The DEA, HHS, and DOJ have jointly issued a letter showing their support for safe and ready access to medications for opioid use disorder (MOUD), especially in rural or underserved areas. The letter acknowledges an increase in the number of practitioners who can prescribe Schedule III MOUD products such as buprenorphine combination products, and naloxone for patients with OUD. In recognizing that there have been recent increases in demand for certain Schedule III MOUD controlled substances, DEA, HHS, and DOJ say there may be a corresponding increase in prescriptions for these medications from medical providers.
The letter also states that distributors should examine quantitative thresholds they have established to ensure that individuals with OUD who need buprenorphine can access it without undue delay. In a related guidance document from January that the letter referenced, DEA stated that neither the Controlled Substance Act nor DEA regulations establish quantitative thresholds or place limits on the volume of controlled substances DEA registrants can order and dispense. The document also reminded all DEA registrants of the requirement to establish systems to identify and report suspicious orders of controlled substances to include MOUD. “DEA supports collaboration amongst all DEA registrants to ensure there is an adequate and uninterrupted supply of MOUD products when these products are appropriately prescribed,” the letter notes. “Distributors should carefully examine quantitative thresholds they have established to ensure that individuals with OUD who need buprenorphine are able to access it without undue delay.”