On behalf of its opioid treatment program (OTP) provider members, RCPA submitted comments to the Independent Regulatory Review Commission (IRRC) in support of a final-omitted regulation that would allow an initial physical examination required for prescribing, administering, and dispensing controlled substances through an OTP to be conducted via telehealth under certain circumstances under Pa. 49 Code § 16.92.

This final-omitted regulation would enable the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to grant a statewide exception to 28 Pa. Code § 715.9(a)(4), which today requires Pennsylvania OTPs (called narcotic treatment programs in DDAP regulations) to conduct a face-to-face determination of whether an individual is currently physiologically dependent on an opioid.

IRRC will consider the final-omitted regulation at a public meeting on December 5.

In its comments, RCPA wrote:

“Enabling OTPs to conduct the initial examination required as part of induction into methadone or buprenorphine treatment through telehealth significantly improves and expedites patient access to the gold standard treatment for OUD without sacrificing quality or safety. In a treatment environment where finding qualified physicians, physician assistants and certified registered nurse practitioners is challenging, telehealth bridges a significant gap. Physicians would no longer need to be physically on site at the OTP where treatment is to take place to examine a patient as part of the induction process. Rather, from anywhere in the commonwealth, a physician can examine more patients, who can then begin treatment with medication faster at a facility near their home. In fact, with this final-omitted regulation, OTPs will have the ability to accommodate same-day or walk-in admissions instead of scheduling intake appointments days later.”

The final-omitted regulation, submitted by the Department of State, Bureau of Professional and Occupational Affairs, State Board of Medicine, along with comments in support from the Department of Drug and Alcohol Programs and RCPA, can be viewed on the IRRC website.