2024 and voted to initiate rule making on this subject. Based on the petition, the commission is considering updating opioid prescribing rules for MDs and PAs to modernize language, add clarity, and better align with current medical practices.

Clear and well-structured rules help ensure that medical professionals understand their responsibilities and that patients receive safe, high-quality care. Over time, medical practices, technology, and patient care standards evolve, making it important to update regulations so they remain relevant and effective.

The intent of this rule making is to further establish clearer expectations for MDs and PAs regarding professional conduct, patient care, and regulatory compliance. By modernizing them, the commission can remove outdated language, clarify ambiguous requirements, and ensure they align with best practices in health care. This can also help streamline processes for medical professionals while maintaining strong oversight to protect patients. Additionally, aligning state rules with federal policies and national standards reduces confusion, improves consistency in medical regulation, and ensures that Washington health care providers are held to the same high standards as those in other states.

Updating these rules is intended to support patient safety, enhance professional accountability, and foster a health care system that reflects current medical knowledge and ethical considerations. It also helps prevent regulatory gaps that could lead to inconsistencies in care, ensuring that both health care providers and patients benefit from clear, well-defined expectations.

Interested parties can participate in the decision to adopt the new rule and formulation of the proposed rule before publication by contacting Amelia Boyd, Program Manager, P.O. Box 47866, Olympia, WA 98504-7866, phone 360-918-6336, TTY 711, email amelia.boyd@wmc.wa.gov, website https://wmc.wa.gov.