Friday, October 30, 2009

DEA On-Site Investigation of Suboxone Prescribing Physicians

I just got off the phone with a pleasant representative of DEA who fielded some of my questions about the (apparently) imminent site visits by DEA agents to... Actually, she never told me the purpose, but I suspect they intend to monitor compliance of doctors prescribing Suboxone and Subutex for opiate withdrawal and maintenance with the law: DATA 2000.

DEA may have started these visits, but I have found no reports. If anyone has experienced an on-site investigation, please describe the experience by commenting here.

Not knowing how such a visit will proceed my fantasies run wild, and I still have numerous questions about this potentially disruptive plan. Mostly the DEA representative referred me to the law which lists requirements regarding record keeping and the 30/100 patient limits. She told me the visit will be unannounced, and that if I am not there when the investigators arrive, they will probably return later. She said they would try to maintain a low profile, but did not directly address many of my questions:

Should we notify patients now to give them an opportunity to object? How long will it take? Suppose I have to leave before they finish? Will we be allowed to de-identify the records? If the investigators demand access to electronic records, do we have to let them use or access computers or hard drives? (She said they just need access.) What if my digital media contain records of patients not prescribed buprenorphine? (She said they will not want to see records of patients not prescribed buprenorphine.) What questions will be asked? If I refuse to answer questions or provide access when demanded, what will happen?

I did not ask why the DEA would want to investigate doctors like me who are treating opiate addiction rather than doctors who are prescribing the drugs that are killing our patients, like OxyContin and methadone. I admit to a cynical drift here, but could it be that we threaten their livelihood? Lots of addicts equals job security for DEA employees. And if we legalize pot...

DEA Audits: insensitivity and disrespect

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