TALKING POINTS WITH LEGISLATORS IN MA About Proposed Buprenorphine
Regulations
1. Epidemiology:
a. 950% increase in abuse of oxycontin and other opioids in MA in the
last 10 years
b. 2% of the U.S. dependent on opioids
c. Doubling of heroin use in the past three years since the reformulation
of Oxycontin
d. Rate of death from opioid overdose has now exceeded rates of death
from automobile accidents
e. True public health crisis is not the illegal procurement of
Buprenorphine, but the extremely high risk of death from continued
opioid abuse
f. >3500 people in MA died between the 2002 and 2007 secondary to
opioid overdose, (approximately 2 people per day), and during that
same time 70 MA residents died in Afghanistan
2. Goals of DATA 2000
a. Increase access to care in patient communities
b. Have physicians be able to provide access to this care in their offices
and not relegate care to “clinics” akin to methadone programs which
unfortunately carry stigma and promulgate the separation of
addiction treatment from traditional medical treatment
c. Buprenorphine treatment is already one of the most highly regulated
prescribed opioids, DEA agents interview each physician prescribing
buprenorphine every three years to ensure conformation with the law
and it’s requirements
d. Doctors are already limited to 30, or 100 patient limits
e. There are no regulatory oversight limitations or DEA visits imposed
upon physicians who regularly prescribe opioids for pain
management
3. MASAM, AMA, APA, ASAM goals
a. We share the wish to see patients receive very high quality care
b. Diversion prevention is extremely important and can be improved via
education of physicians who prescribe
c. REMS strategies have been implemented and have successfully
educated physicians to improve appropriate prescribing of all opioid
therapies for pain and diminish diversion
d. A similar REMS strategy for buprenorphine prescribing physicians
can effectively diminish risk of diversion, while not limiting access to
this life saving medication
e. Addiction specialty physicians can work closely with the DPH and
with the DEA to develop an educational strategy to diminish diversion
and to get patients into high quality care
4. Risks of S-1926 include:
a. Diminishing the number of available programs, offices, physicians
who prescribe Buprenorphine
b. Current regulatory environment has resulted in many community
health centers in the state electing NOT to incorporate treatment into
their programs.
c. Additional regulatory compliance/oversight is likely to further
diminish access