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For Patients
For Physicians
- 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)?
- 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?
- 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?
- I am a waived physician, and I've moved my practice location since receiving my waiver. Do I need to notify SAMHSA or DEA of my new practice address?
- 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?
- I've 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?
- Are there specific Federal record keeping requirements for office-based opioid therapy?
- Does DATA 2000 limit the number of patients who may be treated for opioid addiction at any one time by a physician group practice?
- Is there a limit on the number of patients a practitioner may treat with buprenorphine at any one time?
- 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?
- Can the medical personnel in correctional facilities dispense (or administer) buprenorphine to incarcerated individuals?
- 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?
- May physicians in residency training programs obtain DATA waivers?
- 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?
- Can physicians begin immediately treating patients if they have checked "Immediate" on the waiver notification form?
- How do I increase my patient limits?
For Pharmacists
General Information
For Patients
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 Locator Web site.

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 Locator Web site.

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.

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 or not 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.

Will buprenorphine be available in treatment programs for indigent patients and
patients who don't 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 or
not that health center or hospital offers substance abuse treatment or
emergency care of addictions and whether or not 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 or not
pharmaceuticals are covered, whether or not there is a required co-payment, and
whether or not 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.

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.

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.

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.

For Physicians
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.

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.

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?
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. There is also a new on-line form for physicians to request changes to their contact information. Click
on Update Physician Contact Information and use the State Medical
License Number and DEA Registration Number that we currently have on file to locate and change your information.

I am a waived physician, and I've 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. Or you may use our new on-line form to submit changes to your contact information. Click
on Update Physician Contact Information and use the State Medical
License Number and DEA Registration Number that we currently have on file to locate and change your information.
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.

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.

I've 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).

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.

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.

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.

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.

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.

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
patient's addiction treatment provider, when possible, to obtain treatment history.

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.

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 physician's 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.

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.

How do I increase my patient limits?
To increase your patient limits, visit http://buprenorphine.smdi.com/federal.html.

For Pharmacists
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.

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.

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 practitioner's 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 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 SAMHSA by phone at 240-276-2716 or by
e-mail at Nicholas.Reuter@samhsa.hhs.gov.
Pharmacists should convey their DEA registration number with these requests.

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.

General Information
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.

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 physician's 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.

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.

Where can I get a copy of the Buprenorphine Clinical Practice
Guidelines?
Clinical Guidelines for the Use of Buprenorphine in the Treatment of
Opioid Addiction, Treatment
Improvement Protocol (TIP) 40, is available via SAMHSA's 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.

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.
What is buprenorphine's safety profile? Some sources indicate that the medications Suboxone® and Subutex® are safer and less abusable than methadone. Other information indicates that these medications have been associated with diversion, abuse, and overdose deaths, including over 100 associated deaths tied to Subutex® in France.
The Food and Drug Administration (FDA) approved the buprenorphine products Subutex® and Suboxone® in October 2002. At the same time, the Drug Enforcement Administration (DEA) placed buprenorphine in Schedule III of the Controlled Substances Act. Schedule III substances have a potential for abuse that is less than substances in Schedule II (methadone, morphine, oxycodone, hydrocodone, cocaine, etc.); however, the abuse of Schedule III substances may still lead to moderate or low physical dependence or high psychological dependence.
The use of Suboxone® and Subutex® has increased steadily since their introduction in early 2003. In 2007 alone, over 2 million prescriptions were issued to 300,000 patients. Almost 14,000 physicians have been authorized to prescribe buprenorphine for addiction treatment. When patients and physicians were surveyed by SAMHSA about the effectiveness of buprenorphine, they reported over 80% reductions in illicit opioid use, along with significant increases in employment, and other indices of recovery.
Suboxone® and Subutex® are also diverted and abused. A recent series of articles in the Baltimore Sun in late 2007 and early 2008 describe increasing levels of diversion and abuse in Baltimore itself, Maryland, Massachusetts, and other parts of the United States. Information from SAMHSA's Drug Abuse Warning Network (DAWN) indicates an increase in buprenorphine reports from hospital emergency departments over the last 3 years. Recent publications1-2 indicate a period of experimentation and increased reports of abuse to substance abuse treatment centers in the United States. Buprenorphine products are diverted, misused, and injected. In some cases, this misuse has been associated with overdose deaths.
There have been many references to the French buprenorphine experience. Subutex®, the only product marketed initially in that country, was subject to misuse and many overdose deaths when co-injected with benzodiazepines. In France, however, buprenorphine remains widely available. Physicians are not subject to mandatory training/qualifications as they are in the United States, nor are French physicians subject to patient limits, as in the United States. Pharmacies in France, however, do have additional responsibilities to limit dispensing and report misuse and diversion back to prescribing physicians.
In February 2008, SAMHSA convened a special summit on buprenorphine. The meeting examined the state of buprenorphine treatment and what steps could be considered to improve office-based opioid treatment with buprenorphine and to reduce the risk of diversion and abuse. Buprenorphine is an extremely valuable treatment medication with recognized potential for abuse and diversion.
1 Cicero, T. J., Surratt, H. L., & Inciardi, J. (2007). Use and misuse of buprenorphine in the management of opioid addiction. Journal of Opioid Management, 3(6), 302–308.
2 Cicero, T. J., Surratt, H., Inciardi, J. A., & Munoz, A. (2007). Relationship between therapeutic use and abuse of opioid analgesics in rural, suburban, and urban locations in the United States. Pharmacoepidemiology and Drug Safety, 16, 827–840.
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