I support the petition to remove documentation requirements of the rationale for prescription of doses of buprenorphine which exceed 24 milligrams per day. We have seen in this era of high potency synthetic opioids that individuals clearly benefit from plasma concentrations of buprenorphine higher than what we are able to achieve with 24mg daily. We have long-term experience with this medication that reflects excellent safety profile. The higher plasma concentrations achieved with injectable buprenorphine as just as safe, and even more effective in reducing opioid agonist misuse. Individuals remain in treatment for sustained periods without developing tolerance for buprenorphine-naloxone. Most importantly, individuals who remain in treatment at therapeutic doses show success in recovery in well-rounded aspects of their lives.

I also support the petition to remove the provision of counseling services or referral for counseling services to all patients prescribed buprenorphine. I believe many individuals do benefit from licensed counseling services, however, not all want or need licensed counseling, and even those who gain benefit from those services will continue to benefit from medication treatment long after they have completed a typical duration of substance use related counseling. Counseling as a requirement in a program limits an individual’s ability to transition between providers, or to establish with a community provider that might be more accessible to them. Medications for opioid use disorder are so effective that any barriers to treatment for individuals motivated to take them should be carefully considered, and wherever possible removed.

Finally, I also believe the Board should also remove the restriction on age-limit for prescription of buprenorphine. While we would like to wish that substance use disorders would only occur to older individuals, that is not reality. Providers, and individuals who need treatment, need the best tools available for managing substance use disorders. Buprenorphine has proven to be incredibly effective and safe in individuals 16 and older. Providers and individuals in need of treatment should be able to weigh the risks and benefits of that treatment in individual cases, not be prohibited from considering it by the Board.