The American Society of Addiction Medicine (ASAM) is deeply committed to ensuring every person with substance use disorder (SUD) has access to high-quality, full-spectrum addiction care and to closing the addiction treatment gap. This commitment includes advocating for optimizing telehealth access and utilizing it to advance health equity in addiction medicine. With the illicit drug supply becoming increasingly lethal, and the COVID-19 pandemic’s exacerbation of challenges faced by people with SUD, racial and ethnic health disparities have widened with record numbers of drug overdose deaths. Although telehealth for addiction care grew more slowly than it did for other types of medical care before the onset of COVID-19, the pandemic catalyzed sweeping changes that brought telehealth beyond where it was previously underutilized or prohibited....

Recommendations (October 2022)

1. Federal agencies, states, and payers should standardize telehealth definitions and terminology.
2. Addiction medicine professionals should offer telehealth options to optimize access to addiction care.
3. Requirements for ancillary services, such as toxicology testing, should not be barriers to accessing addiction care via telehealth and may be delivered via telehealth in some circumstances.
4. Federal law should be amended to create a new telehealth evaluation alternative to the Ryan Haight Act’s in-person medical evaluation requirement, which would permit the initial issuance of a prescription for a controlled medication approved by the Food and Drug Administration to treat SUD, using an audio-visual, real-time, and two-way interactive communication system and without any requirement for special registration. If and when the DEA issues final regulations to implement the “special registration” “practice of telemedicine” exception under the Ryan Haight Act, those regulations should be consistent with principles of broad access and low barriers to addiction care.
5. Regulatory flexibilities tied to the COVID-19 PHE are relevant to the opioid overdose crisis and should be extended under that PHE or other available authority. Federal agencies should continue to study the impact of the use of audio-only technology for buprenorphine treatment for OUD, including the impact on health inequities and outcomes.
   DEA regulations should continue to allow for the initiation and maintenance of buprenorphine with audio-only technology during the opioid overdose crisis PHE, and SAMHSA regulations should continue to allow for same at OTPs.
   DEA and SAMHSA should work to make these flexibilities permanent, as appropriate, based on findings of further studies.
   SAMHSA regulations should make permanent other OTP-related telehealth flexibilities implemented during the COVID-19 PHE.
   SAMHSA and DEA regulations should allow for the initial medical evaluation for treatment of OUD with methadone by audio-visual telehealth technology.
   Federal and state laws, regulations, and guidance related to telehealth-delivered addiction care should not add restrictions or barriers that could increase risk of abrupt discontinuation of addiction care.
6. States should align their telehealth policies with federal telehealth policies to the extent the latter allow for increased access to, and retention in, evidence-based addiction care.
7. States should adopt legislation to prohibit pharmacies, pharmacy benefit managers, and health insurers from interfering with a state-licensed pharmacist’s corresponding responsibility under the federal Controlled Substances Act; such legislation should appropriately empower state medical or pharmacy boards to review and potentially veto corporate policies that limit or restrict controlled addiction medication prescriptions or their dispensing84 on basis of relation to telehealth, prior to the policies’ implementation. Any such existing corporate policy should be suspended.
8. The use of audio-only and audio-visual telehealth modalities for addiction care should be studied to inform best practices, ensure better health outcomes, and advance health equity.
9. Federal and state governments should expand programs that reduce inequities in digital access for people with SUD, promote digital literacy, and make strategic investments in telehealth infrastructure, while acting decisively to prevent and eliminate digital discrimination.
10. Jurisdictions and institutions should ensure virtual interpretation services are provided to patients with non-English language preference to increase access to care.
11. Payers should cover telehealth-delivered addiction care on the same basis and to the same extent they cover the provision of the same service through in-person care, including prescribing through telehealth if such prescribing is permissible under applicable federal and state law.
    Reimbursement rates for telehealth-delivered addiction care should be fair and equitable and account for facility fees to support telehealth services for beneficiaries who are unhoused or otherwise difficult-to-reach and treat populations and in need of telehealth services at a safe, confidential location. 
    Utilization management techniques on benefits provided through telehealth for addiction care should be fully consistent with standards of care and clinical practice that are generally recognized by federal agencies or medical societies with expertise in addiction treatment.
12. States should join the Interstate Medical Licensure Compact to increase access to addiction care, especially given the more widespread adoption of telehealth.
13. Further studies, including prospective clinical trials, are needed to measure and compare the effectiveness of different telehealth modalities (audio-visual and audio-only) for addiction care, focusing on utilization, quality of care, and impacts in real world healthcare systems. Studies should attempt to account for the fact that the alternative to telehealth-delivered addiction care is often no care.
14. Federal agencies should study the impact of pausing HIPAA enforcement against healthcare providers in connection with the good faith provision of telehealth during the COVID-19 PHE to inform long-term policy approaches that will protect patient privacy and confidentiality in telehealth care, without creating barriers to accessing care. Federal agencies should provide clear, user-friendly HIPAA telehealth guidance for the period following the COVID-19 PHE.
15. Telehealth should not supplant adequate in-person addiction care. Health plans should have adequate SUD provider networks that allow beneficiaries the option to access telehealth and in-person addiction care.
16. Tele-harm reduction services, including syringe services, should be studied, and expanded to the extent they improve health outcomes.
17. Policymakers, and to the extent applicable, payers, should support telehealth service expansion in jails and prisons to increase access to addiction treatment, including addiction medications.