Keeping Your Suboxone Claims Safe from Recoupment
As of December 29, 2022, the DEA no longer requires prescribers to include a DATA 2000 Waiver ID (commonly called an “XDEA number”) on buprenorphine prescriptions used to treat patients with opioid use disorder via the Consolidated Appropriations Act of 2023. With additional prescribers now able to issue prescriptions, and opioid dependence still plaguing America, oral buprenorphine products remain commonly used and filled by local pharmacies.
A frequent problem that PAAS National® analysts see on audits is …
the splitting of buprenorphine/naloxone tablets and films. The package insert explicitly states that the tablets and films should be taken whole and not to cut, chew, or swallow. Films have been approved to be administered sublingually or buccally, where tablets are only approved to be taken sublingually.
The question remains of how to handle a prescription where the prescriber writes for Suboxone® splitting films or tablets. The best practice would be to contact the prescriber and ask for a second prescription for the lower strength instead of splitting, where possible. Suboxone® films are available in 4 different strengths: 2-0.5 mg, 4-1 mg, 8-2 mg, and 12-3 mg. Suboxone® sublingual tablets are available in 2 strengths: 2-0.5 mg and 8-2 mg. Interchanging between the Suboxone® products should only be done under prescriber supervision as the products are not bioequivalent.
PAAS Tips:
- Prescriptions should have the patient’s address, prescriber’s address and prescriber DEA number on the hard copy
- Verify all controlled substance state required elements are present, including but not limited to alphanumeric quantity and marked quantity checkboxes (where required)
- Dosage form should be specified as tablets or films
- Directions should be in full dose units
- If smaller or larger doses are needed, a separate prescription should be issued instead of splitting/cutting tablets or films
- Route of administration should be “buccal” (films only), “sublingual” or “under the tongue” (films and tablets)
- Claims can be recouped for directions of “by mouth”
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