Lexology January 22, 2025
On January 17, 2025, the US Drug Enforcement Administration (DEA) and the US Department of Health and Human Services (HHS) published two rules regarding telemedicine prescribing of controlled substances: a proposed rule implementing the DEA special registration as an exception to the Ryan Haight Act’s in-person medical evaluation requirement (Special Registration Proposed Rule) and a final rule on telemedicine prescribing of buprenorphine (Buprenorphine Final Rule) (together, the Rules).
Each of the Rules establish pathways for prescribing certain controlled substances via telemedicine without a prior in-person examination beyond the scheduled COVID-19 extended prescribing flexibilities, set to expire December 31, 2025.
Importantly, the Special Registration Proposed Rule outlines DEA’s proposed three categories of special registrations, each offering an exception to the in-person...
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