Tanvir Shagar, Executive Director
Mar 4, 2023
The Drug Enforcement Administration (DEA) is seeking to reenact pre-pandemic regulations which professionals across the nation suspect will result in an unnecessary compromise in the quality and efficacy of mental healthcare. The federal government has requested commentary on the DEA's current transition plan; over 700 mental health provider organizations have since written to the DEA to express relevant concerns. The following is a copy of the letter which was submitted by Adapt Psychiatry as part of this public effort to conserve safe, effective, and high quality virtual psychiatric care. To the Drug Enforcement Administration (DEA),
We at Adapt Psychiatry, a healthcare provider that specializes in treating patients with mental health and substance use disorders, are writing to express our concern about the possible reinstatement of in-person prescribing requirements for controlled substances. While we understand the DEA's goal of preventing the diversion of controlled substances and ensuring appropriate care for patients, we believe that in-person prescribing requirements could create significant barriers to care for our patients. Many of our patients have limited access to transportation or live in remote areas, making it difficult for them to attend in-person visits. Furthermore, we believe that the federal government's current transition plan, which includes the reinstatement of in-person prescribing requirements, will not only cause harm but will cost lives.
We urge you to prioritize the creation of a special registry for telehealth practitioners to prescribe controlled substances through telehealth visits, as per the SUPPORT Act of 2008. This would allow us to continue providing safe and effective care to our patients, while still adhering to appropriate prescribing practices. Recent studies have shown that telehealth is a safe and effective way to provide mental health care, and patients with opioid use disorder who received telehealth services had a lower risk of overdosing.
As a healthcare provider, our primary concern is the safety and wellbeing of our patients. We want to work with the DEA to ensure that patients receive the best possible care while also addressing concerns about the diversion of controlled substances. We believe that a special registry for telehealth practitioners would be a better approach than reinstating in-person prescribing requirements. This would allow clinicians to use their judgement in determining when an in-person evaluation is most appropriate.
Thank you for your attention to this matter. We look forward to working with the DEA to find a solution that prioritizes patient care and safety.
Tanvir H. Shagar, Executive Director
www.Regulations.gov comment tracker ID leu-0122-53dg