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The American Hospital Association (AHA) recently sent a letter to the Drug Enforcement Administration (DEA) urging the agency to advance its proposed rules on the Special Registration for Telemedicine under the Ryan Haight Act.
The Ryan Haight Act, passed in 2008, aims to prevent the abuse and misuse of controlled substances, including prescription drugs, through the Internet. The act requires that practitioners obtain a special registration from the DEA to prescribe controlled substances to patients over the Internet.
Telemedicine has seen significant growth in recent years, with more and more doctors and hospitals offering virtual consultations to patients. However, the Ryan Haight Act restrictions have hindered further development in the field. The AHA’s letter to the DEA highlights the need for updated regulations that support the use of telemedicine and allow doctors to provide the best possible care to their patients.
The AHA believes that the proposed Special Registration for Telemedicine, which would allow doctors to prescribe controlled substances remotely, is crucial in advancing telemedicine and improving patient access to care. In their letter, the AHA stated that “the Special Registration for Telemedicine would allow patients to receive care from the comfort of their own home, reducing the need for unnecessary in-person visits and improving access to care in underserved areas.”
The DEA has yet to respond to the AHA’s letter, but the agency has indicated that it is working on finalizing the proposed rules for the Special Registration for Telemedicine.
AHA Stresses the Importance of Updating Ryan Haight Act Telemedicine Regulations
The AHA’s letter emphasized telemedicine’s importance in increasing patient care access, particularly in rural and underserved areas. Telemedicine can also help to improve the efficiency and effectiveness of healthcare delivery by allowing practitioners to consult with patients remotely and providing patients with access to specialists who may not be available in their local area.
The AHA also emphasized the importance of Ryan Haight Act telemedicine in addressing the opioid crisis, stating that “telemedicine can play a critical role in providing care for patients with substance use disorders and can help reduce the number of opioid-related deaths.”
The AHA noted that the DEA’s proposed rules on the Special Registration for Telemedicine are consistent with the agency’s goal of preventing the abuse and misuse of controlled substances while supporting the growth of telemedicine and its potential benefits for patients.
AHA Asks DEA for Interim Plan to Support Telemedicine Under Ryan Haight Act Following Pandemic
In its recent letter to the DEA, the AHA expressed not only support for the agency’s proposed rules on the Special Registration for Telemedicine but also requested an interim plan to support the continuity of care between the expiration of the COVID-19 Public Health Emergency (PHE) and the implementation of the final rules.
The AHA noted that the COVID-19 PHE had expanded telemedicine services, allowing practitioners to prescribe controlled substances remotely without requiring an in-person exam. However, the PHE is set to expire at the end of 2021, and the AHA is concerned about the potential disruption to patient care if the special registration for telemedicine is not implemented by that time.
In their letter, the AHA requested that the DEA provide an interim plan to ensure the continuity of care for patients receiving telemedicine services. This could include extending the COVID-19 PHE or implementing temporary measures to allow for the continuation of telemedicine services until the final rules are in place.
The AHA’s request for an interim plan highlights the importance of ensuring a smooth transition to implementing the final rules to avoid disrupting patient care.
The AHA has suggested that components of the interim plan could include policies such as:
- Allowing for the continuation of the temporary waiver of the face-to-face requirement for controlled substances.
- Providing guidance to healthcare providers on how to transition back to in-person visits while maintaining the safety of patients and providers.
- Establishing clear and concise communication channels to ensure that all stakeholders are informed of any changes to telemedicine policies.

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