This will remove a significant barrier for many patients. However, six months’ worth of medication will not be enough for patients without in-person access to a provider, and telemedicine itself is not feasible for many of the patients at risk. 

Buprenorphine, commonly referred to by the brand name Suboxone, is one of the three Food and Drug Administration-approved medications for opioid use disorder (MOUD), and one of the two shown to reduce overdose risk. Under the Ryan Haight Online Pharmacy Consumer Protection Act of 2008, buprenorphine could previously be prescribed only after an in-person visit. During the pandemic lockdowns, as patients and providers increasingly turned to telehealth, it became evident that waiving the requirement was feasible and badly needed. In 2023, the number of buprenorphine prescriptions dispensed in the United States—more than 15 million each year—was about the same as it was pre-pandemic, despite the obvious need for expanded access.

For this reason, during the pandemic buprenorphine was temporarily allowed to be prescribed via telemedicine. The DEA final rule making it permanent was originally scheduled to take effect February 18, but that changed after President Donald Trump was inaugurated and put a freeze on federal rulemaking procedures. On February 14, it was formally pushed back until March 21.

The temporary rule still won’t expire until the end of 2025 (by which time it was assumed that many pandemic-era barriers would have eased) so it remains unaffected. The public can still submit comment on the rule until 11:59 pm on March 18. 

Federally Qualified Health Centers are uniquely positioned to address the overdose crisis, but are limited by chronic understaffing and insufficient resources.

Nearly 20 percent of adults diagnosed with OUD are uninsured, and of that group 25 percent are living in poverty. The expanded telemedicine rules represent real progress, but cannot replace in-person care and cannot be implemented in isolation. 

On January 16, the same day the rulemaking was announced, JAMA Network Open published a study showing that in 2023, community-based health clinics serving at-risk populations were providing MOUD to fewer than one in four eligible patients. Of the three FDA-approved MOUD, methadone remains confined to the clinic system and naltrexone is associated with increased overdose risk, so there is a pressing need to increase access to buprenorphine. 

More than 32 million people in the US rely on Federally Qualified Health Centers (FQHC), commonly known as community health centers, for their medical care. FQHC are primarily located in medically underserved communities and serve patients regardless of immigration status, insurance coverage or ability to pay.

These centers are uniquely positioned to address the overdose crisis, but are limited by chronic understaffing and insufficient resources, and by the fact that many medical providers never receive training that covers equitable care for patients with substance use disorder.

The JAMA study highlights how our most vulnerable populations, who already face multiple barriers to health care, are being left behind even as we expand use of telemedicine. Among other particularly troubling disparities, the study found that non-white FQHC patients and those experiencing homelessness were the least likely to access MOUD.

Investment in FQHC would not only improve in-person care, but also improve telemedicine.

To truly address the overdose crisis, policymakers must pair telemedicine expansion with robust investment in FQHC. This means:

First, a significant increase in funding for FQHC providers to receive training and education specific to buprenorphine. Not just prescribing it, but the full spectrum of OUD care, from initial screening to long-term recovery maintenance.

Second, an expansion of other on-site behavioral health services. Many people who use FQHC services, particularly those with more complex medical needs, require in-person care coordination that is only feasible to access if it’s located within their community. 

These investments would not only improve in-person delivery, but also improve telemedicine. After all, adequate staffing levels and more comprehensive care being delivered in-person would have a positive effect on the virtual services, too.

More than 1,000,000 people in the US have died of overdose since the CDC began tracking those deaths in 1999. The crisis demands a dual approach—expanding telemedicine access while simultaneously strengthening our ground-level treatment infrastructure. Only by investing in both can we bring lifesaving treatment within reach of all patients who want it, not just the patients with the resources to access it easily. Otherwise we risk perpetuating a two-tiered system that expands telemedicine access for some, while leaving others further behind.

Image (cropped) via Everett, Washington

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