1. How do I find a doctor who prescribes buprenorphine for the
treatment of opioid addiction?
2. Can buprenorphine be used to treat addiction to prescription
pain relievers, such as oxycodone or codeine?
3. Can Buprenex®, or any other medications besides
Subutex® and Suboxone®, be prescribed/dispensed
for opioid addiction treatment in practice settings other
than Opioid Treatment Programs (OTPs) (i.e., methadone
clinics)?
4. I submitted my waiver notification to SAMHSA a few weeks ago
and received an acknowledgment letter, but haven’t I
heard anything since. How can I check on the status of my
waiver?
5. I am a waived physician and would like to add, change, or
remove my listing on the SAMHSA Buprenorphine Physician Locator
Web site. How do I do this?
6. I am a waived physician, and Ive moved my practice location
since receiving my waiver. Do I need to notify SAMHSA or DEA of
my new practice address?
7. With a DATA 2000 waiver, can I
prescribe
Subutex® or Suboxone® for opioid addiction in more
than one practice location? Can I
dispense
Subutex® or Suboxone® from more than one location?
8. Ive heard this new model for the treatment of opioid
addiction referred to as "office-based opioid therapy."
Does that mean that physicians with DATA 2000 waivers can use
Subutex® and Suboxone® to treat opioid addiction only
in the office-based setting?
9. Are there specific Federal record keeping requirements
for office-based opioid therapy?
10. Does DATA 2000 limit the number of patients who may be
treated for opioid addiction at any one time by a physician
group practice?
11. Is there a limit on the number of patients a practitioner
may treat with buprenorphine at any one time?
12. Can an Opioid Treatment Program (i.e., methadone clinic or
OTP) dispense Subutex® and Suboxone® to patients
admitted to the program? If so, is there a limit on the number
of patients who can be treated with Subutex® and Suboxone®
for opioid addiction treatment in an OTP? Is a DATA 2000 waiver
required?
13. Can the medical personnel in correctional facilities
dispense (or administer) buprenorphine to incarcerated
individuals?
14. Can physicians and other authorized hospital staff
administer buprenorphine to a patient who is addicted to
opioids but who is admitted to a hospital for a condition other
than opioid addiction?
15. Can Physician Assistants or Nurse Practitioners prescribe
buprenorphine for opioid addiction treatment in States that
permit them to prescribe Schedule III, IV, or V medications?
16. May physicians in residency training programs obtain DATA
waivers?
17. Where can I get a copy of the
Buprenorphine Clinical Practice Guidelines?
18. Are Subutex® and Suboxone® available in pharmacies?
19. Do pharmacies need waivers to dispense buprenorphine?
20. How can a pharmacist verify if a physician has a waiver to
prescribe buprenorphine (Subutex® or Suboxone®) for the
treatment of opioid addiction?
21. Can Subutex® or Suboxone® be prescribed for
conditions other than opioid addiction (e.g., pain control)?
22. Can buprenorphine be used to treat cocaine addiction?
23. Can a person currently being treated with methadone switch
to buprenorphine without suffering withdrawal symptoms?
24. How much will a dose of buprenorphine cost a consumer?
25. Will Medicare and Medicaid cover substance abuse treatment
and buprenorphine?
26. Will buprenorphine be available in treatment programs for
indigent patients and patients who dont have Medicaid or
Medicare?
27. Where can I find out more information about buprenorphine
treatment for opioid addiction?
28. As a physician employed by the Federal Government
(Veterans Administration, Indian Health Service, Federal
Department of Corrections, etc.) practicing in a
Federal Government installation, am I eligible for a DATA
2000 waiver?
29. Can physicians begin immediately treating patients
if they have checked “Immediate” on the
waiver notification form?
30. Are there exceptions when Subutex® and Suboxone®
may be administered by a practitioner without the
DATA 2000 waiver?
1. How do I find a doctor who prescribes buprenorphine for the
treatment of opioid addiction?
Doctors in each State who have waivers to prescribe buprenorphine
for the treatment of opioid addiction are listed on the
SAMHSA Buprenorphine Physician and Treatment Program Locator
Web site.
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2. Can buprenorphine be used to treat addiction to prescription
pain relievers, such as oxycodone or codeine?
Prescription pain relievers like oxycodone and codeine are opioids.
Buprenorphine is used to treat addiction to opioids. Buprenorphine
prevents withdrawal symptoms so that a person can stop taking the
opioid drug to which he or she is addicted. A doctor who is qualified
in the use of buprenorphine can determine if it is a good choice for a
patient who is addicted to opioid pain relievers.
Doctors in each State who have waivers to prescribe buprenorphine
for the treatment of opioid addiction are listed on the
SAMHSA Buprenorphine Physician and Treatment Program Locator
Web site.
-top-
3. Can Buprenex®, or any other medications besides Subutex®
and Suboxone®, be prescribed/dispensed for opioid addiction
treatment in practice settings other than Opioid Treatment
Programs (OTPs) (i.e., methadone clinics)?
No. At the present time Subutex® and Suboxone® are the only
Schedule III, IV, or V substances to have received Food and Drug
Administration approval for opioid addiction treatment. Thus, they are
the only opioid medications that may be prescribed or dispensed for
this indication outside the OTP setting. The approval of Subutex®
and Suboxone® does not affect the status of any other medications.
Buprenex® is not approved for treatment of opioid addiction. The
status of methadone and LAAM are also unchanged. They still can be
only dispensed, not prescribed, for opioid addiction, and only at
Federally regulated OTPs.
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4. I submitted my waiver notification to SAMHSA a few weeks ago
and received an acknowledgment letter, but I haven’t
heard anything since. How can I check on the status of my
waiver?
If you have submitted a notification and received an
acknowledgment letter (or e-mail) from us, then your notification
is under active review. It is SAMHSA’s intent to complete
the review of notifications within 45 days of receipt. When
processing of your notification is complete, we will mail you a
letter confirming your waiver and containing your prescribing
identification number.
If you have submitted a notification and received an
acknowledgment from us, and it has been more than 2 months since
you submitted your notification, OR if you submitted a
notification and you did not receive an acknowledgment from us
that it had been received, please call 1-866-BUP-CSAT
(1-866-287-2728) or e-mail
info@buprenorphine.samhsa.gov.
Please be prepared to provide the date when you submitted your original notification
and other identifying information.
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5. I am a waived physician and would like to add, change, or remove my
listing on the SAMHSA Buprenorphine Physician and Treatment Program Locator Web site. How do
I do this?
Waived physicians may call 1-866-BUP-CSAT (1-866-287-2728) or
e-mail
info@buprenorphine.samhsa.gov
with requests to change
Locator
listings.
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6. I am a waived physician, and Ive moved my practice location
since receiving my waiver. Do I need to notify SAMHSA or DEA of
my new practice address?
Waived physicians who change the primary practice address at which
they intend to treat opioid addiction under the authority of their
DATA 2000 waiver must notify SAMHSA by calling 1-866-BUP-CSAT
(1-866-287-2728) or via e-mail at
info@buprenorphine.samhsa.gov.
The Drug Enforcement Administration must also be notified. Call the DEA Office of Diversion
Control at 1-800-882-9539. Phone numbers for local DEA offices can be found on the
DEA Web site at http://www.dea.gov.
-top-
7. With a DATA 2000 waiver, can I
prescribe
Subutex® or Suboxone® for opioid addiction in more
than one practice location? Can I
dispense
Subutex® or Suboxone® from more than one location?
Physicians with DATA 2000 waivers may prescribe Subutex® or
Suboxone® for opioid addiction in any appropriate practice
setting in which they are otherwise credentialed to practice
(e.g., office, hospital). However, they may store and dispense
Subutex® or Suboxone® (or any other controlled substances)
only at the practice address(es) that they have registered with
the DEA. Only one DATA-waiver unique identification number will be
issued for each DATA-waived physician, no matter how many practice
locations or DEA registrations a physician may have.
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8. Ive heard this new model for the treatment of opioid
addiction referred to as "office-based opioid therapy."
Does that mean that physicians with DATA 2000 waivers can use
Subutex® and Suboxone® to treat opioid addiction only
in the office-based setting?
No. Treatment of opioid addiction under the authority of a DATA
2000 waiver is not confined to the office-based setting.
Physicians with DATA 2000 waivers may treat opioid addiction with
Subutex® and Suboxone® in any practice settings in which
they are otherwise credentialed to practice and in which such
treatment would be medically appropriate (e.g., office, community
hospital, health department).
-top-
9. Are there specific Federal record keeping requirements for
office-based opioid therapy?
DEA record keeping requirements for office-based opioid therapy go
beyond the Schedule III record keeping requirements. According to
DEA:
Practitioners must keep records (including an inventory that accounts
for amounts received and amounts dispensed) for all controlled
substances dispensed, including Subutex and Suboxone (21 PART
1304.03[b]). In some cases, patients return to the prescribing
physician with their filled Subutex or Suboxone prescriptions so that
the practitioner can monitor the induction process. While it is
acceptable for the patient to return to the practitioner with their
filled prescription supplies, practitioners shall not store and
dispense controlled substances that are the result of filled patient
prescriptions.
Practitioners must keep records for controlled substances prescribed
and dispensed to patients for maintenance or detoxification treatment
(21 CFR Section 1304.03[c]). Many practitioners comply with this
requirement by creating a log that identifies the patient (an ID
number may be used instead of name), the name of the drug prescribed
or dispensed, as well as the strength and quantity and date of
issuance or dispensing. Some physicians comply with this requirement
by keeping a copy of the prescription in the patient record.
Alternatively, DEA suggests that practitioners could keep separate
records for controlled substances prescribed and dispensed for
maintenance or detoxification treatment to facilitate the record
reviews during physician inspections for DATA compliance. This way,
DEA will only review those records related to controlled substances
prescribed and dispensed for maintenance or detoxification treatment
for physicians maintaining separate records.
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10. Does DATA 2000 limit the number of patients who may be
treated for opioid addiction at any one time by a physician
group practice?
The physician group practice limit was eliminated by Public Law 109-56, which became effective August 2, 2005.
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11. Is there a limit on the number of patients a practitioner
may treat with buprenorphine at any one time?
Yes. DATA 2000, as amended in December 2006, specifies that an individual physician may have a maximum of 30 patients on opioid therapy at any one time for the first year. One year after the date on which a physician submitted the initial notification, the physician may submit a second notification of the need and intent to treat up to 100 patients.
-top-
12. Can an Opioid Treatment Program (i.e., methadone clinic or
OTP) dispense Subutex® and Suboxone® to patients
admitted to the program? If so, is there a limit on the number
of patients who can be treated with Subutex® and Suboxone®
for opioid addiction treatment in an OTP? Is a DATA 2000 waiver
required?
New SAMHSA regulations permit OTPs serving persons addicted to
prescription opioids or heroin to offer buprenorphine treatment
along with methadone and ORLAAM®. These regulations enable
OTPs that are certified by SAMHSA to use Subutex® and
Suboxone® for opioid maintenance or detoxification treatment.
Follow this link to read the
text of the Federal regulation (PDF, 43 kb).
The provision of opioid addiction treatment with Subutex® and
Suboxone® in OTPs certified by SAMHSA/CSAT does not require a
DATA 2000 waiver. Additionally, such treatment is not subject to
the patient limits that apply to individual physicians providing opioid addiction treatment outside the
OTP system under the authority of a DATA 2000 waiver. The
provision of opioid addiction treatment with Subutex® or
Suboxone® in treatment settings other than OTPs, even by
physicians who are licensed to practice in OTPs, does require a
DATA 2000 waiver and is subject to the patient limits for
individual physicians.
OTPs providing Subutex® and Suboxone® for opioid
maintenance or detoxification treatment must conform to the
Federal opioid treatment standards set forth under 42 C.F.R. §
8.12. These regulations require that OTPs provide medical,
counseling, drug abuse testing, and other services to patients
admitted to treatment. To offer Subutex® and Suboxone®,
OTPs will need to review their State licensing laws and
regulations and to modify their registration with the DEA to add
Schedule III narcotics to their registration certificates. Opioid
treatment programs can initiate this streamlined process by fax or
letter. The letter should include the OTP’s DEA registration
number and request that the registration be amended to list
Schedule III narcotic drugs. The letter must be signed by the
Program Sponsor (Program Director) or Medical Director. The
completed letter can be either faxed to Ms. Ghana Giles at
202-353-1125 or mailed to Ms. Giles at DEA, Registration Unit -
OPRR, Washington, DC, 20537. In addition, OTPs can access the
DEA
registration
Web
site
for more information.
Once the registration has been modified, OTPs can order Subutex®
and Suboxone® directly from Reckitt Benckiser, the product
manufacturer, by calling 1-877-782-6966.
-top-
13. Can the medical personnel in correctional facilities
dispense (or administer) buprenorphine to incarcerated
individuals?
Qualified physicians who have obtained a DATA 2000 waiver can dispense
or prescribe Subutex® or Suboxone® for addiction treatment in
any practice setting, including in correctional facilities. Currently,
State laws and policies vary considerably regarding opioid-assisted
(methadone) treatment within correctional facilities. It is assumed
that this same variation will occur with the use of buprenorphine in
this setting. The patient limits per waived physician as stated in the DATA 2000 legislation also apply to the
prescribing or dispensing of this treatment in correctional facilities.
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14. Can physicians and other authorized hospital staff
administer buprenorphine to a patient who is addicted to
opioids but who is admitted to a hospital for a condition other
than opioid addiction?
Neither the Controlled Substances Act (as amended by the Drug
Addiction Treatment Act of 2000) nor DEA implementing regulations (21
CFR 1306.07(c)) impose any limitations on a physician or other
authorized hospital staff to maintain or detoxify a person with an
opioid treatment drug like buprenorphine as an incidental adjunct to
medical or surgical conditions other than opioid addiction.
Thus, a patient with opioid addiction who is admitted to a hospital
for a primary medical problem other than opioid addiction (e.g.,
myocardial infarction) may be administered opioid agonist medications
(e.g., methadone, buprenorphine) to prevent opioid withdrawal that
would complicate the primary medical problem. A DATA 2000 waiver is
not required for practitioners in order to administer or dispense
buprenorphine (or methadone) in this circumstance. It is good practice
for the admitting physician to consult with the patients addiction
treatment provider, when possible, to obtain treatment history.
-top-
15. Can Physician Assistants or Nurse Practitioners prescribe
buprenorphine for opioid addiction treatment in States that
permit them to prescribe Schedule III, IV, or V medications?
No. Under DATA 2000, waivers to permit the prescription of Schedule
III, IV, or V medications for opioid addiction treatment are available
only to "qualifying physicians." The term "qualifying
physician" is specifically defined in DATA 2000 as a "physician
who is licensed under State law," has DEA registration to
dispense controlled substances, has the capacity to refer patients for
counseling and ancillary services, will treat no more than 30 such
patients at any one time, and is qualified by certification, training,
and/or experience to treat opioid addiction.
-top-
16. May physicians in residency training programs obtain DATA
waivers?
The DATA legislation does not specify that a physician in a
residency training program who otherwise meets the qualifications
for a DATA waiver is ineligible to apply for and obtain a waiver.
Therefore, SAMHSA has granted DATA waivers to physicians in
residency training who have unrestricted licenses and the
appropriate DEA registration. Individual States may have laws with
more restrictive rules regarding who may prescribe or dispense
Schedule III narcotic drugs for detoxification or maintenance
treatment.
-top-
17. Where can I get a copy of the
Buprenorphine Clinical Practice Guidelines?
Follow this link to download a copy of the Clinical Guidelines for the Use of Buprenorphine in the Treatment of Opioid Addiction, Treatment Improvement Protocol (TIP) 40 (pdf, 1.1 MB).
TIP 40 is available via
SAMHSAs National Clearinghouse
for Alcohol and Drug Information (NCADI), or by calling 1-800-729-6686.
It will also be available in the near future from the
National Library of Medicine (NLM),
or by calling 1-888-346-3656.
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18. Are Subutex® and Suboxone® available in pharmacies?
Subutex® and Suboxone® are available in pharmacies throughout
the United States. Pharmacies and physicians can obtain the
medications by contacting a pharmaceutical wholesaler directly, or by
contacting the drug manufacturer, Reckitt Benckiser, at
1-877-782-6966. Consumers may also call the same toll-free number for
additional information.
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19. Do pharmacies need waivers to dispense buprenorphine?
No. Physicians are required to obtain DATA 2000 waivers to prescribe
and dispense buprenorphine (Subutex® and Suboxone®) for opioid
addiction, but pharmacists and pharmacies are not required to have any
special credentials for dispensing these medications above and beyond
those for other Schedule III medications. Certain Federal laws and
regulations, however, do affect pharmacy practice with regard to
opioid addiction treatment prescriptions.
-top-
20. How can a pharmacist verify if a physician has a waiver to
prescribe buprenorphine (Subutex® or Suboxone®) for the
treatment of opioid addiction?
Effective July 25, 2005, physicians must include their DATA 2000
waiver ID number on prescriptions for opioid addiction treatment
medications. The practitioners DEA registration number and the unique
identification number (DATA 2000 waiver ID number or "X"
number) must be on the prescription 21 CFR 1306.05(a). The
identification number is not in lieu of the DEA registration number,
it is an addition. If the prescription is telephoned to the pharmacy,
the pharmacist must have both of these numbers on the prescription
record so the physician can provide the numbers or the pharmacist may
have them on file.
The
SAMHSA Buprenorphine Physician and Treatment Program
Locator
Web site lists the physicians in each State who have DATA 2000
waivers. A physician listed on the site can be considered to have
a valid DATA 2000 waiver. Note, however, that the site does not list every physician with
a valid waiver, only those who have agreed to be listed on the site.
Physicians with valid waivers may choose not to be listed on the site.
A pharmacist desiring to verify that a physician who is not listed
on the site has a valid DATA 2000 waiver can contact the CSAT Buprenorphine Information Center, 1-866-BUP-CSAT (1-866-287-2728) or via e-mail at
info@buprenorphine.samhsa.gov.
Pharmacists should convey their DEA registration number with these requests.
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21. Can Subutex® or Suboxone® be prescribed for
conditions other than opioid addiction (e.g., pain control)?
Subutex® and Suboxone® have received FDA approval only for
the treatment of opioid addiction. However, once approved, a drug
product may be prescribed by a licensed physician for any use
that, based on the physician’s professional opinion, is
deemed to be appropriate. Neither the FDA nor the Federal
government regulates the practice of medicine. Any approved
product may be used by a licensed practitioner for uses other than
those stated in the product label. Off-label use is not illegal,
but it means that the data to support that use has not been
independently reviewed by the FDA. Information on FDA policy
regarding off-label use of pharmaceuticals is available on the FDA
Web site,
http://www.fda.gov/cder/cancer/tour.htm,
or
http://www.fda.gov/cder/present/diamontreal/regappr/index.htm
Physicians and other practitioners who are authorized to prescribe
Schedule III controlled narcotic medications under Federal and State
laws are eligible and the unique identifier under the Drug Addiction
Treatment Act is not required.
-top-
22. Can buprenorphine be used to treat cocaine addiction?
Cocaine is not an opioid drug. According to the approved product
labeling, Suboxone® and Subutex® are indicated for the
treatment of opioid addiction. In addition, under DATA 2000, codified
at 21 U.S.C. 823(g), prescription use of Suboxone® and Subutex®
in the treatment of opioid addiction is limited to physicians who meet
certain qualifying requirements, and have notified the Secretary of
Health and Human Services (HHS) of their intent to prescribe this
product for the treatment of opioid addiction.
-top-
23. Can a person currently being treated with methadone switch
to buprenorphine without suffering withdrawal symptoms?
Patients can switch from methadone to buprenorphine treatment, but
because the two drugs are very different, patients are not always
satisfied with the results. A number of factors affect whether
buprenorphine is a good choice for someone who is currently receiving
methadone. It is also possible for patients receiving buprenorphine to
be switched to methadone. Patients interested in finding out more
about the possibility of switching treatment should discuss this with
the doctor who is prescribing their medication.
-top-
24. How much will a dose of buprenorphine cost a consumer?
The final cost to consumers of prescribed outpatient medication such
as buprenorphine is determined by several parties: the pharmaceutical
manufacturer, the insurer, the health plan (if any) or prescribing
clinic, and finally, by the retail pharmacies that typically dispense
the medication. It is important to note that the cost of buprenorphine
itself is only one part of the cost of outpatient opioid treatment,
which also includes the cost of each physician visit, any charges for
laboratory analyses or emergency detoxification or stabilization, and
any necessary ongoing service referrals and visits that are determined
by the physician who prescribes the medication.
-top-
25. Will Medicare and Medicaid cover substance abuse treatment
and buprenorphine?
Medicare
Substance abuse treatment may be covered under Medicare if it is
determined to be medically necessary and it is provided in an
inpatient or outpatient treatment center that is
Medicare-certified according to the HHS. Medicare does not
generally cover prescription drugs that are prescribed or
dispensed to individuals on an outpatient basis. If buprenorphine
is administered by a Medicare-certified facility as a component of
inpatient or emergency treatment such as detoxification or early
stage stabilization treatment, rather than being a separate
outpatient prescription, the medication’s cost could be
covered during that episode of care, just as the cost for any
other medication used in the treatment process is covered when
administered within a certified program/facility. However, this
reimbursement would only occur if the Medicare-certified facility
had buprenorphine on its list of eligible drugs and if the patient
received the treatment at the facility.
There is currently no Medicare fee-for-service coverage for
buprenorphine prescribed by a physician during an outpatient office
visit, whether for outpatient detoxification, early stabilization, or
maintenance. However, if a person is covered by a Medicare HMO that
has a substance abuse and a pharmacy benefit, buprenorphine could be
covered if it is on that particular plan’s formulary and is
determined to be medically necessary under the plan’s coverage
policies. Additionally, some Medicare beneficiaries have Medicare
supplementary or Medi-gap insurance that covers some pharmaceutical
benefits. Again, however, even under a supplementary plan, there may
or may not be benefits for substance abuse treatment or for
buprenorphine if it is not on the supplementary insurer’s
formulary. Medicare HMO members should read their coverage bulletins
or call their plans to determine whether they have coverage for
buprenorphine and for substance abuse treatment. Many HMOs do not
cover outpatient substance abuse treatment except on an emergency
basis required by law.
Medicaid
Medicaid coverage of substance abuse treatment and medication
such as buprenorphine varies considerably by State and by whether
the State’s Medicaid plan is offered under managed
care/HMO arrangements. Coverage of buprenorphine and/or substance
abuse treatment connected with buprenorphine under Medicaid
benefits will not only be a State-by-State decision, but will also
be subject in most States to rules about prior authorization and
medical necessity. In addition, in many States, Medicaid programs
operate with a preferred drug list on which buprenorphine must be
placed before it can be reimbursed. State Medicaid programs
administered by HMOs may have an additional level of formulary and
treatment authorization that affects whether or not buprenorphine,
and treatment connected to it, is covered.
-top-
26. Will buprenorphine be available in treatment programs for
indigent patients and patients who dont have Medicaid or
Medicare?
Community health centers, clinics, and hospitals offering free
care to indigent individuals may or may not make buprenorphine
available. Availability will depend on whether that health
center or hospital offers substance abuse treatment or emergency
care of addictions and whether buprenorphine is available
on its formulary, as well as whether there is a staff/attending
physician associated with the hospital who is qualified to
administer the drug and whether the medication is determined to be
medically necessary.
Individuals not eligible for Medicaid or Medicare who are not indigent
fall into two categories: those who have commercial insurance coverage
and those who do not. If an individual has insurance coverage outside
of Medicare and Medicaid, the individual’s insurance plan may or
may not cover all or part of buprenorphine medication, depending on
medical necessity, whether pharmaceuticals are covered, whether
there is a required co-payment, and whether buprenorphine is on the plan’s approved drug list. Individuals
who are not insured but who are neither indigent nor eligible for
Medicaid or Medicare will have to pay themselves for buprenorphine and
any treatment associated with it.
-top-
27. Where can I find out more information about buprenorphine
treatment for opioid addiction?
In addition to this Web site, you can visit the FDA’s
buprenorphine pages at
http://www.fda.gov/cder/drug/infopage/subutex_suboxone/default.htm,
and
the
manufacturer’s
Web
site
at
http://www.suboxone.com/.
Additionally, you can contact the SAMHSA Buprenorphine Information
Center by telephone, toll-free at 1-866-BUP-CSAT (1-866-287-2728),
or by e-mail at
info@buprenorphine.samhsa.gov.
-top-
28. As a physician employed by the Federal Government (Veterans
Administration, Indian Health Service, Federal Department of
Corrections, etc.) practicing in a Federal Government
installation, am I eligible for a DATA 2000 waiver?
Yes. Physicians employed by an agency of the Federal Government are
eligible for DATA 2000 waivers. In order to be eligible for a waiver
under DATA 2000, a physician must have a valid, individually assigned
DEA registration number (in addition to a license to practice medicine
and the credentialing/training discussed elsewhere). A physician who
is directly employed by the Federal Government may obtain a DEA
number, free of charge, without being licensed in the State where the
Federal facility is located (the physician must have a valid State
license in one of the 50 States, the District of Columbia, Virgin
Islands, or Puerto Rico). In order to receive a DEA number under this
program, each physician must complete a DEA registration application
that includes the physicians official business address and the name
and phone number of the certifying official who can verify the
physicians eligibility for this program. This DEA registration number
may only be used for practice within the Federal Government
installation and may not be used for practice outside this setting.
-top-
29. Can physicians begin immediately treating patients if they
have checked “Immediate” on the waiver notification
form?
A place to check “Immediate” is included on the form
to address a provision in the Drug Addiction Treatment Act to
permit treatment while a notification is under review. Checking
“Immediate” is only one of three requirements that a
physician must meet in order to start a patient on treatment, and
treatment is limited to ONE patient per form submitted. (Each form
must have a different submission date.) The three requirements are
that, first, the physician must “in good faith” meet
the criteria for obtaining a waiver (i.e., valid medical license,
valid DEA registration, credentialing, or 8 hours of qualifying
training). Second, the physician must check “Immediate”
on the waiver. Third, the physician must contact the Buprenorphine
Information Center at 1-866-BUP-CSAT to verify that the
notification form has been received and to notify CSAT of his/her
intent to begin treating ONE patient.
Since the physician will not have the unique identifying number,
pharmacists may question prescriptions received under this provision.
Pharmacists may contact the Buprenorphine Information Center if
additional information is needed.
-top-
30. Are there exceptions when Subutex® and Suboxone® may be
administered by a practitioner without the DATA 2000
waiver?
Under the Narcotic Addiction Treatment Act of 1974, all
practitioners who use narcotic drugs for treating opiate addiction
must obtain a separate registration under 21 U.S.C. Section
823(g)(1) or a DATA 2000 Waiver under 21 U.S.C. Section 823(g)(2).
However, according to the Drug Enforcement Administration (DEA),
an exception to the registration requirement, known as the
"three-day rule" (Title 21, Code of Federal Regulations,
Part 1306.07(b)), allows a practitioner who is not separately
registered as a narcotic treatment program or certified as a
“waivered DATA 2000 physician,” to administer (but not
prescribe) narcotic drugs to a patient for the purpose of
relieving acute withdrawal symptoms while arranging for the
patient’s referral for treatment, under the following
conditions: 1) not more than one day’s medication may be
administered or given to a patient at one time; 2) this treatment
may not be carried out for more than 72 hours; and 3) this 72-hour
period cannot be renewed or extended.
The intent of 21 CFR 1306.07(b) is to provide practitioner
flexibility in emergency situations where he or she may be
confronted with a patient undergoing withdrawal. In such
emergencies, it is impractical to require practitioners to obtain
a separate registration. The 72-hour exception offers an opioid
dependent individual relief from experiencing acute withdrawal
symptoms, while the physician arranges placement in a
maintenance/detoxification treatment program. This provision was
established to augment, not to circumvent, the separate
registration requirement. The three-day (72-hour) emergency
exception cannot be renewed or extended. Because this is a Drug
Enforcement Administration (DEA) rule, for further details consult
DEA. This information may be found at
http://www.deadiversion.usdoj.gov/drugreg/faq.htm.
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