One of the biggest challenges posed by the Covid-19 epidemic is the effect it has had on accessibility to healthcare providers. To ensure that patients can still meet with medical professionals while remaining socially distanced, the use of telemedicine has surged.
Patients looking for treatment for substance use disorders, however, face an additional challenge. The prescription of medication-assisted treatments (MAT) such as buprenorphine, suboxone, and methadone is subject to specific federal and state regulations.
This is seen in the Ryan Haight Online Pharmacy Consumer Protection Act of 2008. This legislation was created to regulate the sale of online prescriptions. It mandates professionals conduct an in-person evaluation before prescribing regulated drugs like buprenorphine and methadone.
This means that as it stands, the use of telemedicine for addiction treatment is severely limited.
What is Telemedicine?
Telemedicine refers to the use of modern telecommunications technology to care for patients. Medical professionals can evaluate, diagnose, and treat patients from a distance through the use of HIPAA-compliant video conferencing tools.
The American Medical Association (AMA) has declared telemedicine as crucial to managing the Covid-19 pandemic. They note that telehealth services allow patients with chronic conditions, worry-free access to medical services.
Benefits of Using Telehealth During the COVID-19 Pandemic
The American Association of Addiction Medication has outlined various benefits of using telehealth services for addiction treatment during the pandemic. These include:
- Allowing quarantined practitioners to continue treating patients remotely.
- Allowing providers to provide treatment to patients who are most vulnerable to COVID-19.
- Allowing more communities to access treatment services.
- Limiting exposure to infection for both vulnerable patients and healthcare workers.
- Promoting physical distancing and reducing viral spread.
- Reducing the risk of spread in high-traffic areas such as doctors’ waiting rooms.
- Reducing the risk of patients participating in associated activities that increase the risk of exposure to COVID-19. These include the use of public transportation when attending appointments.
Telemedicine in Addiction Treatment
The Ryan Haight Act of 2008 means that the use of telemedicine in addiction treatment is limited. In-person evaluation is a legally required component of treatment, especially for new patients.
At the same time, the COVID-19 pandemic has led to a surge in overdose deaths. According to the Substance Abuse and Mental Health Services Administration (SAMHSA), more than 20 million American adults currently suffer from a substance use disorder.
This number includes 2.5 million people suffering from opioid addiction and 18 million people with alcohol use disorder. The COVID-19 pandemic means the introduction of new stressors that puts them at increased risk of overdose.
To address these challenges, care providers are looking at telemedicine as a possible solution. This includes using telehealth addiction treatment programs that allow professionals to treat patients while maintaining social distancing guidelines.
To make this possible, over 80 organizations have signed a letter calling for the U.S. Drug Enforcement Agency (DEA) to create a special telemedicine registration. This registration would permit providers to prescribe controlled substances like buprenorphine and methadone remotely.
Organizations that have signed the letter include several telehealth providers and health systems. They also include the American Telemedicine Association, the American Association of Nurse Practitioners, and the American Psychiatric Association.
At the same time, the Telehealth Buprenorphine Consortium has called on policymakers to allow for treatment via telephone and other audio-only devices. The consortium consists of clinicians and public health experts.
This is aimed at combating the barrier that unequal broadband internet access poses to telemedicine treatments for addiction. The group is also calling for this allowance to be extended post the COVID-19 pandemic. It has called on it to be extended for the extent of the opioid emergency.
The proposed registration would come with some conditions. Providers will have to prove that there is a genuine need for them to take advantage of the special registration. They will also only be able to prescribe controlled medications to patients in the same state as which they are registered. Finally, they will have to follow all federal and state laws when treating patients.
The concept behind the registration was first proposed as part of the Ryan Haight Act of 2008. Though the Act mandates that professionals meet patients in-person before prescribing controlled medications, it also provided an allowance for the potential creation of a special registration.
The 2018 Substance Use Disorder Prevention the Promotes Opioid Recover and Treatment (SUPPORT) for Patients and Communities Act also has a similar provision.
It is these provisions that have led providers to campaign for the implementation of the special registration. This registration means that access to therapists and psychiatrists during the pandemic is more accessible. This is particularly important for patients with existing conditions that make them more susceptible to COVID-19.
Existing Guidelines for Telehealth, COVID-19, and Addiction Treatment
Aside from the proposed special registration, there have been some federal policy changes to make telemedicine more accessible for addiction treatment.
However, it should be noted that these are in place for the duration of the Covid-19 pandemic. The proposed special registration is meant to be a permanent one. The letter points out that while the signatories ‘appreciate these PHE-related changes, statute requires the implementation of a permanent regulation.’
Current federal policy changes for the duration of the pandemic include:
- Passing the Coronavirus Preparedness and Response Supplemental Appropriations Act and the Coronavirus Aid, Relief and Economic Security (CARES) Act. These open up more telehealth services to be eligible for reimbursement under Medicare.
- The removal of a Medicare requirement that mandates that patients be located in a clinic in order to receive telehealth services. Patients can now receive treatment and prescriptions over the phone or computer while in their own homes.
- The addition of an emergency exceptionto the Ryan Haight Act of 2008. The exception allows for providers to prescribe buprenorphine without an in-person evaluation of the patient. However, this exception does not cover methadone. In order to prescribe methadone, providers still need to evaluate patients in-person first.
- Relaxation of HIPAA restrictions to allow providers to meet with patients via videoconferencing platforms like Zoom, Skype, and FaceTime.
There have also been state-level relaxations for providers. Those relaxations differ from state to state.
The Need for a Permanent Special Registration
There have been relaxations to telemedicine guidelines for the duration of the COVID-19 pandemic. However, there is still an understandable need for a permanent special registration.
Even before the pandemic, the opioid crisis has been a major concern in the United States. According to the CDC, nearly 72,000 Americans died of an overdose in 2019. Other substance use disorders are of similar concern, with over 88,000 Americans dying per year as a result of excessive alcohol use.
A permanent special registration will ensure more patients have access to addiction treatment services. It will also make reaching out to patients in communities with limited in-person access to addiction treatment services easier.
References:
https://www.cdc.gov/mmwr/volumes/69/wr/mm6943a3.htm
https://www.ama-assn.org/practice-management/digital/ama-telehealth-quick-guide
https://www.nytimes.com/interactive/2020/07/15/upshot/drug-overdose-deaths.html
https://www.samhsa.gov/data/sites/default/files/report_2790/ShortReport-2790.html
https://blogs.cdc.gov/niosh-science-blog/2020/09/14/covid-19-and-oud/
https://brown.co1.qualtrics.com/jfe/form/SV_eqCFPf04BDYcrjL
https://www.samhsa.gov/sites/default/files/faqs-for-oud-prescribing-and-dispensing.pdf
https://www.cdc.gov/nchs/nvss/vsrr/drug-overdose-data.htm
https://www.niaaa.nih.gov/publications/brochures-and-fact-sheets/alcohol-facts-and-statistics
