VASAM Comments on Proposed Buprenorphine Treatment Regulations

On December 13, the Virginia Society of Addiction Medicine (VASAM) sent a comment letter to the Virginia Board of Medicine about their recent proposal to update the buprenorphine treatment regulations. In the letter, VASAM praised the board of medicine for improving upon previous version of the regulations, while also highlighting further areas for revision.

Specifically, VASAM highlighted three areas for revision based upon the most recent proposal. First, VASAM urged the Board to revise strict requirements for psychosocial treatment as a condition of receiving medications for opioid use disorder (MOUD). While psychosocial treatment is an important part of treatment and should be encouraged, VASAM expressed concerns that strict requirements as a condition of treatment may serve as a barrier to treatment in rural and underserved areas. Further, the proposal still requires documentation for prescribing buprenorphine dosages above 24 mg per day. VASAM urged the board to remove this requirement as it fails to meet the demands of providing treatment in the age of the fentanyl crisis. Finally, the proposal keeps in place a prohibition on providing buprenorphine treatment to adolescents under the age of 16 years old. VASAM noted that this provision is overly restrictive and prevents practitioners from providing individualized care to younger patients.

Read the letter here.