Meeting the 24 Hour Requirement
If the PA works in a state that requires that they prescribe under the supervision of or in collaboration with a qualified physician, the physician doesn’t need the waiver, they only need to be qualified to apply for it. The definition of a qualified physician is provided below and further information regarding the qualifications can be found in Public Law 114-198 (see page 27).
The term “qualifying physician” has a defined meaning within the context of CSA. Specifically, 21 USC 823(g)(2)(G)(ii) provides the following (emphasis added): See page 27 Public Law 114-198.
Therefore, when the CSA references a “qualifying physician” in this context, it is not just referring to a physician with an active license, but to a licensed physician who also satisfies one or more of the above conditions. Please note that these conditions establish the eligibility requirements for receiving a waiver and do not include possession of a waiver itself.
PAs may use their waiver to prescribe buprenorphine products for the treatment of opioid use disorder in any healthcare setting including OTPs. However, the healthcare setting or employer, OTP or otherwise, is free to establish by policy which services are to be provided and by which professionals. Any practitioner who uses the waiver to treat patients must comply with their patient limit regardless of the treatment setting. Physician assistants may order buprenorphine or methadone for administration or dispensing from an OTP without a DATA waiver, but must receive an exemption from SAMHSA to make dose and administration adjustments.
At the end of the 8 hour MAT waiver training, you will receive a certificate of completion and a CME credit certificate.
With PCSS, you will receive a certificate of completion for the 16 hour MAT waiver training and a CME credit certificate for the 16 hour requirement.
PCSS offers the entire 24 hours of training at no cost. All DATA 2000 organizations, including the American Academy of Addiction Psychiatry (AAAP), American Society for Addiction Medicine (ASAM), American Psychiatric Association, and American Osteopathic Academy of Addiction Medicine can provide this training as well (some fees may apply).
No, if you have taken the 8 hours of MAT waiver training and received your certificate of completion from a DATA 2000 organization (listed above), even if it was prior to the passage of CARA, you only need a copy of your certificate of completion. You can use this certificate when applying to the Substance Abuse and Mental Health Services Administration (SAMHSA) for a waiver. Apply here ›
Contact one of the DATA organizations (AAAP, ASAM, American Psychiatric Association, and American Osteopathic Academy of Addiction Medicine) to learn if you have taken the training.
PCSS offers the 8 hour MAT waiver training as an on-demand online course. The course is specifically targeted to PAs and allows users to take the course on their own time. You must complete this self-paced training with 45 days of initiating.
To accommodate larger groups, healthcare organizations may also request a training through the PCSS program. Contact PCSS for more information.
Yes. You can complete the 8 hour training provided by one of the DATA 2000 organizations listed above, then complete the 16 hour training by a different organization. However, you must complete all 16 hours of the 16 hour training with the same organization.
No. All 16 hours must be provided by the same organization. For example, all 16 hours must be taken with PCSS.
PAs may take the required 16 hours of additional training through PCSS at no cost or through several other organizations listed in CARA, including AAAP, ASAM, APA, and AOAAM, the American Association of Nurse Practitioners, and American Nurses Credentialing Center (fees may apply).
Once you have completed the 24 hours of coursework required you will need to submit the following to SAMHSA to apply for the waiver
Certificate of completion for 8 hour waiver course
Certificate of completion of 16 hours of courses
Notice of Intent form ›
This infographic contains helpful information/links ›
Currently, PAs who are waivered may prescribe buprenorphine to 30 patients. HHS is reviewing increasing the patient limit to 100 after one year at the 30-patient level.