I am an internist at a federally qualified health center and recently obtained DATA 2000 waivers and started treating opiate addicted patients with buprenorphine about 1 month ago. I have already had 2 who received their initial script to pick up at a pharmacy and bring back for observed induction, but they never came back. I have a mentor who told me that he has had this same experience and for that reason he obtained a small lock-box and keeps a small supply of buprenorphine tablets for immediate induction of new patients coming to the clinic in withdrawal.
I would like to do the same, but I am concerned about any rules or regulations I need to be aware of prior to doing this. I know that I need to keep it locked and keep a log of everything that I dispense. Is there anything else I need to do?
Also, on my Missouri BNDD renewal application they ask if I prescribe only or if I also dispense scheduled medications. If I am keeping a small supply of buprenorphine for induction purposes, should I put on my BNDD renewal application that I want to be licensed to dispense controlled substances as well? I do not intend to provide long term medication, only to have enough buprenorphine on hand for induction of patients in withdrawal. I am seeing 4 to 6 new patients per week right now, but will hit my 30 patient limit in the next few weeks.
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