Make your voice heard! Comment on the DEA telehealth proposal today
The DEA is evaluating a proposal that puts additional limitations on the ways telemedicine professionals can prescribe stimulants to patients, but it's not too late to speak up! Submit your comment by March 18.
Step 1: Choose any statistic from the menu below.
Step 2: Add a sentence in your own words so your comment doesn't unfairly get flagged as a repeat.
Step 3: Post your comment on the Regulations.gov website using this link.
Example: “I'm worried about this proposal because it will make it harder for people with ADHD to access stimulants. People with ADHD who don’t take medications are 67% more likely to get in a car crash. For the safety of all Americans, please don’t make stimulant prescriptions more complicated.”.
Driving
Unmedicated ADHDers…
…react 9.1% slower to surprise events
…are 67% more likely to have a collision
when compared to ADHDers who are appropriately medicated.
Substance Use Disorder
Unmedicated ADHDers…
…are 35% more likely to abuse drugs or become addicted
…are 50% more likely to overdose
when compared to ADHDers who are appropriately medicated.
Notably, studies show that ADHD medication is not associated with a higher risk of substance abuse for ADHDers and decreases risk of substance abuse the longer it is taken.
Disease Risk
Unmedicated ADHDers…
…are 52% more likely to test positive for COVID
…are 41% more likely to contract an STD
…are 3x more likely to develop dementia
when compared to ADHDers who are appropriately medicated.
Prison
Unmedicated ADHD prisoners…
…are twice as likely to reoffend
when compared to appropriately medicated ADHD offenders.
Notably, between 25 and 40 percent of prison inmates have ADHD, most of whom are undiagnosed.
Hospitalization and death
Unmedicated ADHDers…
…have a 19% higher overall risk of death
…are 50% more likely to die from accidental poisoning if they are male
… die 11 to 13 years earlier
when compared to ADHDers who are appropriately medicated.
FAQ
What is this proposal?
The Drug Enforcement Administration in the United States is currently evaluating new changes to the way telehealth providers are able to prescribe medication.
This is an attempt to add clarity and regulation after many pre-existing rules for telehealth established by the Ryan Haight Act in 2008 were temporarily suspended during COVID.
This is a broad proposal, with a mix of good and bad components.
Which parts of this proposal are good?
One of the positive changes would allow telehealth providers to prescribe buprenorphine without seeing the patient in person, first. This is a medication that helps to treat opioid addiction.
Another positive aspect of this proposal would loosen restrictions for telehealth Veteran's Affairs doctors to see their patients solely through telehealth
Which parts of this proposal are bad?
Practitioners would need to be located in the same state as the patient at the time of the encounter when issuing a Schedule II controlled substance prescription.
This means our choice in doctor is greatly limited, and we cannot continue care if we move to a new state.
An estimated 55% of U.S. counties don't have a local psychiatrist, and 70% lack a child and adolescent psychiatrist. Patients in these areas rely on telehealth visits for their medical care.
The average monthly number of Schedule II controlled substances prescribed via telemedicine would need to be limited to less than 50% of the practitioner’s total Schedule II prescriptions (including both telemedicine prescriptions and non-telemedicine prescriptions).
This creates a perverse incentive for doctors to prescribe less effective or inappropriate medications if they are nearing the 50% quota.
It also means doctors may choose to not accept us and decline to take on new ADHD patients, which creates a dangerous situation where ADHDers lack access to medical care.
Medical treatment should be based on the unique circumstances of each patient and not based on arbitrary quotas.
How does this affect people with ADHD?
The most common ADHD medications are stimulants (Adderall/amphetamine and Ritalin/methylphenidate). Stimulants are Schedule II medications, which puts them in the same regulatory category as cocaine, meth, fentanyl, and opiates.
As discussed above, this new proposal would limit telehealth providers in their ability to prescribe Schedule II medications. That means these restrictions would apply to anyone treating their ADHD with stimulants.
Stimulants are considered the gold standard of treatment for ADHD. They work for an astounding 70 to 80 percent of people with ADHD. Non stimulant alternatives are nowhere near as effective.
What should I do?
Follow our instructions above to leave your thoughts on regulations.gov, where policymakers will read through them.
Encourage your friends, family, and doctors to leave a comment as well.
How can I learn more?
You can check out the It's Just AuDHD podcast where we discuss this proposal and our concerns.
You can read this explanation from the American Psychiatric Association, where they state “Erecting these overly restrictive barriers to virtual care will limit our ability to serve our patients. It may force clinicians to limit their practice to only those who have the means and ability to travel to in-person care.”