Client Alert: Michigan Controlled Substance Prescribing
Michigan continues to impose significant compliance obligations on prescribers and provider organizations in response to the opioid epidemic. Among the most important requirements is the obligation to establish a bona-fide prescriber-patient relationship before prescribing Schedule II through V controlled substances, a standard that has practical implications for clinical workflows, documentation, and oversight.
As a general matter, Michigan requires an appropriate controlled substance license to prescribe controlled substances in the state. In addition, Michigan law defines a “bona-fide prescriber-patient relationship” as one in which the prescriber has reviewed relevant medical or clinical records, assessed the patient’s medical history and current condition, conducted a relevant medical evaluation in person or through telehealth, and created and maintained records consistent with medically accepted standards.
For providers, this means that prescribing Schedule II through V controlled substances should be supported by a documented clinical foundation, not merely by the issuance of a prescription. The medical record should reflect the prescriber’s review of available records, evaluation of the patient’s condition, and the basis for treatment decisions. Where telehealth is used, organizations should confirm that the encounter and resulting documentation satisfy applicable standards.
Provider organizations should consider reviewing prescribing policies, documentation templates, telehealth protocols, and compliance training to confirm alignment with Michigan requirements. Periodic auditing and monitoring may also help identify gaps in recordkeeping or prescribing practices before they result in regulatory scrutiny or professional discipline. Because regulatory guidance may continue to evolve, providers should continue to monitor developments and update internal processes as needed.
Key takeaway:
Michigan prescribers and healthcare organizations should ensure that controlled substance prescribing practices are supported by a documented bona-fide prescriber-patient relationship, with particular attention to medical record documentation, telehealth workflows, and ongoing compliance oversight.
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