Patient cap being lifted?

Buprenorphine Post
Posts: 1404

Postby drpasser » Mon Sep 21, 2015 9:25 am

Very nice post, Dr. Stinson !

Posts: 16

Postby tstinson » Mon Sep 21, 2015 9:25 am

Although I can fathom additional regulations on expanded buprenorphine prescribing, those regulations should be clear and unambiguous. Simply requiring compliance with "good medical practice" according to several, and possibly shifting privately-written documents does not constitute legitimate rule-making. With this sort of imprecision in language, no doctor with the 200 patient waiver can be sure that his prescribing is unambigiously legal, no matter what he does. The genius of the original waiver program was its simplicity and clarity. This should be restored for the additional patient waiver.

Posts: 187

Postby Dave » Mon Sep 21, 2015 9:25 am

I have submitted my comment on the Federal Register objecting to the new restrictions on MAT providers****ociated with the 200 patient limit. There should be no more regulations on increasing the number of patients allowed. Any physician currently approved for MAT with buprenorphine should be allowed to increase the patient load. I hope more of us do the same.

Posts: 111

Postby fishdoc » Mon Sep 21, 2015 9:25 am

As the new board will certify only those holding another certification from a ABMS board, many presently ABOD certified physicians will lose certification and NOT be permitted the new 200 cap.

Posts: 32

Postby mattkeene » Mon Sep 21, 2015 9:25 am

I get profoundly furious when I read articles or policy proposals that vilify cash pay clinicians. I've been blessed in that I have not taken any insurance for General psychiatry in well over a decade. At this stage of my career, my only clinical practice is dedicated to 100 Bup/Nal patients. I commit all of my patient care to these 100 individuals and their families. I get to know them, their issues, and in doing so, believe I have a much better opportunity to avert diversion / abuse than most insurance based clinicians who have to knock out 25 to 30 patients per day just to keep the lights on. Furthermore, it is my own personal bias, but I think patients who have "some skin in the game" are much more motivated to take treatment seriously.

Take a look at what has taken place recently in Tennessee. For several months, the Medicaid population was given access to free treatment and free generic Suboxone. Not too long ago, there was a universal formulary change to switch those patients to Bunavail as it has less current street value and less likelihood for abuse. As it turns out, about 50% of those patients who were getting their medications for free, simply stopped coming back to the clinic. The****umption being that in these clinics, where everything is free and sometimes oversight is spotty, A significant amount of suboxone was getting diverted to the street.

I cannot fathom restricting doctors who choose not to except insurance. Somehow that seems to violate free trade laws and I can't see how that would hold up in court. Is anyone aware of any such situation where this standard has been successfully applied?

Posts: 49

Postby Bruni » Mon Sep 21, 2015 9:25 am

Originally posted by mattkeene
Is this trying to say that if you are a Doc who does not take insurance, you cannot get waivered to see 200??

I believe that is essentially what is being proposed here for the public to comment upon, although the wording is vague enough to allow that some types of services related to bupe, or services for some bupe patients, might not be covered by third party payors. It seems designed to invite a lot of vociferous comment, and might carry the connotation that pay-as-you-go invites more diversion. It might also be prompted by the supposition that more pts will access treatment if it is less personally expensive.


Posts: 571

Postby kcairns » Mon Sep 21, 2015 9:25 am

Yes Matt..PS also they will spend all treatment $on burocracy for surveillance on us factless most diversion d/t no access to care

Posts: 571

Postby kcairns » Mon Sep 21, 2015 9:25 am

Mattkeene sure does...PS they will be spending most of treatment money setting up surveillance bureaucracy on us factless most bup diversion d/t no access to treatment.. PT on my waiting list just texted it's easier to get bup on street than get in w a doc

Posts: 104

Postby jmosby1469 » Mon Sep 21, 2015 9:25 am

"...has the ABILITY to accept..." (emphasis mine, of course)

Posts: 198

Postby NoDrugs4u » Mon Sep 21, 2015 9:25 am

From the March 14th press release by the ABAM and ABMS:

"Osteopathic and Canadian physicians will be eligible if they hold a current ABMS (Allopathic) primary certificate.
Addiction medicine is a multispecialty subspecialty of the American Osteopathic A,ssociation (AOA). However, neither an initial certification exam nor a recertification exam is currently available."

Previously, DO's could sit for the ABAM Exam, but since the ABAM has joined the ABMS there is now no way for DO boarded physicians to be certified in Addiction Medicine. Sad.

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