For inquiries related to controlled medications and details about in-person visits, please call us at 803.216.0850. You can also reach us by fax at 803.216.0420 to discuss telepsychiatry regulations.
On May 11th, 2023, the "relaxed" regulations for prescribing controlled medications through virtual visits will come to an end. With the expiration of the Public State of Emergency (PSE) on May 11 this year, it is essential that if you have not met with your prescribing provider in person at least once, we must schedule that in-person visit. After May 11, pharmacies will no longer fill prescriptions for controlled substances unless this in-person requirement is satisfied.
We understand that requiring patients to come to the office may lead to scheduling conflicts for both patients and staff. Therefore, we encourage you to work with us to ensure you can continue your medication(s) as needed. Please reach out to our office or visit our portal to request an IN-PERSON visit. If you already have an appointment scheduled, kindly indicate a CHANGE TO IN PERSON.
Keep in mind that you must be seen in person at least once by the prescribing provider if you have not yet had an in-person visit (if you have met with a counselor but not your medication management provider, it remains necessary to see the medication management provider).
What are controlled vs. non-controlled substances?
Controlled medications are those that can lead to physical and mental dependence, and they are subject to strict regulations on how they can be filled and refilled. These substances are classified and regulated by the DEA (Drug Enforcement Administration) based on their potential for abuse and dependence.
Examples of controlled medications include:
- ADHD medications, such as Adderall (amphetamine salt combo) and Vyvanse (lisdexamfetamine)
- Anti-anxiety medications, like alprazolam (Xanax) and clonazepam (Klonopin)
- Nerve pain medications, such as pregabalin (Lyrica)
- Opioid pain medications, including Norco (hydrocodone/acetaminophen) and tramadol (Ultram)
- Sleep medications, like zolpidem (Ambien)
Additionally, while some medications may not be classified as controlled substances by the DEA, they can be regarded as such in certain states. Gabapentin (Neurontin) and pseudoephedrine (Sudafed) are notable examples.
The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 was established to regulate online prescriptions, enforced by the DEA, and imposes specific telepsychiatry regulations regarding the prescription of controlled medications. The Act mandates that any practitioner prescribing controlled substances must conduct an in-person medical evaluation (with specified exemptions) before issuing such prescriptions. After an initial in-person medical evaluation, telemedicine can be utilized for subsequent prescriptions. However, additional in-person visits are not mandated under the Ryan Haight Act.
The Act also outlines provisions for “covering practitioners,” who can perform medical evaluations via telemedicine at the request of another practitioner who has previously conducted an in-person evaluation of the patient within the last 24 months, as well as prescribing within a federal healthcare system, such as the Indian Health System or the Department of Veterans Affairs. Psychiatrists practicing in these systems should be familiar with their organization's policies pertaining to telepsychiatry regulations for controlled medications.
Moreover, psychiatrists must comply with not just the Ryan Haight Act, but also with other federal, state, and organizational policies regarding the prescription of controlled substances. As of December 2022, the Centers for Medicare & Medicaid Services (CMS) mandates annual in-person visits for mental health assessments, with exceptions allowed if the risk of in-person care overshadows the clinical benefit for Medicare patients. CMS further requires that Medicare patients be seen in person to establish care before telemental health services are provided, which cannot be exempted.
Whether further in-person evaluations are necessary beyond the minimum stipulated requirements by relevant policies is left to the clinician's discretion. For instance, if a practitioner cannot gather essential data for clinical decision-making through telehealth alone, they may advise that a patient attends an in-person visit.
Please bring your driver's license and insurance card, and ensure any balances are up to date if you are a returning patient. Additionally, it is important to complete any required screeners prior to your in-person visit to make the check-in process as quick as possible. If you wish to expedite the checkout process, please enter and save your credit card information in the portal, particularly if you are receiving prescriptions for controlled medications. For those utilizing telepsychiatry regulations, this preparation will help streamline your overall experience.
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