OSMA Responds to Med Board OARRS Letter Issues


October 18, 2018

A.J. Groeber
Executive Director
State Medical Board of Ohio
30 East Broad Street, 3rd Floor
Columbus, OH 43215

Dear Mr. Groeber,

The Ohio State Medical Association (OSMA), representing over 12,000 Ohio physicians, would like to comment on your recent OARRS compliance letters to physicians.

We understand and appreciate that the State Medical Board of Ohio is tasked with ensuring that licensed Ohio physicians comply with Ohio’s prescribing rules. The OSMA has been closely involved with the development of Ohio’s opioid prescribing rules, guidelines and legislation. The OSMA worked closely with regulators and lawmakers when enforcement and tracking efforts substantially increased following the passage of Ohio House Bill 93, Ohio’s initial response to addressing the alarming “pill mill” issue. OSMA physicians served on the Governor’s Cabinet Opioid Action Team (GCOAT) and we have provided physician feedback and expertise on the numerous legislative and regulatory initiatives dealing with the treatment of acute and chronic pain and opioid prescribing.

The OSMA works diligently to provide updated prescribing and treatment information to our members. As you are aware, the OSMA launched SmartRx®, our online opioid prescribing education tool, so our members (and all Ohio physicians) would have access to accurate information that we update as the rules and laws change. Our members look to us as a reliable education source and credible point of contact when they are seeking clarification of an Ohio law, rule, or guideline. Because the OSMA is known as a credible source of information regarding the regulatory and legislative landscape in Ohio, we are sometimes a physician’s first point of contact when they receive a letter from the medical board. The board’s most recent letter to licensees is no exception. The OSMA received numerous calls and emails from frustrated physicians following the issuance of these letters.

The OSMA would like to address some of the concerns we heard from our members and we encourage the board to consider our input pertaining to these, and similar, issues.

Incorrect Medical License Numbers:
The first issue brought to our attention by our members was that the medical license number provided on the letter did not correspond with the physician who received the letter. The greatest concern in regard to this issue was that the OARRS/ICD-10 data provided in the letter was not intended for the licensee who received the letter, but instead intended for the owner of the incorrect medical license number. OSMA staff immediately reached out to the medical board and was at that point informed that the board was aware that some, not all, of the letters were incorrectly processed, but that the data in the letters corresponded to the addressee, not the owner of the incorrect medical license number.

While we do not know how many physicians this error effected, we hope that the medical board was able to identify these physicians, alert them of the error, and reassure them of the validity of the data in the letters.

OARRS Data Unavailability: The most concerning issue that we were made aware of was the inability of physicians to check the OARRS system to confirm or dispute the information provided in the board’s letter. We heard from a number of physicians who were frustrated because they could not prove or disprove the board’s claims because the OARRS site did not allow them to research missing OARRS checks for the month of August 2018. The OSMA learned, through outreach to the pharmacy board, that the August 2018 OARRS data had not yet been loaded and made available before the letters were sent out to physicians. The OSMA has since been advised that the August 2018 data has been loaded and we have conveyed that information to our members.

If you will, imagine the fear that a physician feels when they receive any communication from the medical board indicating that they are not compliant with Ohio’s rules. Now imagine, in addition to fear, the frustration a physician feels when he/she tries to investigate the board’s claims and cannot adequately perform that investigation because the tools, that should be available, are not there. This is simply not an acceptable way to treat Ohio’s physicians.

As for the board’s incorrect medical license number issue, it is unfortunate, but we understand that processing mistakes can occur with large-scale data projects. The OSMA expects that the board will reach out to those physicians who are affected and inform them of the mistake. Regarding the bigger issue of coordination of efforts with the pharmacy board, the OSMA urges the medical board to make certain that OARRS data is updated and available before any compliance communications are sent to licensees. As you are aware, this is not the first time the medical board has had issues following the issuance of OARRS compliance letters to licensees. The OSMA encourages the medical board to make every possible effort to ensure that future letters, and any associated data systems, are aptly timed and meticulously verified prior to processing and distribution.

The medical board and the OSMA have the common goal of educating Ohio’s physicians about the rules and laws they must follow when caring for their patients. If there is anything the OSMA can do to assist the medical board in this effort, please feel free to reach out to us.


Evangeline C. Andarsio, MD
Ohio State Medical Association

C: OSMA Council
Todd Baker, CEO, Ohio State Medical Association