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Removal Of Data Waiver (X-Waiver) Requirement 

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POSTED IN: 2023 Quarter 2, EM Pulse - The Official Newsletter of MOCEP,

On December 29, 2022, the Consolidated Appropriations Act of 2023 enacted a new one-time, eight-hour training requirement for all Drug Enforcement Administration (DEA)-registered practitioners on the treatment and management of patients with opioid or other substance use disorders. The removal of this federal requirement also removes other associated regulations such as discipline restrictions, patient limits, and certifications related to provision of counseling – representing a significant change to practice.

Appropriate training in substance use disorders is urgent, enabling practitioners to screen more widely, treat pain appropriately, prevent substance misuse, and engage people in life-saving interventions. Although repealing the X-waiver was a top legislative priority, stakeholders convinced Congress that additional education was also necessary to promote best practices in the treatment of OUD and SUD more generally and to encourage more practitioners to prescribe buprenorphine.

Beginning on June 27, 2023, practitioners will be required to check a box on their online DEA registration form—regardless of whether a registrant is completing their initial registration application or renewing their registration—affirming that they have completed the new training requirement. This is an honor system. Documentation of training will not be required for the registration.

SAMHSA has released recommendations and the DEA has issued specific guidance on how practitioners can meet this requirement. The elements that SAMHSA recommends provide a basic overview of SUD identification, management and evidence-based care, as well as pain management.

There are other important considerations for this training that will make it easier for practitioners to complete:

  • Exemptions: Those who are board-certified in addiction medicine or addiction psychiatry from the American Board of Medical Specialties, American Board of Addiction Medicine, or the American Osteopathic Association are exempt from the requirement. In addition, practitioners who graduated within five years and in good standing from a medical, advanced practice nursing, or physician assistant school in the United States that included successful completion of an opioid or other substance use disorder curriculum of at least 8 hours are also exempt.
  • Previous X-Waiver training: Those of you who did 8 hours of classroom training to receive an X-waiver have already met the new educational requirement.
  • Previous Training: If you received any other training related to the treatment of patients with OUD or SUD that counts as well – the training is retrospective and could have occurred any time in the past.
  • Multiple Training Sessions: You don’t have to sit through one 8-hour session—the requirement can be satisfied through cumulative CME hours.
  • Training Flexibility: Trainings can occur in a variety of formats, including classroom settings, seminars at professional society meetings, or virtual offerings.

If you don’t qualify for any of the exemptions or haven’t received previous training, the Missouri Telehealth Network – University of Missouri via their Show-Me ECHO (Extension for Community Healthcare Outcomes) platform, are offering Missouri practitioners free training opportunities to complete the required 8-hours of training.

Attendance in certain Show-Me ECHO programs will fulfill this 8-hour training requirement.  Participation in the Opioid Use Disorder ECHO, Pain Management ECHO, or the Mothers, Infants, and NAS (Neonatal Alcohol Syndrome) ECHO will satisfy the DEA guidelines. Additionally, practitioners who have previously attended any of these specific ECHO sessions can count prior trainings towards the 8-hour requirement.  

OUD ECHO Link: https://showmeecho.org/clinics/opioid-use-disorder/

Pain Management ECHO Link: https://showmeecho.org/clinics/pain-management/

Mothers, Infants, & NAS ECHO Link: https://showmeecho.org/clinics/nas/

Healthcare professionals are encouraged to register for the next free ECHO session at showmeech.org. For further questions or clarification, please contact [email protected]

A special thanks to our friends at the Missouri Telehealth Network – University of Missouri for providing this free training infrastructure for Missouri practitioners.