Public Comments
The Pharmacy Access to Resources and Medication for Opioid Use Disorder Guideline
A public comment period was held from April 15 to May 31. These comments were analyzed thematically, and a panel of experts who were not involved in the initial guideline creation process convened to review the aggregated comments and discuss potential changes to the guideline document.
Public Comment Period: April 15 – May 31, 2024
Comments | Entry creation date |
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Many pharmacist have experienced abusive statements and threatening behavior from patients collecting their suboxone. Suboxone users tend to purchase small amounts (2-3 strips) at a time, due to cost. Pharmacy staff sees the Suboxone user more then the prescriber. Patients often exhibit signs of abuse and addiction during these encounters. Since the majority of pharmacist practice in corporate run environments that do not encourage boundaries for pharmacist, I suggest a behavior contract at the beginning of each relationship with a pharmacy. The behavior contract can provide an opportunity for the pharmacist to go over the requirements for a prescription, future roadblocks that could occur (prior authorization, wholesale limits, no refills etc). The pharmacist can explain what they are willing to do and what is the patient and prescriber’s responsibilities. If patients yell at staff, use inappropriate language, or request multiple early refills the patient will be referred back to the prescriber with a request to find another pharmacy. If you EMPOWER pharmacist to feel like they have a choice with the way they practice that honors THEIR needs as well as the patient, I believe the “buy-in” will be greater among said pharmacist. Lastly, I have grave concerns about the length of therapy on Suboxone. In my 6 years of community practice, I never witnessed a patient titrated off the drug. I would like to see this addressed. | April 17, 2024 at 7:45 am |
Excellent document! Just a few suggestions: | April 17, 2024 at 9:41 am |
I have been a licensed pharmacist for over 20 years. I believe that increasing access to OUD medications, specifically buprenorphine at the pharmacy level, will have a tremendous impact on getting individuals into treatment and recovery from OUD. Pharmacists should be permitted to prescribe and dispense buprenorphine, and should be compensated fairly for doing so. This is a critical public health matter that pharmacists are best positioned to address. Many individuals with OUD are not equipped with the resources to obtain access to MAT. This move would align with the DEA’s recent activity to increase access to buprenorphine and other medications to treat OUD. | April 18, 2024 at 3:33 pm |
To the Committee: As I already mentioned in this scenario, the first pharmacy “did not have the medication in stock”. We practice a harm reduction model whereby we don’t automatically discharge pain management patients for using illicit substances but instead work with them to obtain appropriate treatment. What we also do is offer them buprenorphine therapy for their pain. I had a new pain management patient who had a history of using cocaine and had been discharged from at least two other pain management practices. I attempted to order buprenorphine-naloxone tablets at a pharmacy in the patient’s county and I contacted a pharmacy in a chain grocery store to see if they had the medication in stock. The pharmacist informed me “we don’t do THAT here” i.e. stock buprenorphine-naloxone formulations. I inquired about other formulations and the indication was that this particular pharmacy wanted nothing to do with buprenorphine. It was again stigma, which is very hard to combat but I have several patients on Suboxone, Zubsolv and the generic equivalents for chronic pain. They are happier with this medication than conventional opioid analgesics because they experience better pain control and their dose remains stable. The physician who owns the practice is triple certified in anesthesia, interventional pain management and addiction medicine so I have expert consultation immediately available in addition to continually educating myself. I was encouraged to post these comments by a pharmacist but again my concerns are the delay of life-saving medication to patients particularly if they are in withdrawal and pharmacies being reluctant to stock buprenorphine products so they can avoid serving persons with SUDs. Thank you, Janet Beebe, DNP. ANP-BC, PMHNP | April 26, 2024 at 5:32 pm |
This is one of the best set of guidelines regarding buprenorphine that I’ve seen. Bravo! After 20 years of prescribing buprenorphine to patients, my patient population was made up of individuals who had been seeing me, on average, for 7 years and were quite stable. Most of them followed me when I moved my practice to RI from MA. But that set off alarms at pharmacies, and several cut my patients off because they were now “traveling” (albeit about 45 minutes) to see the doctor. That’s when the fact that they were paying cash (because they didn’t want employers finding out that they had addictive disease) hadn’t already gotten them in trouble at the pharmacy. I hope the pharmacists on Cape Cod read this closely! | April 29, 2024 at 11:34 am |
This is a very important document that will have a positive impact on evidence-based opioid use disorder treatment access. As a registered nurse at a telehealth opioid use disorder treatment organization, I can speak to the many barriers patients with OUD face when seeking treatment with buprenorphine and how this leads many patients to end their OUD care. One of the most frequent and demoralizing barriers I see patients with OUD experience is at the pharmacy level. It is not uncommon for patients with OUD to drop out of buprenorphine treatment because they are denied their prescription. Common reasons patients are denied their prescription include: 1) prescription is from a telehealth provider, 2) the patient lives far away from the pharmacy, 3) patient lives far away from provider, and 4) pharmacy not accepting new bupnorphine prescriptions due to fear of over-prescribing. I am glad to see the document address many of the aforementioned barriers. Notably, I am glad to see the document highlights that pharmacists should dispense buprenorphine prescriptions issued by telehealth providers. I would like to see additional context in this section around patients who live far from providers and when patients live far from the pharmacy. These situations often happen in telehealth; the lack of proximate OUD care is a big part of why patients seek care via telehealth. Thank you for this document! | May 9, 2024 at 12:40 pm |
Thank you for this opportunity to submit comments. Specific suggestions for Background section: Recommendation 2) Recommendation 4) Recommendation 5) Recommendations 6-10) Recommendations 11-15) Recommendation 16) Recommendation 17) | May 13, 2024 at 3:38 pm |
This is a very good article, well-reasoned. Our job as healthcare providers is to help our patients not put up roadblocks to their care. OUD patients will become “Dope Sick” without the medication and end up in the hospital, jail, or dead. This is a way to help your patients as long as they are doing the right thing, mutual respect. If they are caught selling or snorting in the parking lot, they need a in house treatment program. | May 14, 2024 at 6:54 am |
Thank you for this guideline to our pharmacy colleagues. Access to buprenorphine is much better than what it was years ago. I am an addiction medicine specialist certified by the ABPM. I treat opioid use disorder, chronic pain and opioid dependence, stimulant use disorder, benodiazepine use disorder, alcohol use disorder, cannabis and tobacco use disorders. I also treat co-occuring disorders as ADHD, anxiety, and depression. Some pharmacies refuse to fill my prescriptions when benzodiazepines or CNS stimulants are prescribed together with buprenorphine. I urge the board to review the current literature and guidelines in the field of addiction medicine for other substance use disorders than OUD and come up with guidelines for community pharmacists so that they are free and enpowered to fill legitimate prescriptions by trained addiction medicine physicians. Mark Norleans, MD, PhD, FASAM | May 15, 2024 at 9:55 pm |
As an owner and pharmacist, I understand the importance of carrying life enhancing medications, but current insurance practices are not sustainable for our business. The insurances pay me $20 for $60 worth of buprenorphine or buprenorphine/naloxone combo. Sometimes I’m able to get the “cheap” one from mckesson, but it’s often out of stock since everyone wants it. I have been losing hundreds of dollars filling this medication with insurnace but we are done doing that. I refused to fill one this week due to insurance reimbursement. I called the doctor and the patient but it took a week for the doctor to call me back. There’s needs to be a requirement for insurances to pay more than they currently are for these medicines or it will be a cash only prescription. Even for medicaid patients who already struggle with costs. | May 18, 2024 at 6:30 am |
Pharmacists are highly trained healthcare professionals with deep expertise in medications and their effects. Allowing pharmacists to initiate treatments for opioid use disorder (OUD) can significantly improve access to care, particularly in underserved communities where healthcare resources may be limited. Pharmacists can offer timely interventions, including medication-assisted treatments like buprenorphine, which have been shown to reduce opioid cravings and withdrawal symptoms, ultimately aiding in recovery and reducing the risk of overdose. Their accessibility and knowledge make them valuable allies in combating the opioid crisis, providing holistic care alongside other healthcare providers. A big missing piece is after-hours care from a lot of stake holders we have spoken to. Most practices are open from 9-5. A lot of these dire critical moments occur after hours. We can save a lot of lives. | May 18, 2024 at 12:19 pm |
There’s nothing in here about the Medicaid guidelines we’re all trying to follow. This basically deals with the Mono and Dual therapy. Certain Medicaid’s will not cover the monotherapy. Leaving only the dual therapy or the patient paying out of pocket due to a PA never rarely getting approved. Also on the patient side, there’s a lot more street value for the Monotherapy. Patients are consistently getting the doctor to document allergy to Naloxone on the script. This is always a red flag for us. From what I’m gathering the DEA is still looking at the Monotherapy a little differently than the dual. | May 20, 2024 at 2:54 pm |
Buprenorphine is a necessary medication in the treatment of Opioid Use Disorder. Many of our patients receiving buprenorphine are either uninsured or underinsured. Buprenorphine provides a more cost effective treatment. Alternative therapies can easily be over 300 to 400 dollars. Although buprenorphine may not be the most ideal medication option for OUD, I appreciate role that it plays in OUD treatment. | May 20, 2024 at 5:51 pm |
I believe these guidelines will be very beneficial to help improve access to providers for treatment and pharmacies that stock buprenorphine containing products. My pharmacy is located on the campus of a mental health and recovery facility and in a medical building that houses physicians that specialize in those areas. Being in the metro Atlanta area, there is an increased number of providers that treat OUD and we have patients that drive a significant distance to use one of these providers in our area and use us as their pharmacy because we keep generally keep these products in stock and we do not judge them for their past and need for a buprenorphine containing product. Our largest barrier is the limitations by our wholesaler on how much we may order at a time due to controlled substance ratios and quotas. We try to care for as many patients with OUD as possible, but often have to turn someone away due to the product being out of stock. We have relationships with these providers. We know them. We know their prescribing patterns and policies in place at their offices. Having to turn someone always makes me worry if they will relapse if they are unable to find a pharmacy that has it in stock and is willing to care for the patient. Hopefully this will help decrease the stigma around these products and improve access more locally for these patients. | May 21, 2024 at 12:01 pm |