MGMA urges DEA to withdraw proposed telehealth rule (March 18, 2025)

March 18, 2025 

The Honorable Derek S. Maltz
Acting Administrator
Drug Enforcement Administration
500 Army Navy Drive
Arlington, VA 22202

Re: Special Registrations for Telemedicine and Limited State Telemedicine Registrations (RIN 1117-AB40)

Dear Acting Administrator Maltz:

The Medical Group Management Association (MGMA) thanks the Drug Enforcement Administration (DEA) for the opportunity to comment on the Special Registration for Telemedicine and Limited State Telemedicine Registrations proposed rule. While we support the DEA’s efforts to establish a special registration to improve the efficiency of prescribing controlled medications under the Ryan Haight Online Pharmacy Consumer Protection Act of 2008 (Ryan Haight Act), the proposed process would unnecessarily impede patient access to telehealth care and add burdensome and unworkable requirements, ultimately undermining the intention of the special registration framework.

With a membership of more than 60,000 medical practice administrators, executives, and leaders, MGMA represents more than 15,000 medical group practices ranging from small private medical practices to large national health systems, representing more than 350,000 physicians. MGMA’s diverse membership uniquely situates us to offer the following policy recommendations.

We appreciate the DEA’s leadership in enforcing controlled substance laws and working over the past few years to expand access to telehealth services. The Ryan Haight Act initially required a patient to have an in-person medical evaluation prior to receiving a prescription for a controlled substance. During the COVID-19 Public Health Emergency (PHE), the DEA instituted critical policy flexibilities to allow practitioners to continue treating patients and prescribing medication through telehealth without an in-person visit. This was a demonstrable success, especially for patients in rural areas and locations with provider shortages. Instead of disrupting care following the end of the COVID-19 PHE, the DEA rightly continued these policies through the end of 2025.

While we understand the need for appropriate protections, MGMA cautions the DEA against moving forward with an overly restrictive and administratively complex special registration process. It is essential to build on the progress made over the last five years and not upend the availability of vital telehealth services.

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