Today, the Overdose Prevention Initiative at the Global Health Advocacy Incubator submitted a comment on the Drug Enforcement Agency’s (DEA) proposed rule for expansion of induction of buprenorphine via telemedicine encounter (Docket No. DEA-948 Document ID: DEA-2023-0028-0001) to modify regulations regarding access to buprenorphine through telemedicine.

Expanding access to treatment for individuals with substance use disorder through telemedicine is critical in saving lives and ending the overdose epidemic — the new DEA rule attests to this. However, the rule also adds a required in-person appointment after thirty days of buprenorphine treatment, rolling back flexibilities allowed during the COVID-19 pandemic. These flexibilities led to increased access to addiction treatment and resulted in higher levels of treatment initiation, but this proposal has the potential to hinder the accessibility of the substance use disorder treatment delivery system for individuals in need of lifesaving care.

“With more than 100,000 Americans dying from overdose each year, treatment for opioid use disorder needs to be easier to access. Telemedicine is a proven way to increase access to medications for opioid use disorder (MOUD) and help people stay in treatment longer,” says Libby Jones, Program Director at the Overdose Prevention Initiative. “The DEA plays a role in delivery of addiction treatment. Instead of adding requirements that make it more difficult to continue treatment, they should align with the Biden Administration’s goal of ensuring universal access to MOUD.”

The Overdose Prevention Initiative asserts that the thirty-day requirement is not grounded in research or best practice and may result in discontinuation of care. If patients’ access to buprenorphine lapses due to the new requirement, they can experience withdrawal from the medication, potentially invoking the return to illicit drug use or overdose. The Overdose Prevention Initiative also cautions that the requirement for an in-person visit could further exacerbate existing inequities for individuals living in rural and remote areas, and those with special needs in accessing treatment, including Americans with disabilities, or whose employment, childcare, or transportation needs limit their travel options.

The Overdose Prevention Initiative encourages the DEA to reconsider the proposed thirty-day requirement. Instead, the Overdose Prevention Initiative recommends extending the window of time a patient can go without an in-person visit to a time period that is informed by clinical guidelines on buprenorphine treatment.

Read our entire comment here: https://www.regulations.gov/comment/DEA-2023-0028-2345

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