The Dreaded HHS Drug Utilization Review Board Letter re Morphine Equivalents, What Does it Mean?

The Michigan Health and Human Services Drug Utilization Review Board (DUR) monitors the safety of medication use and prescribing trends within the Michigan Medicaid population. The DUR analyzes Medicaid claims to determine how your statistical prescribing habits measure up with the average Medicaid prescriber. The DUR began sending letters to physicians who they believe are “high volume opioid prescribers”. This letter can be quite alarming for a physician but what does it mean? Receiving this letter from the DUR simply means that you may have been “red flagged” as a physician potentially engaging in prescribing without medical necessity or Medicaid fraud or Medicare fraud. Essentially your Morphine Equivalent Daily Dose (MEDD) is higher than the DUR’s statistical average which prompted this letter. There may be an innocent explanation for this, it is important to note that the DUR does not use geographic region, scope of your practice, and the medical needs of your patients when determining whether or not you statically deviate from other prescribers. However, regardless of the reason for the statistical deviation it is highly likely that health and human services and the medical board will consider investigating your practice.

Therefore, it is vital that you immediately contact an experienced healthcare law attorney to discuss your prescribing habits and potentially conduct an audit to prevent or mitigate the potential for a DEA, HHS or DOJ investigation into your practice. Chapman Law Group has successfully aided a number of practitioners who have received similar letters and prevented or mitigated collateral consequences. Call us today at (248) 644-6326.