On March 18, 2025, the National Alliance for Care at Home submitted comments to the Drug Enforcement Administration (DEA) in response to its proposed rule, Special Registrations for Telemedicine and Limited State Telemedicine Registrations.

(See our prior Alliance Daily article covering the proposed rule in greater detail.)

While supporting DEA’s goals to prevent drug diversion, the Alliance expressed strong concerns that the proposed rule would significantly hinder timely access to necessary controlled medications for hospice and palliative care patients. In comments submitted to the DEA, the Alliance emphasized that subjecting hospice practitioners to in-person medical evaluation requirements under the Ryan Haight Act would disastrously upend decades of successful hospice care delivery and urged the DEA to, among other things, to explicitly exclude these practitioners to eliminate any confusion, and to revise the proposed rule to ensure it clearly aligns with legislative intent, protect vulnerable patients, and prevent any disruptions in care.

The proposed rule received almost 42,000 comments — including a number from Alliance members — a significant increase over the 2023 DEA telemedicine rule, which received slightl over 35,000 comments.

We thank our members for their contributions and engagement in crafting these recommendations, as their invaluable feedback and frontline experiences significantly informed our comments.