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    March 31, 2023 

    The Honorable Anne Milgram
    United States Drug Enforcement Administration
    800 K Street NW Suite 500
    Washington, D.C. 20001

    RE: Telemedicine prescribing of controlled substances when the practitioner and the patient have not had a prior in-person medical evaluation (RIN: 1117-AB40)

    Administrator Milgram:

    Thank you for the opportunity to comment on the Drug Enforcement Administration rule on telemedicine prescribing of controlled substances. We are anxious to ensure continued access to care for patients with telehealth-based provider relationships that include a controlled substance, and appreciate finally having a proposal. However, as written we are concerned that it will substantially curtail access for patients.

    As you know, the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 provides the Administrator, in conjunction with the Secretary of HHS with the authority to promulgate rules under which practitioners may prescribe controlled medications. It also permits the Attorney General to issue to a practitioner a special registration to engage in the practice of telemedicine if the practitioner demonstrates a legitimate need for the special registration and meets other DEA requirements.1 The NPRM does not outline a registration process. In fact, it ventures into treatment decisions that should be up to a patient and their provider.


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