What happens if I am an medical doctor (MD) or osteopathic medical doctor (DO) practicing in a pain management clinic that should register but hasn’t done so?

A MD or DO is subject to discipline if they practice in a pain management clinic that is required to register with the Department and has not done so. Submission of an application is not approval.

Does the clinic/facility/office have to be inspected?

Yes. Inspections are not conducted before registration but will occur within a year of registration. The annual inspection fee of $1,500 is due at the time of the inspection.

No accrediting organizations have yet been approved by the Boards of Medicine and Osteopathic Medicine. Therefore, the “Inspection” option is the only option currently available in Section 7 of the application.

What are the requirements for registering?

The application will have full instructions, including the requirements for registration and copies of relevant statutes and rules. The application fee is $150.

Are physicians practicing in a pain-management clinic required to have special training?

Yes. Effective July 1, 2012, physicians practicing in pain management clinics are required to meet the training requirement provided in Rules 64B8-9.0131 and 64B15-14.0051, Florida Administrative Code.

I would like to participate or send documentation for the board’s consideration during the rulemaking process. How would I do that?

The Florida Board of Medicine meets bimonthly, generally on the first weekend of the month.

You can send us an email with meeting materials. We ask that materials be submitted one month prior to any meeting to allow the board members time to read the materials by the meeting date.

How long will it take to process my application?

Florida law requires that an initial application must be reviewed within 30 days. More information about processing times is available on the Florida Board of Medicine’s website.

Am I exempt from registering as a pain clinic?

You are exempt from registration if you are licensed under Chapter 395, Florida Statutes.

  • Majority of physicians who provide services in the clinic provide surgical services
  • Clinic is 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
  • Clinic is affiliated with an accredited medical school at which training in provided for medical students, residents, or fellows
  • Clinic does not prescribe or dispense controlled substances for the treatment of pain
  • Clinic is owned by a corporate entity exempt from federal taxation under section 501(c)(3) of Title 26, United States Code.
Who may own a pain management clinic?

It must be one of the following:

  • Medical doctor and/or osteopathic medical doctor
  • Group of medical doctors and/or osteopathic medical doctors
  • Entities registered under Section X of Chapter 400, Florida Statutes (Florida Agency for Healthcare Administration)

Any change in ownership requires a new application.

Can my pain management clinic application be denied?

Yes. We will deny your application if the clinic is not owned by anyone described in the above panel.

We will also deny registration to any clinic owned by or with any contractual or employment relationship with a physician whose:

  • Drug Enforcement Administration number has been revoked
  • Application for license to prescribe, dispense, or administer a controlled substance has been denied by any jurisdiction

We will also deny registration if any associated physician has been convicted of or has plead guilty or nolo contendere to a felony offense for receipt of illicit and diverted drugs, including a controlled substance listed under Schedule I, II, III, IV, or V of section 893.03, Florida Statutes, in this state, any other state, or any jurisdiction of the United States.

What are other requirements I should be aware of?

Other requirements for pain management clinics include:

  • A physical exam must be performed on the same day the physician prescribes or dispenses a controlled substance.
  • If the physician is prescribing or dispensing more than a 72-hour supply of controlled substances for non-malignant pain, the physician must document the reason in the patient’s medical record.
  • Each physician is responsible for maintaining control and security of prescription blanks and any other method used for prescribing controlled substances.
  • Each physician must use counterfeit-resistant prescription blanks.
  • All physicians must notify the Department within 24 hours of any theft or loss of a prescription blank or breach of any other method for prescribing pain medication.
  • The medical doctor or osteopathic medical doctor must dispense all medications.
How do I submit my quarterly data report?

Your designated physician can submit your quarterly data reports online under “Pain Management Clinic Quarterly Report.” After submitting the data, print the confirmation page and keep it on file for inspections.

You cannot submit late forms through the online reporting system. Any late forms must be mailed to the Florida Board of Medicine.