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The following letter from the DEA appeared on the American Society For Addiction Medicine (ASAM) website in response to a letter sent to ask for clarification regarding the use of pain medication in addiction medicine practice.  As you read this letter remember that the central question that needs to be answered by national policy is this:  

Who should have the final authority to determine the medically appropriate use of prescription drugs - doctors or enforcement professionals?  

The answer to this question is important and must be clearly answered.  The United States is currently operating under a War On Drugs Policy that views people who use of prescription drugs for  "non-medical reasons" and the doctors & pharmacists who provide them as criminals guilty of felony drug offenses.  The enforcement professionals at the DEA and other governmental agencies are ready and willing to step in, over-ride medical doctors, and criminalize the acts of prescribing, filling, and using prescription medications.  When this happens the legal penalties for all concerned can be severe and include prison time.  This legal threat can compromise medical decision making.

Here's the DEA letter to ASAM.  You can read more about my position on Prescription Drug Abuse on my website   My congratulations to ASAM for directly addressing this issue.

Terence T. Gorski
April 13, 2001

asamlogo3.gif (7559 bytes)DEA: Pain Management In Addiction Medicine

U. S. Department of Justice
Drug Enforcement Administration
Washington, D.C. 20537

March 3, 2000

Howard Heit, M.D., F.A.C.P., F.A.S.A.M.
8316 Arlington Boulevard
Suite 232
Fairfax, Virginia 22031-5216

Dear Dr. Heit:

This is in response to your letter regarding pain management and narcotic addiction treatment.

Pain specialists may treat a chronic pain patient currently enrolled in a narcotic treatment program with narcotics: ~ The Controlled Substances Act does not set standards of medical practice. It is the responsibility of individual practitioners to treat patients according to their professional judgment for a legitimate medical purpose in accordance with generally acceptable medical standards.

As you know, state boards of medical examiners establish standards of medical practice and regulate such practice by doctors and other practitioners in their states. Many states have undertaken actions to develop guidelines for pain treatment. A booklet entitled "Model Guidelines for the Use of Controlled Substances for the Treatment of Pain," is enclosed for your use. You may also wish to contact your state medical authorities or other nationally recognized organizations such as the American Methadone Treatment Association, the American Society for Addiction Medicine, or the American Academy of Pain Medicine.

Although pain specialists may treat a chronic pain patient currently enrolled in a narcotic treatment program, they may only treat the patient's pain. Care of patients fighting substance abuse requires sensitivity to the issue and careful monitoring of outcomes. As a suggestion, you may wish to obtain the patient's permission to coordinate your pain management treatment with his/her narcotic treatment program.

If a practitioner wishes to provide detoxification treatment or maintenance treatment to narcotic dependent persons, a separate registration with the Drug Enforcement Administration (DEA) as a narcotic treatment program is required. A registration as a narcotic treatment program will allow the practitioner to administer or directly dispense, but not prescribe, narcotic drugs. Currently, methadone and levo-alpha-acetyl-methadol (LAAM) are the only controlled substances approved for maintenance and/or detoxification treatment. Buprenorphine, single entity or in combination with Naloxone, has not yet received approval from the U.S. Food and Drug Administration (FDA) and National Institute for Drug Abuse (NIDA) for narcotic addiction treatment.

I hope this information is useful to you. If you have any further questions, please do not hesitate to contact this office at 202-307-7286.


Patricia M. Good, Chief
Liaison and Policy Section
Office of Diversion Control


cc: DPM Kathy Daniels, DPM
Mary Johnson-Rochee, G/S

House of Delegates of the Federation of State Medical Boards: Model Guidelines for the Use of Controlled Substances for the Treatment of Pain
Updated Saturday, January 26, 2002


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