Buprenorphine prescribing after DATA-Waiver removal
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Explains DEA removal of the DATA-Waiver (X-Waiver) and the resulting change that standard DEA registration with Schedule III authority is sufficient for prescribing buprenorphine for opioid use disorder; affects practitioners who prescribe controlled substances and members/providers of San Francisco Health Plan.
The DATA-Waiver (X-Waiver) registration numbers are no longer needed for any buprenorphine prescription.
Any practitioner with a current DEA registration that includes Schedule III authority may now prescribe buprenorphine for OUD.
New DEA training requirements (an eight-hour addiction identification and treatment training) will take effect for prescribers when applying for or renewing DEA registration on June 21, 2023.
Coverage Criteria for Buprenorphine Prescribing
Prescriber Authorization to Prescribe Buprenorphine
Covered when ALL of the following are met
No separate DATA-Waiver/X-Waiver required
The policy does not list any additional clinical exclusions for buprenorphine prescribing beyond standard DEA registration requirements. Specifically, there are no stated clinical conditions or member-level exclusions that would prohibit prescribing buprenorphine for opioid use disorder; coverage is tied to prescriber authorization rather than patient clinical exclusions.
This document does not identify any circumstances or diagnoses as not medically necessary for buprenorphine treatment. No explicit "not medically necessary" conditions are specified; coverage considerations focus on prescriber DEA registration status rather than clinical exclusion criteria.
Coding and Administrative Details
| No codes listed |
Provider Actions, Documentation, and Risk
DATA‑Waiver/X‑Waiver no longer required for buprenorphine
No DATA‑Waiver/X‑Waiver number is required; a standard DEA registration that includes Schedule III authority is sufficient for buprenorphine prescriptions.
Prescriptive authority and patient limits
Prescribers should be aware of DEA regulatory changes: any practitioner with a current DEA registration that includes Schedule III authority may prescribe buprenorphine for OUD; there are no DEA patient‑limit caps.
Maintain current DEA registration with Schedule III authority
Prescribers must have and maintain a current DEA registration that includes Schedule III authority to prescribe buprenorphine for opioid use disorder.
Risk of denial without Schedule III DEA registration
Prescriptions may be denied if the prescriber does not have a valid DEA registration that includes Schedule III authority when prescribing buprenorphine for OUD.
Background
The DEA eliminated the DATA‑Waiver (X‑Waiver) program effective January 12, 2023. As a result, waiver (X‑Waiver) registration numbers are no longer required for buprenorphine prescriptions and will not be accepted. Any practitioner with a current DEA registration that includes Schedule III authority may prescribe buprenorphine for opioid use disorder, and there are no limits on the number of patients a prescriber may treat with buprenorphine under this change. Additionally, the DEA announced new training requirements effective June 21, 2023: prescribers applying for or renewing DEA registration must complete an 8-hour training on identifying and treating addiction.
Definitions
Level of Care Criteria
Treatment Modalities
Medication for OUD (Buprenorphine)
Applicable to treatment of OUD
Revision History
DEA confirmed elimination of the DATA‑Waiver (X‑Waiver) program and stated waiver applications will no longer be accepted; DATA‑Waiver numbers are no longer needed for buprenorphine prescriptions.
San Francisco Health Plan updated prescribing requirements to allow any practitioner with a current DEA registration that includes Schedule III authority to prescribe buprenorphine for opioid use disorder and removed previous patient limits.
New DEA requirement effective June 21, 2023: prescribers applying for or renewing DEA registration must complete an eight‑hour training on identifying and treating addiction.
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