Buprenorphine Waiver Training for APRNs
APNA and PCSS-MAT will be jointly providing, at no cost, the 24 hours of training required for nurses and physician assistants to obtain waivers to prescribe buprenorphine in the treatment of opioid use disorder. This page will include links to the free buprenorphine waiver training for APRNs once the process has been finalized. In the meantime, please see the below information and fill out this form to receive email updates.
(February 21, 2017) Here are updates to the three aspects of the buprenorphine waiver process for APRNs: the required 24 hours of education, the process for issuing buprenorphine waivers, and the regulations for implementing the CARA 2016 legislation.
- Educational Content for Required Training
APNA is working with our partners at PCSS-MAT to finalize the updated content and optimize it for continuing nursing education contact hours. We anticipate that the program will be ready in the near future, but no sooner than March 1st.
- OMB Approval of Buprenorphine Waiver Issuance Process
From SAMHSA Website as of February 17, 2017:
NPs and PAs who have completed the 24 hours of required training may seek to obtain a DATA 2000-waiver for up to 30 patients may apply by completing a hardcopy of the Notification of Intent (NOI) (DOC | 64 KB) and sending to email@example.com, along with copies of their training certificate(s). Starting February 27, 2017 SAMHSA will only accept electronic submissions of the NOI. These waiver applications are forwarded to the DEA, which will assign the NP or PA a special identification number. DEA regulations require this number to be included on all buprenorphine prescriptions for opioid dependency treatment, along with the NP’s or PA’s regular DEA registration number. SAMHSA shall review waiver applications within 45 days of receipt. If approved, NPs and PAs will receive a letter via email that confirms their waiver and includes their prescribing identification number.
- HHS Regulation to Implement CARA 2016
Finally, even when the OMB process to issue the buprenorphine waivers is in place, without regulation from the Department of Health and Human Services to implement the CARA legislation, you will not be able to prescribe. Again, when these regulations will be put into place is not something which we can predict.
(January 30, 2017) The Comprehensive Addiction and Recovery Act, signed into law on July 22, 2016, expanded the privilege of prescribing buprenorphine in office-based settings to qualifying advanced practice nurses (APRNs) and physician assistants (PAs) through October 1, 2021. In order to qualify for prescribing waivers, these providers must complete several steps, beginning with 24 hours of approved training.
In order for APRNs and PAs to obtain the waivers to prescribe buprenorphine, as authorized in the 2016 CARA, the US Office of Management and Budget (OMB) must approve the ability for NPs and PAs to complete a waiver notification form and receive a special identification number from the DEA, which is still in progress. Therefore waivers cannot actually be dispensed yet.
This is all subject to a regulation which must be written by the Secretary of the Department of Health and Human Services (see below language from the bill). Additionally there is a question of whether these regulations fall under the regulatory freeze memo signed by President Trump on January 20, 2017 (see excerpt below). It is important to have a complete understanding of the requirements prior to drawing any conclusions.
Excerpt from CARA:
Not later than 18 months after the date of enactment of this Act, the Attorney General and the Secretary of Health and Human Services, as appropriate, shall update regulations regarding practitioners described in subsection (a)(3)(B)(vii) (as amended by this section) to include nurse practitioners and physician assistants to ensure the quality of patient care and prevent diversion. (View full text here)
Excerpt from Presidential Regulatory Freeze Memo:
With respect to regulations that have been published in the [Federal Register] but have not taken effect, as permitted by applicable law, temporarily postpone their effective date for 60 days from the date of this memorandum, subject to the exceptions described in paragraph 1, for the purpose of reviewing questions of fact, law, and policy they raise. Where appropriate and as permitted by applicable law, you should consider proposing for notice and comment a rule to delay the effective date for regulations beyond that 60 day period. In cases where the effective date has been delayed in order to review questions of fact, law, or policy, you should consider potentially proposing further notice-and-comment rulemaking. (View full text here)