Statistics & Background Information

  • About 80 percent of the approximately two million people in the U.S. with opioid use disorder (“OUD”) do not have access to medication-assisted treatment (“MAT”).
  • Fewer than seven percent of the nation’s doctors have satisfied the regulatory requirements to prescribe buprenorphine. As a result, more than half of all counties in the U.S. have no licensed buprenorphine prescriber.
  • Therefore, there is a need for innovative approaches to increase the number of medical providers who can administer MAT to individuals with OUD.
  • The federal Controlled Substances Act (“CSA”) was amended in 2018 to allow emergency medical services (“EMS”) professionals to administer controlled substances outside the presence of a medical director or other authorizing medical professional pursuant to a standing order for a specific patient and as authorized by state law.
  • EMS professionals include nurses, paramedics, or emergency medical technicians who are licensed or certified in their respective states and credentialed by the EMS agency medical director.
  • This new authority is limited to emergency medical response and emergency mobile medical services provided outside of a fixed medical facility.

Notable Requirements

  • A registered EMS agency, under the supervision of a medical director, is responsible for ensuring that:
    • All EMS professionals who administer controlled substances using the agency’s registration act in accordance with the law;
    • Controlled substance record keeping requirements are met with respect to a registered location and each designated location of the agency;
    • The applicable physical security requirements established by regulation of the Attorney General are complied with wherever controlled substances are stored by the agency; and
    • The agency maintains, at a registered location of the agency, a record of the standing orders issued or adopted in accordance with general record maintenance requirements.