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DEA Surveillance for buprenorphine/opiate combinations

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Some information from this article on the DEA surveillance efforts caught my eye.  In particular, the part where buprenorphine combined with opiates is targeted.  Presumably, the off-label use of buprenorphine in the sublingual formulations in combination with classical opioids is looked upon with suspicion.  For those of us who work in pain management and addiction medicine, where chronic pain and opioid use disorders are not mutually exclusive, one wonders what prescribing practices may raise red flags or even what is considered to be appropriate.  

  • Patients who are receiving MAT do have surgical procedures and often do suffer from chronic pain conditions.  If the Rx for MAT as well as acute or chronic pain comes from the same prescriber, does that raise a concern or is that preferable to multiple prescribers?
  • The lower-dose buprenorphine formulations are approved for use in pain.  Is the use of higher-dose sublingual forms of buprenorphine prohibited for use in chronic pain as a safer  long-acting opiate?  Or is just deemed suspicious?
  • What, exactly, makes combination prescribing of buprenorphine and traditional opioids suspicious?  Is it due to diversion risk or because patients who are on MAT shouldn't be taking other opioids?

From a regulatory standpoint, it seems that we are still stuck with the notion that patients must have chronic pain or addiction but not both.  Buprenorphine, then, either must be prescribed for chronic pain or addiction but not both or anything in-between.Pasted Graphic.pdf



The DEA’s desired ability to search controlled-substance prescriptions to this degree targets seemingly mundane behaviors—like the number of times a patient paid in cash for a Schedule II substance like Adderall or OxyContin, or the geographic distances between patients and their prescribers and pharmacies.

But it also subjects people prescribed medications for opioid use disorder (OUD) to even more surveillance than is currently the case. In particular, the Pharmacy Prescription Data system would allow the DEA to track patients by their “Number of Opiate and Buprenorphine combinations.”


Webster - Bup for Pain.pdf

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