APA, the American Academy of Addiction Medicine (AAAM), and the American Osteopathic Academy of Addiction Medicine (AOAAM) advocate replacing the current practice limits of 30/100 patients, established under the Drug Abuse Treatment Act (DATA) of 2000, with a three-tiered system.
Tier 1. Small Primary Care or Psychiatry Practices. Physicians in this tier would be allowed to follow up to 30 patients at one time, as with the present system; however, there would be no Drug Enforcement Administration (DEA) inspections unless DEA or single state agency review of state Prescription Drug Monitoring Program data suggest the 30-patient limit has been exceeded.
Tier 2. Solo or Multidisciplinary Practice Model. In the solo practice model (including a group or multiple physicians practicing within the same system), physicians would be able to apply (after one year) to increase their patient load receiving buprenorphine from the 30 patient limit to 150 patients. Prescribers in this group would be required to take three hours of approved addiction-related CME annually, certify that they follow a nationally recognized set of standard evidence-based guidelines for the treatment of patients with substance use disorders, and undergo occasional DEA inspections, as in the current system.
In the multidisciplinary practice model, a physician would be able to apply (after one year) to increase the patient load receiving buprenorphine from the 30 patient limit to a range of up to 340 patients with the addition of up to three physician extenders to the practice (either physician assistants or nurse practitioners). The physician would be capped at 100 patients; each physician extender would be capped at 80 patients, with the total practice capped at 180 to 340 patients depending on the number of physician extenders in the group.
Tier 3. Specialized Opioid Treatment Programs. These practices would be permitted to treat more than 340 patients. They would require separate registration as a specialized Opioid Treatment Program, be monitored accordingly with varying staffing requirements related to the number of patients being treated, and be subject to periodic reviews by the DEA and the Commission on Accreditation of Rehabilitation Facilities or The Joint Commission.
Further APA, AAAM, and AOAAM recommend expanding the numbers of prescribers in the following ways:
•
Permit buprenorphine prescribing by physician assistants and nurse practitioners (in those states or jurisdictions where such practice is permitted) who have taken an eight-hour face-to-face waiver course, who take three hours of approved addiction-related CME annually, and who practice under the supervision of a physician certified in addiction psychiatry or addiction medicine.
•
Explore options utilizing telemedicine that would permit delivery of buprenorphine services in rural or underserved areas.
•
Enhance federal funding for buprenorphine training for physicians and physician extenders, as well as ongoing CME programs to enhance the clinical skills of treatment providers.
•
Set aside government funding for residency training programs to provide training in medication-assisted treatment (MAT), physician training in MAT through ABPN-approved addiction psychiatry fellowships, and general practice addiction medicine fellowships.
•
Provide funds to cover the costs of an expanded treatment system for uninsured individuals with opioid use disorders, as well as those covered under Medicaid programs. ■