Answer: As a condition of registration, the new training requirement in section 1263(a) of the CAA went into effect on June 27, 2023, and applies to all qualified practitioners when they apply for a new registration or a renewal of registration on or after that date. DEA-registered practitioners that are not solely veterinarians must, upon initial application or application for renewal of a registration (beginning on June 27, 2023), attest to meeting one of three standards for training set forth in the CAA:

1. The applicant is a physician holding a board certification in addiction psychiatry or addiction medicine from the American Board of Medical Specialties, a board certification from the American Board of Addiction Medicine, or a board certification in addiction medicine from the American Osteopathic Association.
2. The applicant is a physician who graduated in good standing from an accredited school of allopathic medicine, osteopathic medicine, dental surgery, or dental medicine in the United States during the past 5 years and successfully completed a comprehensive allopathic or osteopathic medicine curriculum or accredited medical residency or dental surgery or dental medicine curriculum that included not less than 8 hours of training on treating and managing patients with opioid or other substance use disorders, including the appropriate clinical use of all medications approved by the FDA for treatment of substance use disorder or the safe pharmacological management of dental pain and screening, brief intervention, and referral for appropriate treatment of patients with or at risk of developing opioid and other substance use disorders.
   
   Those applicants, other than a physician or a veterinarian, legally authorized by the State to dispense controlled medications under schedules II-V, may meet the training requirement when they have graduated in good standing from an accredited physician assistant school or accredited school of advanced practice nursing in the United States during the past 5 years, and successfully completed a comprehensive physician assistant or advanced practice nursing curriculum that included at least 8 hours of training on treating and managing patients with opioid or other substance use disorders, including the appropriate clinical use of all medications approved by the FDA for the treatment of substance use disorder.
3. The applicant is a physician who has completed at least 8 hours of training (inclusive or incremental) with respect to the treatment and management of patients with opioid or other substance use disorders or the safe pharmacological management of dental pain and screening, brief intervention, and referral for appropriate treatment of patients with or at risk of developing opioid and other substance use disorders by an entity listed in the CAA.
   
   For those applicants who are non-physicians and legally authorized by the State to dispense controlled medications under schedules II-V, at least 8 hours of training must include training with respect to the treatment and management of patients with opioid or other substance use disorders delivered by an entity listed in the CAA.

It should be noted that this is a one-time attestation and trainings can occur in classroom settings, seminars at professional society meetings, or virtual offerings.

DEA has modified the DEA Form 224 and DEA Form-224a applications for registration/renewal, in order for practitioners to attest to the training standards at their first applicable registration. The term "first applicable registration" means the first registration or renewal of registration by a qualified practitioner on or after June 27, 2023, under 21 U.S.C. 823(l)(4)(A). The updated forms will be available from June 27, 2023, and include a section where a practitioner will attest to meeting the required training according to one of the standards identified above. It is recommended that each practitioner keep a record of training certificates or other materials documenting completion. However, these documents will not need to be submitted to DEA for review at the time of initial application or renewal of registration. After a practitioner attests to the completion of the CAA’s training requirement, if DEA approves the new or renewal application for registration, the new certificate of registration will be issued.

For information on how to satisfy the training requirement, please see the letter dated March 27, 2023, which DEA posted on its website. Practitioners can find additional information related to recommended training content on SAMHSA’s website at Recommendations for Curricular Elements in Substance Use Disorders Training | SAMHSA. EO-DEA268, DEA-DC-075, August 31, 2023

Answer: All DEA-registered practitioners, with the exception of practitioners that are solely veterinarians.

Answer: 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.

Answer: The deadline for satisfying this new training requirement is the date of a practitioner's next scheduled DEA registration submission—regardless of whether it is an initial registration or a renewal registration—on or after June 27, 2023. This one-time training requirement affirmation will not be a part of future registration renewals.

Answer: There are multiple ways that practitioners can satisfy this new training requirement. First, the following groups of practitioners are deemed to have satisfied this training:

1. Group 1: All practitioners that are board certified in addiction medicine or addiction psychiatry from the American Board of Medical Specialties, the American Board of Addiction Medicine, or the American Osteopathic Association.
2. Group 2: All practitioners that graduated in good standing from a medical (allopathic or osteopathic), dental, physician assistant, or advanced practice nursing school in the United States within five years of June 27, 2023, and successfully completed a comprehensive curriculum that included at least eight hours of training on: Past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement. In other words, if you received a relevant training from one of the groups listed below—prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement.
3. Past DATA-Waived trainings count towards a DEA registrant's 8-hour training requirement.
4. Trainings can occur in a variety of formats, including classroom settings, seminars at professional society meetings, or virtual offerings.

Answer:

• The American Society of Addiction Medicine (ASAM)
• The American Academy of Addiction Psychiatry (AAAP)
• American Medical Association (AMA)
• The American Osteopathic Association (AOA), or any organizations accredited by the AOA to provide continuing medical education
• The American Dental Association (ADA)
• The American Association of Oral and Maxillofacial Surgeons (AAOMS)
• The American Psychiatric Association (APA)
• The American Association of Nurse Practitioners (AANP)
• The American Academy of Physician Associates (AAPA)
• The American Nurses Credentialing Center (ANCC)
• Any other organization accredited by the Accreditation Council for Continuing Medical Education (AACCME) or the Commission for Continuing Education Provider Recognition (CCEPR), whether directly or through an organization accredited by a State medical society that is recognized by the ACCME or CCEPR
• Any other organization approved or accredited by the Assistant Secretary for Mental Health and Substance Use, the ACCME, or the CCEPR

Answer: After enactment of the CAA, there are no longer limitations, under federal law, on the number of patients with OUD that a practitioner may treat with buprenorphine. On December 29, 2022, President Biden signed into law the CAA which expanded patient access to medications for OUD.

Answer: Yes, but only in limited circumstances. Ordinarily, a prescription only authorizes a pharmacist to dispense a controlled substance to an ultimate user, which includes a patient or a member of the patient's household. However, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) permits a pharmacy to deliver a controlled substance prescribed for maintenance or detoxification treatment to a practitioner's registered location for the purpose of direct administration through either injection or implantation to a narcotic dependent person.