Public Comments

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.

Excellent document! Just a few suggestions:
1. Suggest removing 50% dose increase as a red flag. As you outlined later in the paper, there are MANY MANY legitimate medical reasons for dose increases of this kind, particularly in the first few weeks of BUP therapy.
2. Under “Telehealth” section, I would specifically have one of the “supporting recomendations” be “Removing Provider-Patient Distance requirements.” You elaborate on this later, but since it is the number one reason pharmacists currently give for not filling BUP, I would specifically include it under “Supporting Recommendations” to be very clear
3. Under “Red flags/Green flags” section, I sugget making the point that NOT having a BUP prescription on file when checking PDMP should NOT be a red flag. I’ve had several pharmacists refuse to fill new start BUP patient scripts bc PDMP did not show it listed. This logic makes sense with stimulants, but not BUP.

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.