As a busy Addiction Psychiatrist in the NOVA area, I am strongly in support of this proposed change. I've personally had 5 patients under the age of 15 with opioid use disorder die of opioid overdose in the past 2 years. This would not have happenned if physicians were allowed to prescribe Suboxone to those under 15. Let's update the regulations and save more of our childrens' lives. 

-Lauren Grawert, MD

I've had several friends under the age of 16 die of opioid overdoses over the past few years in Virginia. Suboxone would have saved their lives. Please make these changes to protect future Virginia teens. 

-Jackson G

I’m strongly in support of making these changes.

As a healthcare professional and advocate for evidence-based addiction treatment, I strongly support the petition to amend these regulations governing the prescribing of buprenorphine (Suboxone). The proposed changes would reduce unnecessary barriers to care and better align clinical practice with current scientific understanding of opioid use disorder (OUD). These changes are practical, patient-centered, and supported by leading medical organizations. I urge the Board to adopt them in the interest of saving lives and improving access to timely, individualized care. 

Carrie Grassi, MSN, ANP, CARN-AP

I’m strongly in favor of the proposed changes! In makes sense and provides better patient care! Thank you!

These changes will save lives. 

I strongly support the prescribing of buprenorphine (Suboxone) to patients age 16 and under.

As a psychiatrist that treats addictions, Buprenorphine is life saving, and we need to consider allowing it to those under the age of 16. There are real instances of opioid overdose and there are dangrously few options for middle and high school age adolescents who are very much at high risk given limited resources and lack of knowledge of how deadly these substances can be. We also need to think about the dosing of this not all people metabolize the same and the dose restrictions of 24mg may need to be reconsidered.  I strongly support making these changes.

I find it interesting and saddening that addiction indiscriminately affects all demographics and that we see children younger and younger losing their lives to substance use disorder, yet proven treatments are reserved for those above the age of 16. I firmly believe this should change. 

I've worked in the addiction field for 12 years and bring my own lived experience with opioid use disorder to the work I do every day. I’ve seen firsthand how critical timely access to treatment can be, especially for young people.

I fully support the proposed changes to the regulations governing the prescribing of buprenorphine (Suboxone). These updates would remove outdated barriers, align treatment practices with current medical evidence, and expand access to life-saving care for those who need it most, including adolescents.

This change isn’t just about policy, it’s about people. It’s about families. And it’s about protecting our children. I urge the Board to adopt these changes in the interest of saving lives and providing compassionate, evidence-based care to all who need it, regardless of age.

I support this life changing decision to make access easier

I am in strong support of making these changes. 

I as a practicing Psychiatrist, very strongly support for these children on opiates to receive Suboxone , helping save children’s lives and for them to help enjoy their daily living life very well . To save these children is very important, since children are a backbone for our country . So please help them , help them providing them with Suboxone, they deserve for the opiates treatment . 

As President of the Virginia Chapter of the American Society of Addiction Medicine (VASAM), I strongly endorse the evidence-based proposal to allow buprenorphine prescribing to minors under the age of 16 and remove burdensome documentation requirements to prescribe buprenorphine at daily doses higher than 24 mg. 

People are dying. Make changes fast!

This is urgent.  People need help faster.

People need affordable and quick options -- current system too slow to help.

I am strongly in support of these proposed changes which will undoubtedly save lives.

We need immediate, compassionate emergency care, now!

We need a better way to get people emergency treatment ASAP -- yes to updating the outdated way.

One life lost is a thousand too many. Let's hasten accessibility.

Strongly support changes in favor of helping more people get access to emergency care!

Too much is at stake not to make emergency care user friendly.

People in these circumstances need viable resources to emergency treatments.

Reference comment subject. 

I primarily work with young adults. I’m noticing a trend of kids earlier and earlier using substances such as cocaine and fentanyl. Having access to MAT is crucial for all patients seeking support. The goal is helping clients get in the door, and with substances literally killing people at a rapid pace we need policies like this to change in order to mitigate. 

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.  

Firmly advocate for expanding access to emergency care! 

The proposed regulatory changes are life saving. I am highly supportive of these changes. 

As a Psychiatrist, I've personally had several teen (15 year olds) patients experience serious opioid overdoses. They clinically need to be prescribed Suboxone, but I am unable to do so in Virginia until this regulation is changed. Additionally, prescribing Suboxone doses of 24 mg and above is now routine practice (not the exception to the rule) with stronger synthetic opioids. Additional documentation requirements is unnecessary, burdenson, and a barrier to care for busy physicians. 

Please make both of these proposed evidence based changes to the regulations. 

Respectfully, 

Jon Snipes, MD 

Psychiatrist 

I am at a loss for why Virginia believes that children cannot become addicted to opioids. The notion that people under the age of 16 cannot suffer from the same addictions as someone over the age of 16 is starry-eyed and ignores the reality of the epidemic we are currently facing with opioids. If I'm being entirely honest, I believe the only reason Buprenorphine is restricted from this population is due to a biased phobia against products like Suboxone. Some medical professionals don't agree with the concept of how this medicine works, thus they try to slip in restrictions to vulnerable populations. But this phobia ignores the science and stats behind the medicine. Buprenorphine saves lives. 

Children can become addicted to opioids. Why would we prevent a life-saving drug from being used on a child who is addicted to opioids? I cannot think of a single reason why this restriction would exist, and after reviewing the other comments, it's clear that no one else can think of a reason. A doctor should not have to risk their license to provide the appropriate medical treatment to a child. The current restrictions are wildly outdated, and they are an affront to the Hippocratic Oath.

Drugs are killing our youth- and some are asking for treatment. Our providers should not have to choose between saving their client or losing their license because of antiquated regulations. Lower the age for people to receive buprenorphine so lives can start being transformed and saved. 

Please allow doctors to prescribe this life saving medication to our young people.  

Getting rid of the X waiver was the first step in making buprenorphine available now get rid of the age restriction.  We need to save lives!

I am an adult living in Virginia. I strongly support the petition as published. 

I am in favor of approving buprenorphine for teenagers with SUD.

My son died by suicide while going through heroin withdrawal in 2015. He was just 20 years old. I saw then how difficult it was for 15-25 year olds to stay in recovery, how few skills they had at that point in their lives.  

In conversations I had with Dr. Peter Coleman, a respected recovery specialist now retired, he shared that while he didn’t often prescribe buprenorphine long-term for adults, he made an exception for adolescents. Because the teenage brain is still developing, and teens often lack the maturity and life experience to fully engage in recovery, he saw long-term buprenorphine as a lifeline at least until they had more maturity. This was to keep them alive until they had time to grow, stabilize, and build the skills needed for a sustained recovery effort and program. 

Lapses in recovery for young people can be not only discouraging and costly, but deadly. Medication-assisted treatment, including longer-term use of buprenorphine, can save the lives of teenagers.  

Teens must talk with their parents as to the danger of experimenting with drugs, whether in pill form, or any other form.   This conversation should be ongoing.

Middle and High School students need the same medical support as others being impacted by the opioid epidemic.  Please make needed changes ASAP.

First responders know the impact of emergency care to save lives of people old and young, regardless of age.  Let's update emergency medical treatment so that all can be protected.

Medical professionals across the board are weary from the news of death from opioid overdoses, so it is time to make affordable care available to the people who need it -- quick access.  We don't even have enough people trained in the U.S. to get care to everyone as it is.  Telemedicine is the way to go.  Age is not the issue -- death is the issue.

Even one teenage death from a person too young to officially qualify for this medicine in Virginia is unacceptable.  The current descriptions for who can receive care are antiquated.  Let's fix this now! Please.  

It takes great determination to get the nerve and willpower to overcome addiction, and this is something that few middle schools or young high schoolers have.  Please revise the regulations to support those too young to go it alone, without medicine.

There's not one reason why younger persons cannot have the same medical support as those who are considered adults.  If our society is in such a bind that younger Americans can get the drugs that are killing them, then it is our moral obligation to put the medicine in their reach to overcome such a travesty.  Please change the regulations ... soon!

With a society in crisis as drugs spiked with deadly consequences kill our children, we need greater access to emergency care for all.  Make changes to accommodate the emergency. 

We need current access to reflect the crisis at hand.  Please update regulations to reflect the depth of trouble that people who are addicted are in.  Nobody chose to be an addict.  People of all ages need a better, quicker, emergency support system.

The problem we face today is much broader and monstrous than the place our society was in when these regulations were enacted.  We need greater access to people who can help -- but there are not enough medical professionals out there to allow all who need it to get help, not to mention the cost of medical care.  Please make this care available to a broader section of society to lessen the burden on those who show up when it is too late.

Yes we need the changes.  Everyone I speak to is worried about the situation and thinks it cannot get any worse, but it can.  Upgrade and widen the circle of who can receive care. We all need to know that getting help is for everyone... old, young, smart, not so smart, just everyone.

I'm in favor of these changes

I am in favor.

We cannot ignore the necessity prescribe to individual needs.