SSN Public Comment

Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have Not Had a Prior In-Person Medical Evaluation

Policy field

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University of Alabama at Birmingham

Below is an excerpt from a public comment written with Adam J. Gordon, Ajay Manhapra, Leah J. Leisch,​​​​​​​ and Sally Satel, submitted to the Drug Enforcement Administration in regard to the regulation "Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have Not Had a Prior In-Person Medical Evaluation" on March 31st, 2023. 

My colleagues and I are long committed to serving patients with pain, medication dependence, substance misuse, substance use disorder, and – often – disadvantaged social situations. My colleagues are internal medicine and addiction medicine physicians, academic scholars, and patient advocates. As a primary drafter, I have board certifications in internal medicine (American Board of Internal Medicine) and addiction medicine (American Board of Preventive Medicine). I have a 27-year history of frontline care for vulnerable populations, most notably homeless and formerly homeless individuals who live in urban and rural settings, including Veterans. My research publications include consideration of prescription opioid misuse, addiction treatment, challenges of care delivery for poverty populations, and challenges in caring for patients with long-term pain. None of us have ties to the pharmaceutical industry or opioid litigation.