PAINKILLER LAW BLOG: Fear, Dread and a Warm Welcome – Here Comes Zohydro

How can a drug about to hit the market be feared, dreaded, welcomed and deemed medically necessary, all at the same time? It’s complicated, so if the new “super painkiller” Zohydro had human feelings, it would definitely be in the midst of an identity crisis. In this post I’ll talk about the Zohydro kerfuffle, and why it’s more proof that in most cases, “blame” for prescription drug addiction lies with the drugs themselves, not the doctors who’ve prescribed them.

First, what is a “kerfuffle?” It’s a brouhaha. Commotion. Turmoil. Uproar. Hubbub. I learned the word from The Onion. Second, why the kerfuffle over Zohydro? Because Zohydro, a new opioid painkiller approved by the FDA and slated for market entry soon, is ten times more powerful than Oxycontin or Vicodin, and it contains no abuse-deterrent formulations. This has policymakers and even some medical societies worried that the drug will – well, how to say it gently? – kill or injure a lot of people who will be using it. Though the drug is slated to be used as a painkiller of last resort for patients who cannot get relief from other medication, its potency and its emergence on the market in an era of high rates of addiction, overdose and death from opioid painkillers are indeed cause for concern.

Last year, an FDA panel opposed approving Zohydro; the FDA itself then went against its panel’s recommendation and green-lighted the drug. The drug’s approval has been the subject of controversy ever since, and this week U.S. Senator Charles Schumer (D – N.Y.) asked the Dept. of Health and Human Services to reverse the FDA’s decision. Good luck, Chuck; the Congressmen from Big Pharma likely have a different view.

The controversy swirling around Zohydro got me thinking about doctors who prescribe opioid painkillers, and of law enforcement efforts to “do something” about the prescription drug crisis. To me, at the core of the Zohydro debate is the widespread belief that the drug’s mere availability will further aggravate an already serious public health problem. Is the worry that doctors, however cautiously, may be prescribing it? Or is it that Zohydro will exist at all? My answer is that people are worried about Zohydro’s very existence. To date, media reports haven’t much discussed the role doctors may play in prescribing the drug; reports instead have focused on how Zohydro’s very presence in the market will automatically impact the prescription drug crisis.

Isn’t this a powerful indicator that the problem could be the drug itself? After all, doctors would be directed to follow protocols, guidelines, safety measures and other steps in assessing patients’ eligibility and need for the drug, its effectiveness, and any problems that might arise in treatment. If that part of the discussion is so irrelevant in the minds of Zohydro critics, then doesn’t it stand to reason that doctors ordinarily aren’t the problem? Yes, it does, in case you’re on the fence about that one. I have long believed that in all but the extraordinary, outlier case, prescribers aren’t the problem so much as the drugs they’re prescribing are. The Zohydro kerfuffle is but one more piece of evidence that aggressively targeting legitimate doctors is the wrong way to go, especially when the same law enforcement agents who self-righteously kick in office doors and hold slanderous press conferences refuse to look past their own noses for the real roots of the problem.

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PAINKILLER LAW BLOG: The FDA’s Original Blessing Isn’t a Pain Doc’s Original Sin

Doctors who prescribe opioid painkillers to chronic pain patients are, as we know, the subject of intense regulatory and law enforcement scrutiny today. Many of my doctor-clients are under investigation or being charged for supposed crimes arising out of their prescription writing. While every case is different, to me there is a universally applicable defense that should be raised on doctors’ behalf in court against a criminal charge.

That defense relates to lack of criminal intent, since opioids’ addictive power was not known or acknowledged until years after the drugs’ approval for mass use. Today, a criminal charge is at its essence a misguided and ill-considered way of blaming doctors for not having seen the future, for not having foreseen what would happen, even though government regulators and even the drug manufacturing companies didn’t see the abuse crisis coming, either.

The FDA originally blessed the prescribing of powerful and potentially addictive medication for chronic pain. We now know that the scientific evidence offered by Big Pharma about the safety of the medications for chronic pain was incomplete at best, wrong at worst. There are attempts being made today by counsel in various parts of the country to uncover any possible funny business or overly cozy relationships which may have existed between government regulators and private business (Pharma advocates) during the drugs’ approval process years ago. Is this the Erin Brockovich-like scandal waiting to break? Could be.

Whether or not a scandal exists or will be revealed, though, it still must be noted that doctors were the ones who were told by the FDA and the pharmaceutical companies that drugs like Oxycontin and other opioid-based painkillers were safe and effective for chronic pain. The addiction risk was significantly downplayed or underestimated by regulators and manufacturers. The drug companies unleashed a marketing and advertising juggernaut to persuade patients that the miracle pain drugs had at last arrived. That was then; this is now. And now that we know the drugs so frequently lead to addiction, we can change the advice and practice guidelines given to doctors, but we cannot hold them legally accountable for not knowing what the rest of us didn’t know, either – or what some people in the game may not have revealed – years ago.

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PAINKILLER LAW: Yet More Evidence That the Drug is the Problem

Yet more evidence has emerged that long-acting extended release opioids for chronic pain should never have been marketed as safe, effective and generally non-addictive. To avoid criminal liability, malpractice suits or Medical Board actions, medical providers who prescribe opioids for their patients have to change with the changing science. To ignore the changing science – major developments emerge pretty much weekly now – is to risk imperiling patients with outdated information, and to consequently put your liberty and livelihood in great danger. If you’re out of the loop on information that could save your patients’ lives, when you had the chance to come up to speed and you ignored or passed on the opportunity, imagine how easy you’ll have made it for the DEA, or your licensing board, to nab you. I’ve said this before, and I say it again because there’s more important news to share about this.

Here’s what we know so far:

-The Centers for Disease Control believe that too many doctors are prescribing too many opioids to too many patients;

-The AMA concurs, to the great disappointment of pharmaceutical manufacturers;

-The FDA has ordered new labeling for long-acting extended release opioids to better warn providers and patients of the dangers of addiction and abuse;

-Johns Hopkins Medical School has concluded that even though opioid prescriptions have skyrocketed, fewer patients are actually experiencing pain relief.

And now, Exhibit 5: The National Pain Report on September 23, 2013 says that “a drug increasingly being used to treat opioid addiction may be fueling a new epidemic of diversion, overdose, addiction and death in the U.S.” The article talks about buprenorphine, known by its brand name, Suboxone, and how it is not only being prescribed by some doctors who don’t know what they’re doing, but that it’s also being sold on the street by heroin dealers because it reportedly softens any withdrawal symptoms between doses or highs.

And still, pharmaceutical manufacturers would have patients and physicians believe that the problem is not with the drugs themselves. Instead we see the same old acronyms like “the 5 R’s, or “S.A.F.E. N.A.R.C.” or other catchy phrases that do what they can, but which ultimately miss the point, in favor of the idea that the patient and the doctor can be in complete control in any prescribing or treatment scenario. Patients and doctors can’t be, because the drugs are too powerful. The nation’s prescription drug abuse epidemic and the weekly scientific bombshells prove this.

So what to do, if you are a medical provider? First, if you’re not in pain management, don’t get into it unless you are Board certified and fully trained by a body other than a self-interested, profit-motivated provider advocacy group. Such groups will sell you on taking the easy way, and that will ultimately disserve your patients and you. Second, if you already have a pain management practice, read and incorporate all the new scientific data into your practice without delay, so that you can show any law enforcement investigators that when the science changed, you changed with it. And third, even though the current assessment, treatment, monitoring and other compliance/patient safety tools are valid and should continue to be utilized, know that they’re increasingly being revealed as inadequate. They are no match for the immense power of the drugs they seek to keep in check. So relying on them alone will, as the science continues to advance, leave you high and dry when it comes to defending yourself against criminal, malpractice, or Medical Board scrutiny.

info@painkillerlaw.com MEISTER LAW OFFICES 213.293.3737

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PAINKILLER LAW: Opioid Prescribers! The CDC Just Warned You, and Gave You a Defense.

Today’s Los Angeles Times reports that Dr. Tom Frieden, head of the national Centers for Disease Control, condemns widespread prescribing of opioid/narcotic painkillers as dangerous and inappropriate. But if you read his remarks, he’s not only warning opioid prescribers, he’s giving them a ready defense against an accusation. Any medical provider who writes for opioids needs to pay attention or risk DEA, law enforcement and Medical Board wrath – criminal prosecution, conviction and imprisonment for drug dealing or homicide, and loss of license. MD’s, DO’s, PA’s, NP’s – now or never, take heed!

Frieden said two things which jumped out at me. First, here’s his bottom-line take on the U.S. epidemic of prescription drug abuse:

“These are dangerous medications, and they should be reserved for situations like severe cancer pain. In many other situations, the risks far outweigh the benefits. Prescribing an opiate may be condemning a patient to lifelong addiction and life-threatening complications.”

That’s the warning. The scientific evidence and widespread belief developing across the country are that these drugs should never have been recommended or made available to treat chronic pain. In the face of mounting evidence of the medical inadvisability of treating chronic pain (however that’s defined for each patient) with highly addictive, powerful narcotics, any provider who continues to prescribe high rates of these medications takes an ever-increasing chance of being accused of “operating outside the accepted standard of practice” or “prescribing without a legitimate medical purpose.” And as I’ve explained in this blog’s posts, if in the view of the DEA or a prosecutor you are “prescribing without a legitimate medical purpose” but you’re still prescribing like crazy, then you’re just dealing drugs. So the lesson from the CDC is to know what you’re doing, in light of the evolving prevailing science, or don’t do it. The CDC’s warning will have a big ripple effect, I’m sure, and that wouldn’t be such a bad thing, as long as ethical medical providers aren’t unfairly targeted for investigation and prosecution.

But Dr. Frieden also gave medical providers a powerful defense, a compelling argument to make in the face of criminal or administrative investigation. Here’s what he said:

“When I went to medical school, the one thing they told me about pain was if you give a patient in pain an opiate painkiller, they will not become addicted. And that was completely wrong.”

That’s a great argument, a legitimate defense, for a medical provider who faces official scrutiny over their narcotic prescription-writing. Today’s providers were all trained to treat pain as “the fifth vital sign,” and to take patient complaints about pain very seriously and respond accordingly. But if what you were taught about pain medication way back when is newly shown to have been wrong, then up until now, what crime did you commit by following accepted and scientifically validated medical practice? None, to my mind. The science changes, and with it, your obligation to keep up with the news and not put patients at risk. But who can righteously accuse you of having willfully neglected patient safety in the past, just because you followed what you were taught and what was at the time the prevailing state of medical knowledge?

The response by pain management medical providers or anyone who writes scrips for chronic pain has to be: (a) know the law, know the science, know what’s changing and stay in line with it, and (b) consider scaling back a pain practice unless even from the most skeptical perspective, you’re doing everything right. This may mean reforming your business model, it may impact income, it may mean a big change in how you’re currently practicing medicine. But a new business model sure beats an indictment or the initiation of license revocation proceedings if you insist on sticking with old ways in the face of new, possible life-saving information about patient safety.

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PAINKILLER LAW: When Crime’s All You Look For, You See Too Many Criminals

If you wake up every morning, strap on a badge and gun and go fight the War on Drugs, you come to view the world in a certain way. If your goal for each workday is to go in peace and not come back in pieces, your perspective on society, people, crime and your role in combating evil are invariably shaped by your experience. That’s why it’s a mistake for the DEA to bring its ordinary approach against drug crime to the issue of prescription drug abuse. But that is just what the agency is doing. It is basically treating like a criminal any healthcare professional who shows up on its radar.

At the recent joint conference sponsored by the California Medical Board and Board of Pharmacy, I heard the DEA speak about rampant drug diversion, pharmacists’ widespread complicity in prescription drug abuse, doctors wantonly prescribing outside the standard of care, drug dealers in white coats, and the DEA’s determination to crack down. The problem is, no one can quantify the degree of “complicity” by the nation’s pharmacists, or durably judge when a provider is prescribing outside the standard of care. The DEA says it’s happening, and its agents are the ones with the guns, and so, well, it must be happening.

The sense of things that I had coming into the conference was unfortunately not at all changed by what I heard there. The DEA’s talk was dominated by war stories of pharmaceutical distributors selling Oxy out the back door, of pharmacists ordering more than they need and keeping lousy records of where it all went, of doctors making megabucks writing scrips for no reason, and patients visiting websites devoted to the celebration of hallucinogens. Seriously, that’s what the speaker talked about. That’s clearly not the entire scope of the issue, and those characterizations don’t fairly define all medical providers or pharmacists or patients. None the less, the DEA is bringing its habitual mindset to a new class of cases and investigations – and a new “target” population – and that’s the wrong approach.

Clearly, the DEA is in reaction mode, just as Medical Boards nationwide are, and it’s being blamed for missing the early signs of what became a prescription drug abuse crisis. In reaction to the blame, the DEA is redirecting the pressure onto doctors, pharmacists and others who the DEA thinks are responsible for whatever the agency is supposed to be trying to stop. And what exactly is to be stopped? Who should decide whether a patient needs the drugs he or she is given: The prescriber, or the federal agent? If a doctor prescribes a lot of pills to a lot of patients, does it mean he or she is operating a pill mill? If a pharmacist fills prescriptions, is the pharmacist automatically part of the problem? And if the meaning of “outside the standard of care” can’t even be succinctly articulated in the law, how are law enforcement agents to know where the line is, BEFORE they decide a practitioner or pharmacist is dirty?

These are the questions all of us must vigilantly continue asking, persistently and if need be peskily, in this latest iteration of the War on Drugs. There is no easy answer, no matter what the DEA might think.

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VOICE OF REASON VS. CALL TO ARMS: THE CALIF. MEDICAL/PHARMACY BOARDS’ CONFERENCE ON PRESCRIPTION DRUG ABUSE

Recently I attended a conference sponsored by the California Medical Board and Board of Pharmacy. I think I was the only criminal defense lawyer in the room. The two-day event was entitled, “Joint Forum to Promote Appropriate Prescribing and Dispensing,” and was supposed to help healthcare providers and pharmacists know the law of controlled substance prescriptions, so they could follow the law and care for patients better. But that didn’t happen. Instead, during a Q and A with high-ranking Board officials on a panel, one attendee put it perfectly: The Boards are in “punitive” mode, “waiting to pounce” on prescribers and providers. That really was the unmistakable and highly regrettable message of the conference. In this post and several to follow, I’ll explain.

The voice of reason was heard briefly in the conference’s opening session. It belonged to the White House Office of National Drug Control Policy, better known as the Drug Czar. The speaker from the Office listed ways to screen for potential abuse, advice for effective patient monitoring, relevant CME, and other tools doctors could use in caring for patients while helping to curb abuse.

The speaker’s final suggestion was the most interesting, to me: He advised providers to regularly prescribe naloxone, the “anti-overdose” drug that has helped save the lives of accidental opiate overdose patients around the country. Great idea! But there’s also a downside, which I pointed out to the speaker: In today’s aggressive enforcement environment, the DEA and Medical Board might view writing for naloxone as prima facie evidence of excessive opioid prescribing. After all, if a doctor felt a patient was at risk of overdosing, why did the doctor write the opioid scrip at all? And why did a pharmacist fill it? What I fear, and what the official acknowledged could be a real issue, is that a provider’s or pharmacist’s act of patient protection could be used against them in a federal or state criminal investigation. That, to put it technically, would be totally uncool. And unfair. And inadvisable as policy and practice.

When the Drug Czar’s office had concluded its remarks, the DEA assumed the microphone. With that transition, the voice of reason gave way to a one-sided call to arms against the very professions represented by the conference’s attendees. More on this in the next post.

info@painkillerlaw.com MEISTER LAW OFFICES 213.293.3737

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PAINKILLER LAW: FDA and I Call For Abuse-Deterrent Drug Agents

The FDA today called upon pharmaceutical researchers to develop formulations of opioids that would bring pain relief while reducing the possibility of addiction. The FDA refers to “abuse-deterrent” drug agents in the chemical sense. I join the FDA in calling for abuse-deterrent drug agents, only the kind of agents I’m talking about wear badges, drive fast in unmarked cars, and show up heavily armed.

The FDA should be commended for its balanced approach, in which it seeks both the development of less addictive drugs, and the need to get real pain relief to patients. What concerns me is that in investigating healthcare providers who write Schedule II-V prescriptions, typically law enforcement agents including the DEA and state Medical Boards emphasize “case clearing” over balance, hard and fast over nuance, and black and white over shades of gray. Whereas the FDA’s January 9 statement expresses its extreme concern “about the inappropriate use of prescription opioids,” the FDA doesn’t define “inappropriate.” Left to the determination of the DEA, which has been accused of being late to the party on addressing prescription drug abuse, and left to state Medical Boards, which have been accused of bailing on the party altogether, the definition of “inappropriate” could be bent, twisted, contorted, and most dangerously, broadened to encompass practices and procedures which a better informed or more detached observer would never contemplate. But when the warrant is signed or the cuffs slapped on, it’s too late for a healthcare provider to say, “Let’s slow down, back up, look at this from the beginning, and then discuss.”

That is why every healthcare provider, risk manager, medical group manager and professional needs to know the black-letter federal and state law of Schedule II-V prescriptions, and the nuances and subtleties of how the law is interpreted, what influences and impacts the agencies charged with “cracking down” on supposedly corrupt providers, and what you can do now, today, to ensure patient safety and the protection of your practice. This is why PAINKILLER LAW exists. Don’t let yourself fall victim to the subjective and loosey-goosey way law enforcement agencies and Medical Boards are defining “inappropriate,” “overprescribing,” “gross negligence,” or other concepts whose interpretation could be fraught with peril for even the most honest and ethical MD, osteopath, or physician’s assistant. Let us help you verify, achieve and maintain full compliance with the laws that well-intentioned but hopelessly biased drug agents are ever more aggressively attempting to enforce.

PAINKILLER LAW – It’s good preventative medicine.

info@painkillerlaw.com 213.293.3737 MEISTER LAW OFFICES

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PAINKILLER LAW: Physician (and Physician’s Assistant), Heal Thyself

Recent Texas Medical Board actions bear mention just before the holidays, and are of particular interest to physicians’ assistants and their supervising MD’s or DO’s.  The TMB just handed down license revocation/suspension penalties against three PA’s and their supervisors, in cases of alleged “pill mills.”  Either the PA was accused of inappropriately prescribing, or the supervisor accused of inadequate supervision, or both.

Head into 2013 with the following tips in mind, if you work in a clinic or medical group that could, by virtue of its very existence, become a target of official inquiry:

For PA’s:

1)   Make sure your Delegated Services Agreement is up to snuff and up to date. Check with your state’s licensing authority as well as professional advocacy organizations or statewide trade groups to make sure the language of your DSA complies with the law of your state, and with federal law.

2)  DEA Number:  If you are authorized to write scrips, are you DEA-current?  Expiration dates can sneak up on you.  Whether you or the office staff keeps track of these matters, give it a year-end check just to be sure.

3)  Is your supervisor actually doing his or her job of reviewing your files at least as often as required by your state’s law?  In California, a supervising MD or DO is supposed to review all PA files every 7 days, especially when Schedule II – V prescriptions have been written.  If you don’t think your supervisor is in compliance, get on him or her to get with the program.  If they balk, weigh your options and always err on the side of staying in compliance with the law, whether it’s at that clinic/office, or another one.

For Supervising MD’s/DO’s:

1.   Don’t fall short in checking charts regularly and thoroughly.  If you are not in compliance with this basic requirement of PA supervision, achieve and maintain compliance immediately in order to (a) ensure patient safety, (b) be a helpful and responsible employer who invests in your employees, and (c) take an easy “find” away from investigators should you come under official scrutiny.

2.   Chart it, chart it, chart it.  Make sure charts are up to date with any advice/feedback/correction given to a PA by you upon chart review.  Again, patient safety will be enhanced, and regulators and investigators will see your diligent efforts to comply and properly supervise.

3.   Make sure your office’s and staff’s efforts and procedures for utilizing your state’s Prescription Drug Monitoring Program are current, understood and practiced every day.  You can’t catch every doctor shopper, and to be sure, PDMPs’ technology leave a lot to be desired, but you still need to do all you can.

4.    Create and nurture an environment of collaboration and communication with PA’s in your office, on all subjects of patient care but especially about Schedule II through V prescriptions.  A culture of candor and compliance is readily apparent to an inspector, investigator, regulator or law enforcement agent.  There are lots of ways to this, but it all starts with office culture, and that starts with you.

And with that, friends, Merry Christmas, happy holidays, happy new year to everyone, and PAINKILLER LAW will be back after January 1.

 

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PAINKILLER LAW: HEALER BEWARE — MEDICAL BOARDS’ 2013 WISH LIST

2012 has seen the nation’s Medical Boards come under relentless scrutiny for allegedly dropping the ball on regulating healthcare providers who write prescriptions for opioids and other potentially addictive drugs.  2013 will see the Boards react in full.  We all know that when a Medical Board gets hit with criticism by Legislator A or Media Outlet B, the Board reflexively lashes out at Doctor C.   For you as a healthcare provider to know how to protect yourself from biased and careless official investigation, you need to know what your regulatory overseer is thinking, and how you could be at risk no matter how ethically and safely you do your job.  Here’s what is on Medical Boards’ “wish lists” nationwide for 2013:

1)  Criminal investigations, in addition to administrative inquiries, for any patient overdose death.  An excellent recent LA Times article roundly criticized the California Medical Board for what the paper viewed as lax oversight of doctors who lose patients to prescription drug overdoses.  The Medical Board’s first reaction will be to raise the stakes by initiating a more clearly criminal inquiry against a healthcare provider when any patient fatality is even partly attributable to prescription drugs.  The Board is out to vindicate itself.  Providers who underestimate the Board’s desire for vindication are operating at their own peril.

2)  Tightening up communication between coroners’ offices and Medical Boards.  It’s good policy for coroners to immediately notify Medical Boards whenever a death is attributed even partly to prescription drugs.  The danger, though, is what Medical Boards will do with the information as new reporting requirements become operative.  In the hands of Medical Boards desperate to rebuild their tarnished reputations, this could easily become a 1-800-WHO TO TARGET NEXT hotline.  That’s not what these new reporting laws intend, but I’m confident it will be their effect.

 

3)  Finding criminal and administrative liability when a provider gives prescription drugs to an addict.   Wait a minute:  Isn’t it permissible under federal and state law to prescribe controlled substances to an addicted person?  Yes.  In fact, doesn’t the law of many states expressly prohibit discipline against healthcare providers who do this?  Yes again.  But in the recent LA Times article cited above, a Medical Board investigator said that a patient’s death was “the inevitable result” of giving narcotics to an addict.  That sounds like a new theory of liability to me.  Take it from a defense lawyer:  An incorrect interpretation of the law does not always stop police from acting.  Healer beware.

I will have more to say on these particular topics, as well as what I think 2013 will bring for the broader issue of prescription drug abuse.  For now, take heed and make sure you’re in compliance with all the federal and state laws governing prescription painkillers and other drugs.  Remember that PAINKILLER LAW is here to help you.

info@painkillerlaw.com              213.293.3737               Meister Law Offices

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PAINKILLER LAW: SEIZING OPPORTUNITY, CALIFORNIA LAWMAKER BOLDLY JUMPS ON BANDWAGON

This past Sunday, the LA Times ran a searing and exhaustively researched article on prescription drug abuse, called “Dying for Relief.” This past Monday, as is the fashion among legislators nationwide, a California lawmaker loudly reacted to the article and grabbed a headline of his own.

Ordinarily, a legislator’s jumping on the bandwagon after a big article runs in the paper isn’t news. But here it is, because in response to the national public health problem of prescription drug abuse, California State Senator Curren Price, Jr. is introducing legislation that targets healthcare providers for law enforcement action. A law enforcement approach to a public health problem typically scores political points and funds new multiagency task forces, while doing nothing to actually address the problem. And innocent people – here, legitimate healthcare providers writing legal prescriptions for approved drugs – get steamrolled in the name of public safety.

Price’s idea isn’t so outrageous: He wants coroner’s offices in California to automatically report patient deaths to the California Medical Board whenever a coroner concludes that prescription drugs caused or contributed to someone’s death.

But the devil will be in the details, because the Medical Board is under tremendous pressure to “crack down” or “do something” about Rx abuse and suspected corrupt healthcare providers. All this while California law doesn’t even define “overprescribing,” for example.

PAINKILLER LAW will be watching very closely for the language and implications of the Price bill. I’m concerned that whereas a coroner’s findings may be circumspect and sober, the Medical Board will eagerly grab the autopsy report and form a posse to go after the “bad guy.” Senator Price needs to be alert to the pressure the Board will put on him and his committee to give the Board too much latitude in investigating, accusing or proceeding against healthcare providers who’ve written prescriptions for potentially addictive drugs. The offense itself is not clearly defined, yet law enforcement will want broad discretion to target it. That’s putting the cart before the horse.

Contact PAINKILLER LAW: CRIMINAL LAW COMPLIANCE FOR HEALTHCARE PROVIDERS, for a free consultation. We want to help you verify, achieve and maintain compliance with the criminal laws of prescribing for Schedule II through V drugs.

213.293.3737 info@painkillerlaw.com Meister Law Offices

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