Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing Prescribing of Opioids and Buprenorphine [18 VAC 85 ‑ 21]
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6/11/25  7:26 pm
Commenter: Breyana Hopkins

I support this amendment for the sake of our children and VA's future.
 

Virginia is one of the few states with prescriber requirements that limit patient access to and use of the innovative medication buprenorphine (CPHLR, 2024). We pride ourselves on the high-quality health training, resources, and services we have worked hard to build, adapt, and advance, especially in creating life-saving protocols for individuals who use substances, particularly opioids.

With rigorous licensing and certification programs for health professionals, Virginia has a highly qualified and intelligent healthcare workforce. These professionals are trained to de-escalate crises, operate effectively in high-stakes environments, and, most importantly, make patients feel heard and understood while collaboratively developing treatment plans. For these reasons, it is imperative to expand the time and support that qualified prescribers have to work one-on-one with patients affected by substance use disorders.

There is no single sector or group to blame for this epidemic, but we all have a responsibility to be part of the solution. Virginia is already making significant progress toward this goal. Emergency department visits, morbidity, and mortality associated with opioid and other drug use have all declined, particularly since 2022. ED visits specifically have been on the decline with about 32.2 VA residents (per 10,000 visits) in 2023, 30 in 2023, and 22 in 2024 (VDH, 2025). Drug overdose rates in VA reduced from 2,463 in 2023 and 1,396 in 2024, which is remarkable and showcases the potential of VA healthcare professionals.  

However, the ongoing challenges in accessing harm reduction medications, like buprenorphine, used to manage withdrawal symptoms only worsen existing physical, social, financial, and geographic barriers to care. People who use harmful substances are especially vulnerable, often caught in cycles of social stigma and physiological dependence that make it difficult to stop, even when they want to. The physical symptoms of withdrawal are constant, intense, and often feel instinctual to suppress which drives continued use. Without increased support from these protocols, opioid users that could have been successful in abstinence will be lost to follow-up if the process is too complex

This kind of medical emergency requires fast, tactical intervention from trained professionals. When someone is experiencing withdrawal, they and those around them are at risk, as overwhelming emotions can override logic and safety. When healthcare providers do manage to convince patients to begin their journey toward recovery, the system for accessing withdrawal-reducing medications and other harm reduction tools must be as streamlined and supportive as possible.

Peer-reviewed research consistently supports the effectiveness of buprenorphine and methadone in keeping patients in treatment. Treatment retention is one of the most critical outcomes, as it significantly reduces opioid use outside of medically controlled environments. In one study, retention rates were 53% (367 out of 697) when using flexible dosing of buprenorphine, or adjusting doses as needed to support abstinence, demonstrating its powerful role in improving adherence and abstinence (Shulman et al., 2019).

Regarding Amendment 2, studies show that flexible dosing is highly practical in clinical settings, as achieving abstinence remains the primary goal. Providers are unlikely to increase doses without assessing environmental or psychological stressors and exploring other interventions first. With more trauma-informed care providers, clinicians are better equipped to identify patterns in dose requests and engage patients in meaningful discussions about their needs. Notably, a brain imaging trial comparing 16 mg and 32 mg doses found no significant difference in activity, suggesting that 24 mg may not be clinically more effective for most patients (Grande, L.A., 2023). However, another study involving over 10,000 patients using prescription monitoring data found that adherence and reduced illicit opioid use were associated with doses over 32 mg (Pizzicato, L.N., 2020).

Finally, prescribing restrictions for individuals under 16 must be reconsidered. According to CDC data, overdose mortality among adolescents aged 14–18 rose by 94% from 2019 to 2020, and another 20% from 2020 to 2021 (Tanz, L.J., 2022). These increases suggest that young people are accessing substances, whether counterfeit, fentanyl-laced, or misused medications, outside the medical system.As of 2025, among Virginia residents, the overdose emergency department (ED) visit rate per 10,000 visits for ages 0–14 is 8.9 for females and 6.0 for males (VDH, 2025). In the 15–19 age group, the rates are 19.8 for females and 18.3 for males per 10,000 visits . Providers must have the option to offer safer alternatives and interventions for adolescents to reduce their risk of overdose and prevent the spread of misuse among peers.

In summary, I support all three of these amendments as a Master of Public Health candidate and a lifelong Virginian. Allowing greater flexibility for healthcare providers sends a clear message that Virginia is taking meaningful action—guided by current data and focused on harm reduction. This approach will reduce overdose mortality, ease the financial burden of the opioid epidemic (which cost the state over $5 billion in 2021 alone; Trani, O., 2024), and increase the number of survivors who can share their stories and help break the cycle of misuse and overprescribing.


References:
Center for Public Health Law Research & Vital Strategies (CPHLR). (2024). Buprenorphine Prescribing Requirements and Limitations [Data set]. Prescription Drug Abuse Policy System. https://www.lawatlas.org/datasets/buprenorphine-prescribing-requirements-and-limitations 

Grande, L. A., Cundiff, D., Greenwald, M. K., Murray, M., Wright, T. E., & Martin, S. A. (2023). Evidence on Buprenorphine Dose Limits: A Review. Journal of addiction medicine, 17(5), 509–516. https://doi.org/10.1097/ADM.0000000000001189 

Pizzicato, L.N, Hom J.K., Sun M., et al. (2020). Adherence to buprenorphine: An analysis of prescription drug monitoring program data. Drug Alcohol Depend. 216:108317. https://doi.org/10.1016/j.drugalcdep.2020.108317 

Shulman, M., Wai, J. M., & Nunes, E. V. (2019). Buprenorphine Treatment for Opioid Use Disorder: An Overview. CNS drugs, 33(6), 567–580. https://doi.org/10.1007/s40263-019-00637-z 

Tanz LJ, Dinwiddie AT, Mattson CL, O’Donnell J, Davis NL. Drug Overdose Deaths Among Persons Aged 10–19 Years — United States, July 2019–December 2021. MMWR Morb Mortal Wkly Rep 2022;71:1576–1582. DOI: http://dx.doi.org/10.15585/mmwr.mm7150a2

Trani, O. (2024). The opioid epidemic cost Virginians $5 billion in 2021, new data shows. VCU news. https://news.vcu.edu/article/2024/01/the-opioid-epidemic-cost-virginians-5-billion-in-2021-new-data-shows  

 

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