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Phone:803.216.0850 Fax:803.216.0420
SPECIAL ANNOUNCEMENT UPDATED 3/1/2023
NEW INFORMATION ON YOUR VISITS if you are taking a controlled medication
On May 11th, 2023 the "relaxed" regulations for prescribing controlled medications through virtual visits will be ending. The Public State of Emergency (PSE) is set to expire May, 11 this year which means that if you have not been by your prescribing provider in person at least once, we need to schedule that visit. After May 11, pharmacies will not fill controlled substances unless the in person requirement is met.
We recognize that asking patients to come in to the office may create scheduling conflicts for both the patients and staff, so we ask that you work with us to help ensure you are able to continue your medication(s) if applicable. Please contact our office, or go to our portal and request an IN PERSON visit or if you have an appointment already, please indicate CHANGE TO IN PERSON.
Remember, you will need to be seen at least once in person if you have not been seen in person already by the PRESCRIBING provider (if you have seen a counselor in person but not your medication management provider, you will still need to be seen by the medication management provider).
What are controlled vs. non-controlled substances?
Controlled substances are medications that can cause physical and mental dependence. There are restrictions on how they can be filled and refilled. Controlled substances are regulated and classified by the DEA (Drug Enforcement Administration). Regulations are based on how likely they are for abuse and to cause dependence.
Some examples of controlled substances include:
- ADHD medications — like Adderall (amphetamine salt combo) and Vyvanse (lisdexamfetamine)
- Anti-anxiety medications — like alprazolam (Xanax) and clonazepam (Klonopin)
- Nerve pain medications — like pregabalin (Lyrica)
- Opioid pain medications — like Norco (hydrocodone/acetaminophen) and tramadol (Ultram)
- Sleep medications — like zolpidem (Ambien)
Additionally, some medications aren’t considered controlled substances by the DEA. But they’re categorized that way in certain states. Examples include gabapentin (Neurontin) and pseudoephedrine (Sudafed).
The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 was created to regulate online internet prescriptions, is enforced by the DEA (Drug Enforcement Agency) and also imposes rules around the prescription of controlled substances through telepsychiatry.
- The Act requires any practitioner issuing a prescription for a controlled substance to conduct an in-person medical evaluation (with certain specified exemptions) prior to prescribing controlled substances. Per the Act, the prescribing practitioner is required to have conducted one in-person medical evaluation with the patient and may prescribe via telemedicine thereafter. The occurrence or frequency of additional in-person visits is not mandated under the Ryan Haight Act.
- The Act also describes special circumstances such as “covering practitioners” – “a practitioner who conducts a medical evaluation [by telemedicine] at the request of a practitioner who … has conducted at least 1 in-person medical evaluation of the patient or an evaluation of the patient through the practice of telemedicine within the previous 24 months" – and prescribing within a federal health care system (e.g. Indian Health System; Department of Veteran’s Affairs). Psychiatrists working in federal health care systems should be familiar with their organization’s policy around the telepsychiatric prescribing of controlled substances.
- In addition to complying with the Ryan Haight Act, psychiatrists need to make sure they comply with other federal, state and organizational rules and policies around the prescription of controlled substances. As of December 2022, the Centers for Medicare & Medicaid Services (CMS) requires annual in-person visits for mental health, subject to exceptions if the risk of in-person care outweighs the clinical benefit, for Medicare patients. CMS also requires in-person establishment of Medicare patients prior to providing telemental health, which is not eligible for exceptions.
Additional in-person evaluations, beyond the minimum required by relevant facility, state, and federal policy, is up to clinical discretion. For example, if the practitioner is unable to obtain the data they need for clinical decision-making through telehealth, the practitioner may recommend that a patient be seen in-person.
Check in Procedures for In Person Visits
Please bring your drivers license, insurance card and make sure any balances are up do date if you are returning patient. Please also make sure any screeners are complete prior to your visit in order to make check in process as quick as possible. Also if you would like to expedite the check out the process, please enter and save your credit card in portal.