Sunday, February 7, 2010

DEA Suboxone Audits: The Video

Continued from: DEA Suboxone Audit: Worst Experience of My Career as a Physician

Read the script below.




Hello. I’m the owner & editor of BehaveNet.com

Today I want to talk to you about an initiative by the Drug Enforcement Administration that threatens patient access to buprenorphine, also known by the Trade names Suboxone and Subutex.

These drugs were made available in the US, as an alternative to methadone, for treatment of addiction to heroin and pharmaceutical opiates like Oxycontin early in 2003.

Starting as early as the summer of 2009 DEA agents started making unannounced and unscheduled visits to physician practices to audit records related to prescribing and dispensing buprenorphine.

These audits needlessly disrupt medical practices, threaten patient privacy, and waste taxpayer money and the agents’ time which could be better devoted to investigating diversion and illegal prescribing of dangerous opiates like Oxycontin.

I don’t object to the audits themselves which may result in stopping inappropriate practices by some physicians.

But physicians qualified to treat addiction with buprenorphine know to expect the audits, so DEA will not likely catch anyone red handed. I have already heard stories of agents wasting their time – and taxpayer money.

In one case agents appeared at a doctor’s office 3 times when they could not perform the audit because the doctor was absent.

In another case agents appeared at a doctor’s office when a staff Halloween costume party was in full swing but the physician was absent. I can just imagine the agent’s response at the reception desk:

"No, this is not a costume. I really am a DEA agent."

Surely agents have better things to do with their time. And taxpayer money.

If you are a patient, even if you are not treated with buprenorphine, you may find yourself sharing your doctor’s waiting room with a DEA agent who lives or works in your community and may recognize you.

I wrote a letter to my local DEA field office offering a time when I would be available for my audit. No one even responded.

Doctors have to jump through too many hoops already to provide this life-saving treatment. The disruption of practices that results from unscheduled audits will discourage physicians from providing buprenorphine treatment, resulting in increased illicit drug use. Maybe it is not just a coincidence that this will also increase job security for DEA employees.

I hope you will join me in demanding that DEA immediately begin scheduling all buprenorphine audits. In protest I have also made a decision to stop accepting new patients for buprenorphine treatment in my practice until my audit is completed. I hope other physicians will do the same and let it be known.

Contact your elected representatives, local medical associations, your local DEA field office, the Substance Abuse and Mental Health Services Administration, Dr. Westley Clark at the Center for Substance Abuse Treatment and Gil Kerlikowske at the Office of National Drug Control Policy. The American Civil Liberties Union may also be interested in your privacy concerns.

Physicians can coordinate efforts at the CSAT buprenorphine forum and the Behavenet opinion blog. Just search for “DEA Suboxone audit.”

Thank you, and stay clean.

Agents in the Waiting Room: To Warn or Not

7 comments:

  1. Your article is very interesting. Thanks for being so informative. I really like you're writing style.

    Are Pain mgt Docs subject to the same type of unannounced audits? How often do Sub Docs get audited? I strongly agree with you in that it wastes everyone's time and is very counter productive.

    Keep spreading the word....Citizens need to know these things.

    Ex

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  2. Good question. I believe any doc with a special DEA number gets audited, but that would presumably not include any doc who prescribes the drug off label for pain.

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  3. Bruce S. Evans, LMFT, LPC, CSACFebruary 24, 2010 at 4:51 PM

    I am a therapist that works with suboxone prescribing MD."s and provides therapy services to theses patients. We are presently involved in one of these audits and I find it both intrusive and unproductive for these encounters to take place during patient hours. Although the agents are polite and friendly the subtext in the room is anxiety, and"what have we might have done wrong" The Docs I work with are excellent clinicians and are not "pill pushers", and once again we seem to be operating from a stance of fear that will surely drive clinicians away from substance abuse treatment with suboxone. DEA has better things to do than create anxiety by unannounced visits.BTW, I am leaving my name as I refuse to remain anonymous despite the "I gotcha climate" that exists in the field today. What a shame that more professionals won't step foward. The Japanese have a saying, "The nail that sticks out the longest gets pounded", however if enough nails stick out they will have to use a mighty big hammer!

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  4. Bruce: Thanks for your comment and your support. I also appreciate and admire your willingness to identify yourself.

    My attempts to remain anonymous grow not from the "I gotcha climate" but from my wish to not burden my own patients with my opinions, or the converse, to be able to speak freely without burdening my patients. I like that proverb. It really hits the nail on the head. So to speak.

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  5. I was recently audited and the audit is still not complete. The agents were in my office for 3 hours and then wanted two years worth of dispensation sheets and patient logs which I was told was not a HIPPA violation because it was the DEA. I did not realize that I had to keep sheets, except form 222 drugs for more than 2 years not to mention the amount of time needed to do this. I am the only Dr. in my practice and I only have one receptionist working for me. I truly felt like a criminal when all I intended to do when I got my Suboxone license was to help people. I have ALWAYS followed protocol in my office to a T as has my receptionist. They also checked my safe and did a pill count of everything in the safe including schedule 4 drugs. Has anyone else had this kind of experience? Please let me know. Should I consult a lawyer? Thank you!!!!

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  6. I just came across this while I have been franticly looking for a new Suboxone doctor for a couple weeks. I am shocked and saddened to hear that civilians such as yourself have taken such a heroic effort in your carrier to save lives and keep many of us who have unfortunately become dependent on opioid substances and have regained our lives and families through the help of Suboxone, and have been able to contribute back to society (as an elementary school teacher myself). The hardest part about all this is although I understand your frustration and outrage, refusing treatment of anymore patients until you are audited, really hurts the ones needing help the most. As mentioned, I have been seeking treatment without luck because of the long waiting lists. I am sorry that you have to be humiliated in such a manner, but do the ones who need help the most need to be hurt in the process too? I have no clue what you probably go through to help, and appreciate more than you can imagine, just wanted to point out the need for more doctors like yourself out there period without letting the DEA win in the meantime.

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  7. The best I can say is that my moratorium is long over, and now many of us can accept 100 patients. Sorry it's not helping. I assume you know about NAABT.org.
    Now, however, the state medical boards make it harder to provide bupe maintenance, for example Vermont: http://behavenet.com/blog/charging-chargers-vermont-medical-board
    More cause for hope: I am told that the bupe implant, which may get FDA approval this summer, will not count against the limits.

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