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traumatic injury with a severity score of 9 or greater, the practitioner must concurrently prescribe an emergency opioid antagonist. Of note is the fact that the statute says a “Schedule II controlled substance” and not an “opioid drug listed as a Schedule II controlled substance.” While it would not make any sense to concurrently prescribe an emergency opioid antagonist with a non-opioid Schedule II controlled substance, the Legislature did not limit this requirement. Hopefully, the boards will interpret this requirement in a reasonable manner. The FMA will seek guidance from the boards and will provide an update as information becomes available. In addition to the 3-7 day limitation on the prescribing of Schedule II opioids, HB 21 requires each board to adopt rules establishing guidelines for prescribing controlled substances for acute pain. The guidelines are to include evaluation of the patient, creation and maintenance of a treatment plan, obtaining informed consent and agreement for treatment, periodic review of the treatment plan, consultation, medical record review, and compliance with controlled substance laws and regulations. It is hoped that the guidelines will provide answers to the inevitable questions that will be raised based on the 3-7 day prescribing limitation. For example, does a physician have to physically see the patient after the 3-7 day prescription expires before the physician can issue another prescription? Can the physician consult with the patient over the phone after the initial 3-7 day prescription period and e-prescribe a Schedule II opioid that the patient can pick up without having to go the physician’s office? Can the physician hand the patient three staggered 3-7-day prescriptions for a Schedule II opioid? The FMA expects the guidelines from the Board of Medicine and Board of Osteopathic Medicine to be adopted sometime after the July 1 effective date of the legislation. The FMA will work to ensure that the guidelines are reasonable, will make all drafts available to our members, and will issue a notification once the guidelines are adopted. Pain-management Clinic Registration: On Oct. 1, 2010, the Florida Statutes began to require “pain-management clinics” to register with the Florida Depart-ment of Health. In 2011, the Legislature amended the definition of a “pain-management clinic” to require registration for all publicly or privately owned facilities that (1) advertise in any medium for any type of pain management services, or (2) where in any month a majority of patients are prescribed opioids, benzodiazepines, barbiturates, or carisoprodol for the treatment of chronic nonmalignant pain. The Legislature exempted the following entities from the registration requirement:• A clinic licensed as a facility pursuant • A clinic in which the majority of the physicians who provide services in the clinic primarily provide surgical service • A clinic owned by a publicly held corporation whose shares are traded on a national exchange or on the over-the-counter market, and whose total assets at the end of the corporation’s most recent fiscal quarter exceeded $50 million • A clinic affiliated with an accredited medical school at which training is provided for medical students, residents, or fellows • A clinic that does not prescribe controlled substances for the treatment of pain• A clinic owned by a corporate entity exempt from federal taxation under 26 U.S.C. s. 501(c)(3)• A clinic wholly owned and operated by one or more board-eligible or board-certified anesthesiologists, physiatrists, rheumatologists, or neurologists• The clinic is wholly owned and operated by a physician multispecialty practice where one or more board-eligible or board-certified medical specialists, who have also completed fellowships in pain medicine approved by the Accreditation Council for Graduate Medical Education or who are also board-certified in pain medicine by the American Board of Pain Medicine or a board approved by the American Board of Medical Specialties, the American Association of Physician Specialists, or the American Osteopathic Association, perform interventional pain procedures of the type routinely billed using surgical codes. Prior to the passage of HB 21, a facility that met the definition of a “pain-management clinic” but did not have to register as a pain-management