Thursday, March 30, 2023

Proposed Regulation for Prescribing Controlled Substances via Telemedicine

RE: DEA NPRM (Document Citation 88 FR 12875) regarding telemedicine prescribing of controlled substances
Dear Administrator Milgram:

The Euthanasia Prevention Coalition-USA (EPC-USA) and the Catholic Medical Association (CMA) represents thousands of physicians, attorneys, nurses, health care professionals, disability rights advocates, and citizens across the country. Members of our organizations oppose assisted suicide and euthanasia, and support positive measures to improve the quality of life of Americans. We fully support your proposed requirement for in-person examination before a Schedule II controlled substance can be prescribed. The patient would be required to see the medical practitioner in person before receiving the prescription.

DEA regulations require registration in each state in which a prescriber is licensed. They do not authorize interstate practice without licensure. This is already the standard of care. Our members have licensure and controlled substance licenses in a variety of states, along with the applicable separate DEA registrations. It is critically important that the final rule prohibit the use of telemedicine to cross state lines by unlicensed and unregistered clinicians.

We support the proposed prohibition on telemedicine prescribing of Schedule II controlled substances without an in-person medical evaluation. In addition, the prescriber must be licensed to practice in, and follow the laws of, the State where the patient is located. Without those regulations, prescribers of potentially dangerous drugs would be able to act beyond the regulatory reach of a state medical board.

Colleen Barry
Chair, Euthanasia Prevention Coalition-USA

Craig Treptow, M.D.
President, Catholic Medical Association

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