Section 303 of the Comprehensive Addiction and Recovery Act (CARA), signed into law by President Obama on July 22, 2016, made several changes to the law regarding office-based opioid addiction treatment with buprenorphine. ASAM's complete summary of CARA is available here.
One of these changes is that prescribing privileges have been expanded to nurse practitioners (NPs) and physician assistants (PAs) for five years (until October 1, 2021). The below information and resources will help members and the public understand this specific change.
On November 17, 2016, the Department of Health and Human Services (HHS) announced that NPs and PAs can immediately begin taking the 24 hours of required training to prescribe buprenorphine for opioid use disorder (please see below for more information on training). NPs and PAs who complete the required training and seek to prescribe buprenorphine for up to 30 patients will be able to apply to do so beginning in early 2017. Once NPs and PAs receive their waiver they can begin prescribing buprenorphine immediately. Any NP or PA who begins to prescribe buprenorphine before applying for and receiving a waiver will be in violation of federal law.
HHS is also announcing its intent to initiate rulemaking to allow NPs and PAs who have prescribed at the 30 patient limit for one year, to apply for a waiver to prescribe buprenorphine for up to 100 patients.
For NPs and PAs to be eligible to apply for a buprenorphine waiver, they must complete 24 hours of training that covers the following topics: opioid maintenance and detoxification; clinical use of all FDA-approved drugs for medication-assisted treatment; patient assessment; treatment planning; psychosocial services; staff roles; and diversion control.
NPs and PAs can begin the training immediately by taking the 8-hour buprenorphine courses offered by ASAM or that other stakeholders offer. The remaining 16 hours will have to be completed with one training provider. ASAM is in the process of developing multiple 16-hour training course options and formats, including collaborations with:
Other providers that can provide the 16 hours of additional training are the American Academy of Addiction Psychiatry, American Medical Association, American Osteopathic Association, American Nurses Credentialing Center, American Psychiatric Association, American Association of Nurse Practitioners, and American Academy of Physician Assistants.
SAMHSA opened a comment period on the 24 hours of training required for Nurse Practitioners and Physician Assistants to be able to apply for a buprenorphine waiver. On behalf of our membership, ASAM submitted these written comments on implementing this training requirement.
NPs and PAs who are approved to prescribe buprenorphine must be supervised by or work in collaboration with a qualifying physician if required by state law. Nurse practice laws and regulations are specific to each state. AANP has created an interactive map to provide licensure and regulatory requirements, as well as practice environment details, for all 50 states and the U.S. Territories. AANP also has a list of state practice laws and regulations categorized by type.