Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing Prescribing of Opioids and Buprenorphine [18 VAC 85 ‑ 21]
Action Amendment of opioid and buprenorphine prescribing regulations following updated federal guidance
Stage Fast-Track
Comment Period Ended on 12/18/2024
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11/21/24  3:30 pm
Commenter: Kanchan Clark MD

buprenorphine regulations
 

Currently the code 18 Va. Admin Code 85-21-150 states “doses exceeding 24 mg of buprenorphine per day shall not be prescribed.” Doses as high as 32 mg have been needed to manage more severe withdrawl symptoms, cravings, and tolerance associated with fentanyl use.

Code 18 Va. Admin Code 85-21-160 says “patients younger than the age of 16 years shall not be prescribed buprenorphine for addiction treatment.” We have a serious youth opiate problem and programs are using it in youth, even though it is off-label. Much of child psychiatry is off label per FDA guidelines, but not in violation of the state code.

I believe it is part of Chapter 21 of Agency 85, which is the Board of Medicine in Title 18 of the Virginia Administrative Code, so perhaps the Board of Medicine could modify it to match the current best practice.

 

§ 54.1-2928.2. says “Board to adopt regulations related to prescribing of opioids and buprenorphine.

Looking at the dates these were written, it appears 54.1-2928.2 was written in 2017.

Codes 18VAC85-21-150 and 160 were written in 2018, perhaps to be in compliance with 54.1-2928.2.

CommentID: 228909