NASADAD releases overview of buprenorphine patient limits

NASADAD has released an overview of buprenorphine patient limits. The overview includes a history of the issue, beginning with the Drug Addiction Treatment Act (DATA) of 2000, which permits physicians who meet certain qualifications to treat opioid use disorders with FDA-approved medications in treatment settings other than opioid treatment programs (OTPs). The document reviews the 2016 final rule on MAT for Opioid Use Disorders, which allows eligible physicians to request approval to treat up to 275 patients after prescribing at the 100-patient limit for one year. The overview also describes the impact of the Comprehensive Addiction and Recovery Act of 2016 and the SUPPORT Act of 2018, which both expanded the definition of a “qualifying other practitioner” who can prescribe buprenorphine to include nurse practitioners and physician assistants (CARA), as well as clinical nurse specialists, certified registered nurse anesthetists, and certified nurse midwives (SUPPORT).


The overview includes the current status of who can be considered a “qualifying practitioner”. If they meet certain criteria (e.g., 8 hours of training for physicians, 24 hours of training for NPs, Pas, CNSs, CRNAs, and CNMs), the following types of practitioners can apply for a DATA waiver in order to offer MAT:

  • Physicians (including osteopathic and allopathic doctors)
  • Nurse practitioners
  • Physician assistants
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Certified nurse midwives


Additionally, the overview summarizes the current maximum patient limit for physicians: Qualifying physicians can treat 100 patients in the first year if they meet the criteria outlined in the SUPPORT Act, and 275 after one year of prescribing at the 100-patient limit. If a physician does not meet the criteria to treat 100 patients in the first year, they would have to prescribe at the 30-patient limit for one year before requesting an increase to 100 patients, and then treat at the 100-patient limit for one year before requesting an increase to 275 patients.