Expansion of Induction of Buprenorphine via Telemedicine Encounter (DEA948)
2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31 2023-03-31
DEA-2023-0028-2693 DEA-2023-0028-2696 DEA-2023-0028-2697 DEA-2023-0028-2701 DEA-2023-0028-2709 DEA-2023-0028-2723 DEA-2023-0028-2726 DEA-2023-0028-2741 DEA-2023-0028-2742 DEA-2023-0028-2743
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/DEA-2023-0028-2693 https://api.regulations.gov/v4/comments/DEA-2023-0028-2696 https://api.regulations.gov/v4/comments/DEA-2023-0028-2697 https://api.regulations.gov/v4/comments/DEA-2023-0028-2701 https://api.regulations.gov/v4/comments/DEA-2023-0028-2709 https://api.regulations.gov/v4/comments/DEA-2023-0028-2723 https://api.regulations.gov/v4/comments/DEA-2023-0028-2726 https://api.regulations.gov/v4/comments/DEA-2023-0028-2741 https://api.regulations.gov/v4/comments/DEA-2023-0028-2742 https://api.regulations.gov/v4/comments/DEA-2023-0028-2743
J Rebecca Patrick Anonymous Anonymous Chad Anonymous Chris Anonymous Pia
Craig Devilbiss Blount Anonymous Anonymous Anderson Anonymous Baker Anonymous S
As a telemedicine OUD provider, I strongly oppose the DEAs proposal to require an in-person visit for buprenorphine prescription. This is a high-barrier imposition in an era when primary care is increasingly hard to find. There is a complete lack of evidence for in-person visits improving patient outcomes or preventing diversion. This rule will do an immense amount of harm for patients who are most vulnerable as those are the patients who are least able to complete this unneeded task.  Bicycle Health has changed my life. I abused pain pills since I was 16 yrs old due to a dysfunctional home environment. I am now 38 years old with a 6 yr old autistic son. During Covid and due to my sond behavior I couldnt take the stress and emotional pain anymore and had no where to turn. I started taking Norcos again to help me cope, well sooner than later I needed more and more and it was killing my budget. Mind you all of my immediate family has passed away except for my 67 yr old mother who is not equipped to take my son for me. I cried out to God what do I do!??? I dont want to be on pain pills and I have no way to rehab because no one can take my son (he is nonverbal and Im a single mom) Bicycle Health Team saved my life. I was able to communicate and get help via video and get kind and compassionate help. Please do not enforce a rule or law that would cost so many their lives.  With a medication like buprenorphine, access should be limited as little as possible. Because of the unprecedented rise in opioid related overdoses, drug users should have as much access to regulated safer options like buprenorphine at all times. One should not need a prescription to access this medication. Its not unreasonable for distribution to be monitored, however, especially when considering the ultra-potent opioids that currently keep the illicit market afloat, excessive purchasing of buprenorphine might not indicate illicit redistribution; but the necessary regimen for someone with OUD and an unreasonably high tolerance to live unimpaired. One might argue that increasing access to this extent would increase use among individuals who arent dealing with OUD, however, even in the case that someone who hasnt previously used opioids becomes dependent on buprenorphine, it is a far safer alternative to opioids available from the illicit market. That is ignoring the fact that in many areas, opioids are already available over the counter; like loperamide and tianeptine. Opioids are already readily available to people who dont have a prescription (or a reason to have one), thus more ready access to a reasonably potent opioid like buprenorphine would only serve as a means of harm reduction; allowing anybody who wishes to use an opioid for whatever reason, to do so with a safe, reliable product that is produced within legal regulations, it would slow down the production of novel synthetic opioids created to replace holes in the illicit market, due to a lower demand because of safer access. there are far more benefits to having a legal, easily obtainable substance than one that is prohibited. Looking at alcohol, the situation is almost entirely identical. During prohibition, the purchase of alcohol was made more dangerous because users had to participate in an unregulated market, alcohol that was available was often produced under poor/no regulations and often contained harmful substances like methanol which would result in a deadlier product for users. People can drink themselves to death; and will, whether alcohol is legal, or illegal. The same situation exists with a drug like heroin. People have used opioids for thousands of years, and according to statistics, will continue to do so despite prohibition. If heroin is illegal, the product on the market will be tainted and more dangerous; causing more deaths by overdose. If heroin is legal, the dea can regulate the production of the drug and make sure anyone who uses it is doing so in a far safer environment with a far safer product. legalize and regulate drugs. drug prohibition was created with racist intent and kills people. bye In reference to Docket No. DEA-948, please do not restrict access to treatment for opioid use disorder. Peoples lives depend on this assistance. Thank you! Please do not take telehealth away!!!  The impact that it will have on the elderly, people without transportation, folks scared to leave their homes, etc.  PLEASE THINK ABOUT THE WRONG DECISION YOU ARE MAKING!!!!!!!!!!!! Ive been on a telehealth plan for approximately two years, which has greatly improved my quality of living.  They took baseline bloodtests, prescribed TRT, gonadotropin and an antiestrogen.  Approximately 6 months later we ran blood tests again, made a few small adjustments and everything has been stable the past year.This has led to a much improved quality of life while not requiring monthly, or even quarterly, visits as the prescription is working as planned.  No different than thyroid and many, many other prescriptions.  Once blood markers and the body are in a stable state, there is no reason to meet with a Doctor on a monthly, or even quarterly, basis unless I am feeling off, or a blood test shows an adjustment is necessary.The requirement to see a Doctor every month for TRT is an unnecessary pressure on the medical system and an unnecessary cost to many insurance plans.   To Whom it May Concern:I am a registered nurse in New York State and I work at a clinic that practices Harm Reduction and prescribes buprenorphine products to individuals with opioid dependence all over the state. Being able to treat these patients via telemedicine has allowed us to help not only individuals in our county but those across the entire state. Many people with OUD face other challenges, such as having low to no income, making transportation access very difficult. Some of our patients live several hours away and would not be able to make it to our clinic for an in-person appointment. Being able to complete these appointments exclusively over telemedicine allows us to prescribe buprenorphine, a life-saving medication, to hundreds of individuals who otherwise would not have access. I strongly encourage you to not mandate in-person appointments for individuals receiving MAT for OUD as this would cause many of our patients to loose access to this medication that has the ability to transform someones life for the better.Thank you for considering this comment. Hello, my name is Chris Baker and I was addicted to opioids over 25 years, I had my Dr. help get me off them and he prescribed Methadone, and I overdosed on that drug too even though I took it as prescribed. Im an American Indian and my body doesnt like hard drugs but I have a chronic pain condition so I need something for the pain. I moved to Florida around 6 years ago and heard about Suboxone to get you off the opiate drugs, I have now been on it for 5 years and in the last year been getting it via video conference with my Doc, there is no doctor near me that can prescribe Suboxone and I need it to stay off the opiate addiction that I have. This is the only way I can get my Suboxone and I am disabled and this is way more convenient for me as I have health issues now, please dont take this away from me, I dont know what I would do without it. I would probably go get some pills and get addicted all over again, I cannot take a second round of this, it almost killed me several times!! If you have any questions just contact me. Thank You for your time!!Chris Baker  Ive been prescribed pain meds for 24 year Ive done a two year sentence and a 7 year sentence because of my addiction I found tele health the very day I got released from doing 7 years in prison clean for those 7 years I still had cravings tele health has saved my life and job because I dont have to chose my job or taking a 2 hour round trip to got to a clinic to get dosed before I go to work its very hard and you end up losing one or both. Tele health makes it easy and has support groups to attend please dont change the way tele health is going it saves peoples lives and I am one of those people thank you I am writing to advocate amending Docket No. DEA-948, which would add an in-person requirement to all telehealth prescriptions of buprenorphine for opioid use disorder (OUD). As written, this rule defies evidence-based practice and will prevent critical medical care to those who need it most. Telemedicine delivered by appropriately licensed addiction treatment professionals is one of our best -- and only -- safe, affordable, available tools for fighting the worsening national overdose crisis.As an employee at a telemedicine company providing evidence-based care for individuals suffering from opioid use disorder, Ive seen first-hand the challenges our patients face accessing care. A requirement for an in-person visit would not serve to protect these patients, but rather to prevent them from accessing life-saving treatment. The vast majority of our patients have Medicaid, and they experience wait times well above 6 weeks  sometimes as much as 6 months  to access in person care. In addition, these patients already face barriers such as income or inability to take time off work, geography, lack of transportation, and lack of childcare. These patients  those that face the biggest challenges  have been the ones least considered in formulating this rule.It is imperative that the DEA reconsider its position. If it does not, the consequences will be catastrophic for these patients.