As Medical Director of the Fairfax-Falls Church Community Services Board and past president of the Virginia Society of Addiction Medicine, I urge the Board of Medicine to amend 18VAC85-21-160 to allow buprenorphine prescribing for youth under 16 when clinically appropriate.

We have treated youth under 16 who have experienced multiple overdoses. The current restriction denies them access to a proven, evidence-based treatment that could save lives. Buprenorphine is safe and effective in preventing relapse and overdose, and providers must be able to weigh its use based on clinical need.

I also support removing the requirement for special documentation above 24mg/day and remove the counseling referral mandate in 18VAC85-21-150. Treatment decisions should not face unnecessary administrative burdens that delays care. Please update state regulations to align treatment with the current medical evidence related to effective opioid use disorder treatment.