Overview: Regulations for Chronic and Subacute Opioid Prescriptions

Establishing safety checkpoints on prescription opioids for long-term pain will help ensure that treatment is improving patients’ quality of life without increasing the risk of opioid misuse and addiction.


Starting December 23, 2018 Ohio prescribers will need to follow new regulations when prescribing opioids for the treatment of long-term pain (lasting 12 weeks or more) and subacute pain (lasting between six and 12 weeks). The specific requirements can be found in Ohio Administrative Code 4731-11. This document will provide an overview of the new regulations so providers may incorporate them into practice without disruption to patients’ care. Ohio’s new rules will not take away medication for those in need, but instead strengthen communication between physicians and patients by establishing check points for additional assessment.


Increasing patient awareness of the risk of opioid misuse and addiction:

Physicians are required to engage in conversations with patients before starting on long-term medication treatment to ensure opioids are improving function and the patient is offered non-opioid treatments when appropriate:

  • Prior to treating or continuing to treat subacute or chronic pain with an opioid, the physician needs to first consider and document non-medication and non-opioid treatment.

  • If opioid medication is appropriate, the physician should prescribe it for the least amount of days and strength to adequately address the pain.

  • Prescribers should complete and document in the patient’s record: history and appropriate physical exam, diagnostic tests if substance misuse disorder is suspected or known, check on the patient’s history in OARRS, functional pain assessment and a treatment plan.

Check points, not limits:

According to the Centers for Disease Control and Prevention, a dose of 50 MED or more per day doubles the risk of opioid overdose death. At 90 MED or more, the risk of overdose increases ten times. The new rules establish the following check points to ensure appropriate prescribing:

  • 50 MED: prescribers are required to re-evaluate the status of the patient’s underlying condition causing pain, assess functioning, look for signs of prescription misuse, consider consultation with a specialist and obtain written informed consent from the patient.

  • 80 MED: prescribers need to look for signs of opioid prescription misuse, consult with a specialist, obtain a written pain-management agreement and offer a prescription for naloxone, the lifesaving overdose antidote.

  • 120 MED: in order for prescribers to prescribe a dosage that exceeds 120 MED (unless the patient was already on a dosage of 120 MED or more prior to December 23, 2018) there must be a recommendation from a board certified pain medicine physician or board certified hospice and palliative care physician that is based upon a face-to-face visit and examination. There does not need to be a recommendation if the prescribing physician is himself/herself board certified in pain medicine or hospice and palliative care.

The rules do not apply to patients receiving medication for terminal conditions or those within a hospital or in-patient setting where they are closely monitored. They also take into consideration patients who are already being treated for chronic pain by not establishing a maximum dose or duration of treatment. For patients that are already being treated with opioids for chronic pain, medical standards of care still apply, however, these patients will not be required to consult with a pain management specialist unless dosages increase.


Ohio Administrative Code 4731-11, Effective 12/23/18