Simplify Controlled Substance Rx Training, AAFP Advises
(Editor’s note: The AAFP counted two wins on advocacy related to the Medication Access and Training Expansion Act since this story was published. The DEA said physicians will be able to attest that they have fulfilled training required by the MATE Act without submitting detailed paperwork. In addition, the Substance Abuse and Mental Health Services Administration updated curricular recommendations to say previous X-waiver and substance use disorder training hours will count toward new requirements. A new AAFP resource answers your questions about this policy change.)
March 24, 2023, News Staff — Upcoming training requirements for prescribing controlled substances should be carefully implemented to avoid disrupting patient care or creating unnecessary administrative tasks for physicians, the AAFP told the DEA and the Substance Abuse and Mental Health Services Administration this month.
The Academy gave the agencies detailed advice for implementing the Medication Access and Training Expansion Act in a way that acknowledges the extensive training many family physicians have already received. And physicians who might require more training should have a one-year grace period from when they seek to register or renew their DEA license to fulfill the new requirements so patients don’t lose access to care, the AAFP added in its March 20 letter.
The MATE Act, which Congress passed as part of the omnibus spending package in December, imposes a one-time eight-hour training requirement for physicians and other clinicians who register or renew a DEA license to prescribe controlled substances in schedules II, III, IV or V. This includes some medications not only for substance use disorder, but also for ADHD, coughs, palliative care and much more. The newly required trainings focus on safe prescribing and SUD screening and treatment.
Patients could be harmed if this wide-reaching requirement is imposed on such a short timeframe or without recognition of expertise that many family physicians have already attained, the Academy warned.
“Moreover, many family physicians in small, solo, or rural practices are the only source of health care for their community and for traditionally underserved populations,” the letter said. “These physicians especially need flexibility and clarity to meet these new requirements and prevent disruptions in their patients’ access to care.”
The AAFP laid out six steps to ease the burden of the new requirements for physicians and their patients:
Allow a Grace Period
Giving physicians a one-year grace period to meet the new requirements while maintaining their DEA license is necessary to protect patients from disruptions in care.
“Without further clarification about a year-long grace period, there is clear danger that many physicians’ registration would lapse and their patients would be left without access to medically necessary care,” the AAFP warned.
Reduce Paperwork
The Academy also advised the DEA to let physicians attest that they have fulfilled the training requirements without having to submit detailed paperwork.
“Primary care physicians are already overwhelmed with administrative tasks and regulatory requirements, which reduce the time a physician can spend caring for their patients,” the AAFP wrote. “Requiring additional reporting to comply with this provision would further burden family physicians and could result in care delays or disruptions for their patients.”
Accept Completed X-waiver Training
The AAFP successfully fought to eliminate the X-waiver requirement for physicians who prescribe buprenorphine for opioid use disorder, but more than 100,000 physicians and other clinicians have already earned the waiver — which required eight hours of training similar to what the MATE Act calls for.
The DEA and SAMHSA must clarify that previous X-waiver training fulfills the MATE Act training requirement, the AAFP said.
Recognize Recent Family Medicine Residency Training
All family physician residents receive SUD and safe prescribing training required by the Accreditation Council for Graduate Medical Education. This includes an average of about 33 hours of education on pain management topics as of 2018, as well as further training on screening, brief intervention, and treatment or referral for SUD.
“It would reduce confusion and burden on current and recent family medicine residents to clarify that they have already met the requirements of this new provision,” the AAFP said.
Recognize State-required Training
Many physicians already fully or partially completed training required by the MATE Act by meeting the requirements of their states.
“The AAFP urges the DEA to clearly stipulate that trainings completed to comply with existing state requirements will count toward completion of the MATE Act training requirements and work with states to provide clear guidance to physicians regarding how many additional hours of training are required,” the letter said.
Accept AAFP-certified CME
The MATE Act allows for the eight hours of training to come “through classroom situations, seminars at professional society meetings, communications or otherwise.” The AAFP acknowledged this flexibility but called for more clarity.
Specifically, qualifying training should include CME accredited by the AAFP, the letter said.
Limiting qualifying CME to only activities certified by the Accreditation Council for Continuing Medical Education would ignore “the high-quality training that maintains the most relevant SUD-related course materials for certain clinician types, in certain states, and/or for a physician’s specific patient population,” the AAFP said.
What’s Next?
The AAFP will offer members updates and resources to help implement MATE Act requirements once the agencies review the Academy’s advice and issue specific guidance. Watch AAFP News for the latest information.