Written By: Janie Ratliff-Sweeney

Those practitioners who are approved to treat up to 275 patients addicted to opioids with suboxone must take heed of the new reporting rule that goes into effect October 27, 2016.  The new reporting rule requires doctors who are authorized to treat the higher patient limit of over 100 (but not in excess of 275 patients) with suboxone to submit to the Substance Abuse and Mental Health Services Administration (“SAMHSA”) on an annual basis certain information related to being approved to treat the higher number of patients.

A summary of the annual reporting requirements is as follows:

1. The annual report must be submitted within 30 days following the anniversary date of the practitioner's request for patient limit increase approval.
2. The annual report must contain the following information:
3. The annual caseload of patients by month;
4. Number of patients provided behavioral health services and referred to behavioral health services; and,
5. Features of the practitioner's diversion control plan.

The rule also permits SAMHSA to check reports it receives from the practitioners prescribing under the higher patient limit against other data sources to determine whether discrepancies exist and, if discrepancies are found, the practitioner may be required to submit additional documentation.

Lastly, failure to submit the reports (or deficiencies in the reports submitted) may be deemed a failure to satisfy the requirements for the patient limit increase and may subsequently result in SAMHSA's approval for that practitioner to treat an increased number of patients to be withdrawn.

Janie is a member at Hemmer DeFrank Wessels. She has helped numerous health care providers in Kentucky and Ohio stay compliant with new and existing laws and regulations. You can reach Janie at [email protected].