Comments Needed on the Washington State Medical Commission’s Proposed Opioid Prescribing Rule

August 8, 2018


The purpose of this bulletin is to share WSHA and the Washington State Medical Association’s (WSMA) official comments and concerns on the Washington State Medical Commission (MQAC) proposed rule on opioid prescribing. We also strongly encourage hospitals and health systems or your medical group to submit comments directly to MQAC by August 16.


This rule, when finalized, will instruct prescribers on opioid prescribing. WSHA and WSMA’s letter contains four major recommendations that we encourage you to adopt in your comment letter. Our primary concerns are:

  • Administrative burden;
  • Increased liability;
  • Little time for provider education and implementation; and
  • Lack of alignment between MQAC pain rules and the State Nursing and Dental Commission’s new pain rules.


  1. Review this bulletin and contact WSHA staff if you have questions;
  2. Review WSHA and WSMA’s official comments (Word version) on the proposed rule, specifically our concerns regarding the volume of administrative burden, liability issues, implementation and the lack of alignment between other commissions;
  3. Submit comments to MQAC on the proposed rule by August 16. Send your comments on the proposed rule to the Medical Commission at before Aug. 16. Please also consider sharing a copy with Ian Corbridge,; and
  4. Consider attending the Medical Commission in person meeting on the proposed rule on Aug. 22, beginning at 2 p.m. at the Hotel RL Olympia located at 2300 Evergreen Park Drive SW in Olympia.


MQAC is seeking public comments on its newly released proposed rule on opioid prescribing as required by House Bill 1427. While the current proposal is drastically improved over previous iterations, the WSMA and WSHA Opioid Taskforce remain concerned about the volume of administrative burden and liability these rules will place on providers and hospitals.

Once finalized, the MQAC intends to enact these opioid prescribing requirements in late 2018. This is your final opportunity to provide input on the rule before they are finalized.

Next Steps

Please start working with your clinical leadership to review the proposed rule, WSMA and WSHA’s comments and submit feedback to MQAC as appropriate.

While other state board and commissions are developing new pain rules under 1427, MQAC is further ahead in the process. The WSMA and WSHA Opioid Taskforce have focused efforts on improving MQAC’s proposed rule to maximize resources and to help move other board and commissions to MQAC’s new rule language. A lack of alignment between MQAC and the Washington State Nursing Commission could create significant challenges for providers and hospitals. Please consider having other professions like nursing and pharmacy submit comments to MQAC and to their respective board or commission.

Background and References 

House Bill 1427 was passed in the 2017 legislative session. The new law is a comprehensive piece of public policy aimed at addressing the state’s opioid crisis. The new law targets numerous aspects to addressing the crisis from stopping overdoses to establishing new pain rules for licensed providers who proscribe opiates.

WSHA and WSMA have been engaged in the rulemaking process over the past year, working both with the Washington State Department of Health and MQAC.


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