Citing the need to expand access to buprenorphine for opioid use disorder (OUD) treatment, the U.S. Department of Health and Human Services recently issued new guidelines that provide an alternative notification of intent (NOI) process for eligible practitioners who seek to treat up to 30 OUD patients with buprenorphine.

In general, the new Practice Guidelines for the Administration of Buprenorphine for Treating Opioid Use Disorder exempt eligible practitioners from the standard statutory certification requirements related to training, counseling and other ancillary services (i.e., psychosocial services). Eligible practitioners interested in utilizing the exemption provided in the new guidelines must submit and receive advance approval of their alternative NOI from the Substance Abuse and Mental Health Services Administration (SAMHSA).

Additional information about the new guidelines, including information on how to submit the alternative NOI, is available on SAMHSA’s website:

• SAMHSA, Become a Buprenorphine Waivered Practitioner
• SAMHSA, FAQs About the New Buprenorphine Practice Guidelines (The first question includes information about how to apply for the alternative NOI.)
• SAMHSA, Buprenorphine Quick Start Guide
• SAMHSA, Record Keeping Requirements

Eligible physicians should also be mindful of state law relevant to this topic. In 2019, the Indiana General Assembly passed a law that put several requirements in place for office-based opioid treatment. That law, Indiana Code section 12-23-20-1, et seq., addresses various aspects of office-based opioid treatment, including treatment agreements and toxicology screening.

Under the law, the Medical Licensing Board of Indiana, in consultation with the Indiana Department of Health and the Family and Social Services Administration, is required to adopt rules or protocols for the provision of office-based opioid treatment. Those rules are still forthcoming.