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Article CommentaryCommentary

The End of the X-waiver: Excitement, Apprehension, and Opportunity

Nicholas LeFevre, Joshua St. Louis, Emma Worringer, Morgan Younkin, Natalie Stahl and Mia Sorcinelli
The Journal of the American Board of Family Medicine September 2023, jabfm.2023.230048R1; DOI: https://doi.org/10.3122/jabfm.2023.230048R1
Nicholas LeFevre
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, MSAM, FAAFP
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Joshua St. Louis
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, MPH, AAHIVS, FAAFP, FASAM
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Emma Worringer
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, MPH
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Morgan Younkin
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, MPH
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Natalie Stahl
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, MPH
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Mia Sorcinelli
From Department of Family and Community Medicine, University of Missouri-Columbia, Columbia, MO; Department of Family Medicine, Tufts University School of Medicine, Core Faculty, Lawrence Family Medicine Residency, Lawrence, MA (JSL); Rush-Esperanza Family Medicine Residency, Chicago, IL (EW); Harm Reduction Services, Boston Health Care for the Homeless Program, Clinical Assistant Professor, Department of Family Medicine, Tufts University School of Medicine, Boston, MA (MY); Department of Family Medicine, Tufts University School of Medicine, Addiction Consult Service, Lawrence General Hospital, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (NS); Office Based Addiction Treatment Program, Greater Lawrence Family Health Center, Community Faculty, Lawrence Family Medicine Residency, Lawrence, MA (MS).
MD, FASAM, FAAFP
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    Figure 1.

    Training requirements for Drug Enforcement Agency (DEA) license renewal under the Medication Training and Expansion (MATE) act. Information from reference.4 Abbreviations: FDA, US food and drug administration; SUD, Substance use disorder.

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    Table 1.

    Timeline of Buprenorphine as Medication for Opioid Use Disorder (MOUD) Regulatory Changes

    1974Narcotic Addict Treatment Act (NATA)Requires special DEA registration to dispense (but not prescribe) MOUD, creating OTPs (opioid treatment programs). Effectively creates Methadone clinics as they exist today.
    2000DATA (Drug Addiction Treatment Act) 2000Exempts buprenorphine from OTP regulations. Allows physicians to prescribe buprenorphine as MOUD but requires an 8-hour training, a special registration with the DEA, and limits the number of patients per clinician (or group practice) to 30. Creates the X-waiver program.
    2005 to 2006Amendments to DATA 2000Remove the group practice limit, introduces 100 patient limits for physicians holding an X-waiver for at least one year (must apply).
    2016CARA (Comprehensive Addiction and Recovery Act)Introduces option for Nurse Practitioners (NP) and Physician Assistants (PA) to apply for a 30-patient X-waiver (with 24 hours of certified training).
    2018SUPPORT (Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities) ActCertain physicians holding a 100-patient X-waiver for at least 1 year may apply for a 275-patient limit if their practices meet certain requirements.
    NPs and PA’s holding 30-patient X-waiver for 1 year can apply for 100-patient X-waiver.
    2020Easy MATPractitioners can dispense (but not prescribe) up to a 3-day supply of buprenorphine without an X-waiver (useful for Emergency Room clinicians)
    2021Executive ActionPhysicians, NPs, and PAs are allowed to apply for an X-waiver with a 30-patient limit without the 8- or 24-hour training requirement.
    2022MAT (Mainstreaming Addiction Treatment) and MATE (Medication Training and Expansion) ActsEliminates the X-waiver program entirely. Buprenorphine is now treated like any other schedule 3 medication when prescribed as MOUD. Institutes new 8-hour addiction treatment training requirement for all clinicians at time of DEA license renewal.
    • Abbreviation: DEA, Drug enforcement agency.

    • Note: Information from references.3,4,28

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The Journal of the American Board of Family     Medicine: 37 (6)
The Journal of the American Board of Family Medicine
Vol. 37, Issue 6
November-December 2024
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The End of the X-waiver: Excitement, Apprehension, and Opportunity
Nicholas LeFevre, Joshua St. Louis, Emma Worringer, Morgan Younkin, Natalie Stahl, Mia Sorcinelli
The Journal of the American Board of Family Medicine Sep 2023, jabfm.2023.230048R1; DOI: 10.3122/jabfm.2023.230048R1

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The End of the X-waiver: Excitement, Apprehension, and Opportunity
Nicholas LeFevre, Joshua St. Louis, Emma Worringer, Morgan Younkin, Natalie Stahl, Mia Sorcinelli
The Journal of the American Board of Family Medicine Sep 2023, jabfm.2023.230048R1; DOI: 10.3122/jabfm.2023.230048R1
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