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in case anyone is not aware, the application to increase the limit to 275 is now available at the link in Dr Passer's original post above. SAMMSHA has 45 days to determine approval once the application has been submitted. as expected, you do have to stipulate that you have 24/7 back-up, that you will have a procedure in place if you are no longer able to prescribe for 275, that you can provide or refer to counseling, that you have a diversion control plan and that you will collect and report "data" annually.
I attended the ASAM webinar on this- it is not going to be as easy to go from 100 to 275 as it was to go from 30-100. Yes the requirements aren't that bad, BUT there are also some stipulations that everyone, whether in a "qualified" practice setting or not, will have to follow. I actually submitted a post outlining the requirements but it has not been approved by the moderators and appears to have disappeared so it is possible that I totally misrepresented the rules as i understood them- suffice it to say that the application which was supposed to be available today 8/8 is still not available according to the samsha website- but most likely will include attestation of such things as the ability to track and report "data" as well as refer to or provide counseling and case management and have 24/7 back-up and follow a "diversion control plan. these stipulations are rather blithely referred to above in Dr Passer's post with the wording "The final rule also includes requirements to ensure that patients receive the full array of services that comprise evidence-based MAT and minimize the risk that the medications provided for treatment are misused or diverted." today is the deadline to comment on exactly what the data reporting requirements will be- see my earlier post for the link to do that.....
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