“Substantial shortcomings” – HLC Urges DEA Collaboration with Healthcare Stakeholders to Revise Special Registrations for Telemedicine Proposed Rule
The Healthcare Leadership Council (HLC), an association of CEOs and C-suite executives from all sectors of healthcare, sent a letter in response to the Drug Enforcement Administration (DEA) proposed rule, “Special Registrations for Telemedicine and Limited State Telemedicine Registrations.”
As champions of telehealth’s role in expanding patient access to healthcare, HLC expressed support for the DEA’s efforts to establish a “long-overdue” special registration framework.
However, the letter notes several provisions of concern, including:
- The 50% prescribing limitation is arbitrary and operationally impracticable;
- Excluding primary care and general medicine practitioners ignores patient needs;
- Geographic restrictions on Schedule II prescribing undermine telemedicine access for patients;
- Nationwide Prescription Drug Monitoring Program check requirement is operationally unworkable; and
- The registration requirement for telemedicine platforms and direct-to-consumer companies, even when they do not prescribe or dispense medication, is unnecessary and burdensome.
“With the current pandemic-era flexibilities set to expire at year end, we encourage DEA to either revisit the current extension or work quickly to promulgate a final rule that reflects stakeholder feedback and can be implemented by all impacted entities. Patients and providers should not lose access to legitimate pathways for evidence-based, clinically appropriate care.” said HLC’s Executive Vice President and Chief Policy Officer Katie Mahoney. “Given its substantial shortcomings, we urge the DEA to collaborate with entities to develop a more effective, patient-centered framework that preserves access while preventing diversion.”
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