Author: jb0nez
Posted: Thu Apr 19, 2012 1:00 am
Wanted to edit my post but didn’t see a button to do so. Anyway this document clears it up. YES it can be prescribed off-label by any doctor with a C-III certification. Just as Darken said, they don’t need to put their special Suboxone UIN on the label.
Here’s the link:
http://www.naabt.org/links/dea_bup_for_pain_letter.pdf
Interesting and relevant quotes:
"The off-label use of the sublingual formulations of buprenorphine (Suboxone®/Subutex®) for the treatment of pain is not prohibited under DEA requirements. However, off-label use does pose a dilemma for pharmacists. Currently, there is no requirement under the DATA for a qualified practitioner to put the Unique Identification Number (UIN) on a prescription for Suboxone® or Subutex® for maintenance or detoxification treatment."
"If a physician prescribes, dispenses or administers buprenorphine (Suboxone®/Subutex®) for the treatment of pain or for any other reason, a DEA registration is required because both products are Schedule III controlled substances. The DATA waiver specifically authorizes qualified practitioners to treat narcotic dependent patients, using FDA approved Schedule III-V narcotic controlled substances for maintenance and detoxification. The DATA waives the requirement for obtaining a separate DEA registration as a narcotic treatment program for physicians using the approved drugs for maintenance and detoxification; however, it does not apply to physicians using Suboxone® or Subutex® for the treatment of pain. A physician using Suboxone® or Subutex® for the treatment of pain would be required to register with DEA as practitioner with Schedule III privileges."
So from the first paragraph it clearly says it is not prohibited for pain — and I think one could infer that it’s not prohibited for depression either (making it relevant to this thread, I’m not wanting this to go off-topic in your log Darken), they just didn’t think to address it the time this was written. The second paragraph is a bit confusing but I think what they are saying is that docs who get the DATA waiver ("subox docs") don’t automatically get the authority to prescribe other C-III meds, and that a doc who prescribes it for pain needs a standard C-III DEA number. Some docs have both and those could do it for opioid dependence or for pain; and any doc with a C-III DEA number already (which is probably most MD’s as that class includes Vicodin/Lortab) can go ahead and prescribe it for pain.
This is very interesting. I didn’t know this and I will show my doc next time. What ISN’T clear is if a doc who has both the DATA waiver and C-III number could *move* a patient from their "100 limit" to the "pain/depression/off label" group.
