On January 4^th, the American Society of Addiction Medicine (ASAM), sent a letter to provide comments on the Interim Final Rule on the Implementation of the Substance Use-Disorder Prevention That Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act of 2018: Dispensing and Administering Controlled Substances for Medication-Assisted Treatment (the “Interim Final Rule”).

One of the intents of this bill was to expand access to long acting injectable/implantable (“LAI”) buprenorphine products by creating an alternative to the “buy and bill” delivery system for these products. With that intent in mind, and knowing that the Government Accountability Office’s August 2020 Report on Treatment with Injectable and Implantable Buprenorphine revealed both low uptake and low diversion risk of these products, ASAM respectfully recommends that DEA:

• Increase the number of days a practitioner can administer LAI buprenorphine after receipt of the medication pursuant to authority granted under the SUPPORT Act;
• Clarify that practitioners who are not DATA-waived can administer LAI buprenorphine pursuant to a lawful prescription by a DATA-waived practitioner; and
• Treat pharmacists as a practitioner who may administer long-acting injectable (not implantable) buprenorphine to the extent authorized by state law

Taken together, this change and these clarifications can help maximize access to LAI buprenorphine products, particularly for patients in rural areas who may lack access to reliable transportation, and those being treated via telemedicine during the COVID-19 Public Health Emergency.

Read the full letter here

Read the rule here