Tag Archives: PC clarification

PC clarification

Andrea,
Here is the tweaked and improved version, and the conversation thread.

“Pharmaceutical products containing buprenorphine shall not be considered, and are specifically exempted from consideration, in the determination of whether a facility is designated as a pain clinic requiring registration as such with the state, if and only if the buprenorphine product is used in accordance with its FDA indication for the treatment of opioid dependency and in the context of an opioid dependence treatment program.  Use of buprenorphine products solely to treat pain, whether transdermal (e.g. Butrans) or sublingual (e.g. Suboxone), shall constitute the use of an opiate for purposes of pain management and shall count toward determination of a facility being designated as a pain clinic requiring registration as such with the state.”

John B. Standridge, M.D., FAAFP, FASAM

President, Tennessee Society of Addiction Medicine
Personal Medicine LLC
2115 Stein Dr  Ste 304
Chattanooga TN  37421-7200

Gary,

Yes, thank you for your courteous and productive response to the issue of clarifying the definition of who must register as a pain clinic. Allow me to suggest wording that the Health Commissioner might issue as a policy statement until it can be added to Senate Bill No 676 in January.
“Pharmaceutical products containing buprenorphine shall not be considered, and are specifically exempted from consideration, in the determination of whether a facility is designated as a pain clinic requiring registration as such with the state, if and only if the buprenorphine product is used in accordance with its FDA indication for the treatment of opioid dependency.”
If you need additional clarification, consider, “Off-label use of buprenorphine products used to treat pain in the absence of an opioid dependence treatment program shall constitute the use of an opiate for purposes of pain management and shall count toward determination of a facility being designated as a pain clinic requiring registration as such with the state.”
Again thank you for your thoughtful deliberation in an effort to avoid the unintended consequences of hindering the efforts of addition specialists in Tennessee. I think these two sentences should satisfy everyone’s concerns.
Thanks again for your productive response.
John