March 29, 2023

Updated April 3, 2023

As previously shared with state component and society leadership on Tuesday, APMA has heard from numerous members regarding the recently released guidance about the updated one-time training requirements for any Drug Enforcement Administration (DEA)-registered practitioners on the treatment and management of patients with opioid or other substance use disorders, called the Medication Access and Training Expansion Act, or MATE Act.

APMA had been monitoring the MATE Act when it was originally introduced in the 117th Congress last year. The progress of the stand-alone bill stalled and was not expected to advance, and then it unfortunately was included as a last-minute addition to the end-of-year Omnibus package passed late in December 2022, before APMA had an opportunity to engage and address it. We will be sending information directly to members tomorrow and creating a resource page to provide some clarity on the requirements as well as how and when they apply to our members.

In the meantime, APMA wants to stress that these training requirements are effective on June 27, 2023, for an applicant’s initial registration application or a practitioner renewing their registration. The deadline for satisfying this new training requirement is the date of a practitioner’s next scheduled DEA registration submission—regardless of whether it is an initial registration or a renewal registration—on or after June 27, 2023. This means that if, for example, a member’s DEA license is not due for renewal until January 1, 2024, they have until January 1, 2024, to complete the eight hours of training.

APMA is working to clarify the oversight that the Council on Podiatric Medical Education (CPME) was not included in the initial list of approved accrediting organizations, as well as APMA’s own exclusion from the approved list of accredited groups that may provide trainings that meet this new requirement. APMA intends to correct these oversights in the coming weeks. APMA Legislative Advocacy staff has set a meeting with Rep. Lori Trahan’s (MA) staff on April 11 to discuss APMA's request for a technical correction.

APMA is also working to clarify what previous trainings a DPM may have received recently might apply, given the FAQ in this letter sent to DEA-registered practitioners on March 27, 2023:

"Past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement. In other words, if you received a relevant training from one of the groups listed below— prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement."

APMA recognizes this onerous new requirement has taken members by surprise and is equally disturbed by the apparent lack of inclusion or recognition of DPMs as physicians in the related informational documents. We will provide updates as they are available. In the meantime, if you have concerns or questions, please contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.