The Alliance appreciates the DEA’s forward movement on telemedicine prescribing of controlled substances policy. However, the Alliance continues to be concerned to see language in the proposed rulemaking mandating in-person visits as this is not an appropriate guardrail for a telehealth service. Similarly, restricting the geography in which telemedicine can be offered undermines the value of creating virtual access for those patients who need it most. For these reasons, the Alliance encourages the Trump Administration to withdraw this proposal and work with stakeholders to ensure continued access to comprehensive medical care through telehealth, including when a controlled substance is required.

In our below comments, we discuss how the telemedicine access created on a temporary basis by DEA increased access to care, offer specific feedback on the proposed rule, and request the DEA to work with Congress and stakeholders to advance a safe and permanent pathway to ensure continued access to comprehensive medical care through telehealth, including when a controlled substance is required. We also request that the DEA consider holding another listening session to hear from health care practitioners, experts, advocates, patients, and other members of the public, including the Alliance, on the prescribing controlled substances via telemedicine.

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