There’s no standard that I know of, either, Kevin. Have you considered adapting the DOT/FMCSA form that can be used for prescribing physicians to address dosing, side effects, risk of impairment? Not to use the form itself but it could be a starting point for the information to request from their prescriber. Probably given that she works in a correctional institution and takes the medication multiple times a day, even if she is stable, there is the issue of security of her medication to consider, and it would be reasonable to come to a clear agreement and plan for how much medication she brings into the facility with her. Even if her use is stable, appropriate, and non-impairing, she could be at risk of unintentional diversion so it would be important to ensure her meds are not kept on her person or where any of her patients could access them while she is caring for them in the clinic.
It’s not uncommon to come across prescription opiate use for chronic conditions in healthcare workers, often identified during onboarding when a routine screen is positive for a prescription opiate. In new hires, we have no work history to judge if they’ve been safe at work, so we have to evaluate case by case and do as you are doing to get further information from the employee and sometimes their prescribing provider. For someone who has been working without the lack of evidence of impairment or safety concerns is reassuring, as long as you know that is true from the employer and not just the employee’s word for it.
My only other thought is that unless you find something concerning in the information you get from the prescriber, you might just want to ensure that she is under close monitoring with a controlled substance agreement with her provider.
Good luck, I hope it turns out OK!
Melanie
From: MCOH-EH <mcoh-eh-bounces@mylist.net> On Behalf Of
Smith, Kevin
Sent: Friday, July 28, 2023 8:20 AM
To: mcoh-eh@mylist.net
Subject: [EXTERNAL] [MCOH-EH] Pain management
List members,
We are doing a periodic eval on an LPN working in a county jail (not an employee of our hospital). She has been in this facility for about a year. We did not see her for the initial/pre-placement evaluation.
She has chronic LBP, and sees pain management, and apparently is on hydrodocone 10 mg qid, and has been for several years. We are requesting further information from the treating provider as part of an individualized assessment as per ADA.
I'm familiar with recommendations in other safety sensitive environments (i.e. FMCSA, NFPA, FRA, FAA, etc), with regulatory guidance, but do not recall seeing any specific or consensus guidelines covering medical personnel. Concern would be for sedation/cognitive issues, keeping in mind tolerance issues, and the fact that she has apparently been working successfully to the best of our knowledge to date.
With the assistance of our legal team, we reviewed positions of the state regulatory boards (i.e licensing prohibitions, impaired provider programs, etc,,) and have not come up with blanket prohibitions or guidance.
With the lack of specific guidance at the State level, I wanted to reach out to this group to see if anyone is aware of national consensus guidelines or standards that may inform our decision.
Thank you in advance, and hope you have a great weekend!
Kevin M. Smith, MD, MPH, FACOEM
Medical Director
Phoebe Corporate Health
Phoebe Employee Health Services
229-312-9220
229-889-7074 Fax
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