At a very high level, the rule proposes to specify the circumstances under which telehealth practitioners may prescribe controlled medications in the following ways:
- Restrict any practitioner practicing telemedicine to offering no more than a 30-day supply of a controlled substance to a patient. After 30 days, an in-person visit is required, by either that practitioner or an eligible referring practitioner.
- Prohibit the prescribing of Schedule IIN substances without an in-person evaluation/referral. Limit the prescription of schedule III-V controlled medications to the 30-days above.
- There will be a 180-day grace period for patient-provider relationships established during the public health emergency.
The below letter is intended to emphasize and call attention to how these restrictions will hinder mental health treatment. It also calls for a separate mental health flexibility.
Please note that this high-level group letter is intended to augment the individual responses of many organizations, which may have additional requests or go into more detail. PDF of letter.
