TITLE: Increasing Access to Medications for Opioid Use Disorder

WHEREAS, opioid use disorder (OUD) continues to grow to epidemic proportions in the United States, with an estimated 3 million people suffering from OUD in 2021;1 and

WHEREAS, also in 2021, nearly 108,000 people died from drug overdoses, with approximately 81,000 of those deaths involving a prescription or illicit opioid;2 and

WHEREAS, treatment with medication for OUD (MOUD) is widely acknowledged as being an effective treatment method for those with OUD; and

WHEREAS, buprenorphine has been successfully used to treat OUD by suppressing withdrawal symptoms, reducing cravings, re-establishing normal brain function, and preventing relapse; and

WHEREAS, on December 29, 2022, with the signing of the Consolidated Appropriations Act of 2023 (the Act), also known as the Omnibus bill, Congress eliminated the DATA-Waiver Program; and

WHEREAS, US Drug Enforcement Administration (DEA) posted a letter on the agency’s website stating that “all DEA registrants should be aware of the following:3

  • A DATA-Waiver registration is no longer required to treat patients with buprenorphine for opioid use disorder.
  • Going forward, all prescriptions for buprenorphine only require a standard DEA registration number. The previously used DATA-Waiver registration numbers are no longer needed for any prescription.
  • There are no longer any limits or patient caps on the number of patients a prescriber may treat for opioid use disorder with buprenorphine.
  • The Act does not impact existing state laws or regulations that may be applicable”; and

WHEREAS, the Substance Abuse and Mental Health Services Administration and DEA are actively working on implementation of a separate provision of the Act related to training requirements for DEA registration, which becomes effective in June 2023; and

WHEREAS, states can increase patient access to buprenorphine by allowing pharmacists to prescribe buprenorphine through independent authority, collaborative practice agreements, or statewide protocols; and

WHEREAS, pharmacists who are permitted by their state to prescribe4 controlled substances (CS) can register for a DEA registration number. Currently, there are 10 states that allow pharmacists to prescribe CS, and nine of those states allow pharmacists to prescribe CS in the community pharmacy setting;5 and

WHEREAS, many individuals suffering with OUD must also confront stigma associated with treating OUD, which may limit access; and

WHEREAS, challenges with patient access to buprenorphine treatment also result from a pharmacy’s request to purchase the medication being denied due to a potentially low threshold number when buprenorphine is reported by wholesale distributors to DEA through the Suspicious Orders Report System (SORS) when it is perceived that a pharmacy has placed a suspicious order;

THEREFORE BE IT RESOLVED that NABP collaborate with states to expand patient access to buprenorphine by developing model language that allows pharmacists to prescribe buprenorphine through independent authority, collaborative practice agreement, or statewide protocol; and

BE IT FURTHER RESOLVED that NABP collaborate with DEA and other applicable government agencies and professional associations to address stigma and other barriers to increase patient access to buprenorphine.

(Resolution passed at the 119th Annual Meeting in Nashville, TN.)

1Azadfard M, Huecker MR, Leaming JM. Opioid Addiction. [Updated 2022 Apr 7]. In: StatPearls [Internet]. Treasure Island (FL): StatPearls Publishing; 2022 Jan-. Available from: Accessed January 13, 2023.

2 Accessed January 13, 2023

3 Accessed January 13, 2023.

4“Prescribing” includes independent prescribing, prescribing through collaborative practice agreements with physicians and other authorized practitioners, and prescribing through state-wide protocol or as provided by state law.

5 Accessed on January 13, 2023.