ECHO Idaho X-Waiver Training Information
ECHO Idaho is partnering with the Providers Clinical Support System (PCSS), led by the American Academy of Addiction Psychiatry and a large coalition of national professional organizations, including DATA 2000 organizations, the American Psychiatric Association and the American Osteopathic Academy of Addiction Medicine, to provide free X-waiver trainings.
In this two-part training, participants take a live (in person or via Zoom videoconferencing) four-hour training through ECHO Idaho and complete a four-hour online self-study portion through PCSS. Once both portions of the training are completed, eligible providers can apply for their DATA 2000 Waiver to prescribe and dispense opioid dependency medications to more than 30 patients.
Definition of "Provider"
For this, “providers” are physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, and certified nurse midwives.
Per the HHS guidance effective on April 28, 2021, providers no longer need additional training to apply for the X-waiver to treat up to 30 patients. However, providers must still apply for the waiver before prescribing buprenorphine for opioid use disorder.
All information about additional training in this document refers to providers applying for the X-waiver to treat more than 30 patients.
Live Portion Training Logistics
- The training is done in a half-live and half-online format.
- Four hours of the training are live. You can join this portion via videoconferencing (Zoom) from a computer or smartphone. You must have a webcam turned on and focused on you for the entire training so we can verify your attendance.
- Four hours of the training are an online self-study portion you complete on your own schedule. At the end of the online modules, you must pass an exam with 75% or higher and complete a survey from PCSS in order to receive your certificate of completion.
- The live portion of the training is four hours. The online modules are expected to take about four hours (self-paced). Providers are eligible to apply for their X-waiver to treat more than 30 patients after meeting this eight-hour training requirement.
- Physician assistants (PAs) and advanced practice registered nurses (APRNs - NP/CNM/CNS/CRNA) must complete 16 additional hours of online training. APRNs and PAs do not have to take the trainings in any particular order. However, they both must complete 24 hours of specialized training (the eight-hour ECHO Idaho/PCSS training plus a 16-hour training).
- See PCSS for more information and to access FAQs relating to the eight-hour and 24-hour requirements, or contact firstname.lastname@example.org for assistance.
- If you miss any part of the live training, you are not yet eligible to apply for the waiver to treat more than 30 patients.
- The training is free through PCSS and ECHO Idaho.
- The additional 16-hour X-waiver courses for PAs and APRNs are also offered at no cost.
- Yes, you must register at least 24 hours ahead of the training.
- Complete the RSVP form. You will receive an email confirmation once your registration is received.
- Email email@example.com or call 208-364-4569 to let the event coordinator know you are unable to attend. Then, watch our website for the next training date!
- Join via videoconference and webcam using Zoom from a computer or smartphone. If you are new to Zoom, contact us at firstname.lastname@example.org or 208-364-4569 and we will assist you.
- Yes! You are eligible to earn the X-waiver through this training. NPs, CNMs, CRNAs, CNSs, and PAs must complete 24 hours of specialized training before applying for their waiver. The Half and Half X-Waiver Training offered through ECHO counts toward the eight-hour requirement.
- You must also complete a 16-hour course specific to your credential. The eight-hour and 16-hour trainings can be taken in any order.
- Medical residents and PA/APRN students can complete the X-waiver training at any point in their studies. Once you complete the eight-hour training, you will receive a certificate of completion that does not expire.
- Residents and students are eligible to apply for their waiver after they have their DEA number and an unrestricted medical license. With this additional training, residents will be able to apply to treat up to 100 patients.
- Yes! We welcome everyone who wants to audit the training for their own professional development, even those who are not eligible or interested in earning their X-waiver. Pharmacists, counselors, and health educators working in clinics where medications for opioid use disorder are dispensed have audited past trainings.
- Additionally, providers who already have their X-waiver are welcome to attend this training, especially if they are interested in increasing their patient limit from 30 to 100.
- After you register for the training, you will receive a confirmation email from ECHO Idaho. This email contains information about accessing the online portion of the training.
- Yes. Anyone who registers for the live training will receive the link to access the online modules.
- You are encouraged to complete the online modules and pass the exam within 90 days after the live training. If you prefer, you may complete the online modules prior to the live training.
Continuing Education (CE and CME) Credit Information
- Your CME certificate will be available in eeds, our online training CE platform, within 48-72 hours after the live training. Instructions on how to access your certificate can be found here.
- Note: Partial CE credit will be awarded in 0.25 increments for the live portion of the training.
- Once you complete both the live and online trainings, you may access your certificate of completion for the full eight-hour training in the online learning platform.
- Note: Partial CE credit will not be awarded for the online portion.
- Yes, you are able to receive CE commensurate to the extent of your participation in the live portion (partial credit available in 0.25 increments). The online portion provides four hours of CE, but all components of the training must be completed in order to be awarded credit. Partial credit will not be awarded for the online training.
Applying for the X-Waiver
Providers that are waiver eligible include:
- Physician (MD, DO)
- Advanced Practice Registered Nurse (APRN: NP, CNS, CRNA, CNM)
- Physician Assistant (PA)
- Before you begin, make sure you have your DEA number and state medical license.
- Go to the Buprenorphine Waiver Notification page (NOI) and answer all the questions.
- Physicians should select “Other” in “CERTIFICATION OR QUALIFYING CRITERA” and then enter “practice guidelines” in the text box for the city of the training.
- Mid-level practitioners will need to enter “practice guidelines” in the text box for the date of training.
- Once SAMHSA has reviewed your NOI, the process may take up to 45 days for approval. If approved, you will receive notification via email.
- For more information, contact the SAMHSA Center for Substance Abuse Treatment’s Buprenorphine Information Center at 866-287-2728, or email email@example.com.
- Yes. To qualify for the waiver to treat more than 30 patients, APRNs and PAs must complete a total of 24 hours of training. This means that in addition to the eight hours earned through the ECHO Idaho/PCSS X-waiver training, you need an additional 16 hours of training. There are many ways to complete the additional 16 hours of training, including free online opportunities at PCSS or through the American Society of Addiction Medicine.
- No, your certificate of completion does not expire. You can apply for the waiver any time after you receive your certificate of completion.
- If you have completed the live portion of the training, the online modules and the post-module exams and do not see your certificate of completion in your online learning platform account, complete this request form.
- Before you begin, make sure you have your DEA number, state medical license number and your training certificate of completion.
- Go to the Buprenorphine Waiver Notification page and answer all of the questions.
- AAAP is considered the accrediting agency.
- For the date of completion, you will put the date of the live (ECHO) portion of the X-waiver training.
- After you complete the waiver notification, you will email your training completion certificate to firstname.lastname@example.org (as directed on the waiver notification home screen) and to email@example.com (as directed by PCSS).
- Once SAMHSA has received all of your documentation, the process may take up to 45 days for review and approval. You will receive notification via email if approved.
- For more information, contact the SAMHSA Center for Substance Abuse Treatment’s Buprenorphine Information Center at 866-287-2728 or email firstname.lastname@example.org.
- Note: One year of treating up to 30 patients is required before you can apply to treat up to 100 patients, unless you hold certain board certifications as discussed below.
- If approved, you will receive a letter via email from email@example.com with the subject line “Buprenorphine Information Center/Waiver Notification Information” that confirms your waiver and includes your prescribing identification number. DEA regulations require this number to be included on all buprenorphine for opioid use disorder.
- While possible, we do not recommend it. As stated on the SAMHSA website, “To receive permission to provide treatment while a notification is under review, check the box ‘New Notification, with the intent to immediately facilitate treatment of an individual (one) patient’ on the notification form. Checking the ‘immediate’ box is only one of three requirements a practitioner must meet in order to start a patient on treatment, and immediate treatment is limited to one patient per form submitted. Each form must have a different submission date. Other requirements the applicant must address include:
- Meeting ‘in good faith’ the criteria for obtaining a waiver such as having a valid medical license, valid Drug Enforcement Administration (DEA) registration, qualified or completion of eight hours of qualifying training.
- Contacting CSAT's Buprenorphine Information Center at 866-BUP-CSAT (866-287-2728) to verify that the notification form has been received and to notify CSAT of the practitioner’s intent to begin treating one patient.
- Since the practitioner will not have a unique identifying number, pharmacists may question prescriptions received under this provision. Pharmacists may contact SAMHSA, if additional information is needed, at 866-BUP-CSAT (866-287-2728) or by sending an email to firstname.lastname@example.org.
General X-Waiver Information
Yes. The X-waiver is commonly known by several names:
- Bupe (Buprenorphine) waiver
- DATA (Drug Addiction Treatment Act) waiver
- X-waiver (for the X that will be added to your DEA license when you receive the waiver)
- DATA 2000 waiver (named as such because 2000 is the year the Act was passed)
- MAT waiver: MAT stands for Medication for Addiction Treatment, previously known as Medication Assisted Treatment
- You can treat up to 30 patients the first year you have your waiver, even if you have not taken additional training.
- Time spent treating patients under the training exemption does not qualify practitioners to apply for the higher patient limit.
- After one year, you can apply for a patient limit increase by using the buprenorphine waiver notification form to treat up to 100 patients if you have already completed the additional X-waiver training. If you have not yet taken the additional training, you must do so before applying to treat up to 100 patients.
- After you hold the 100-patient waiver for one year, you can apply for a 275-patient waiver with the buprenorphine waiver notification form if you have additional credentialing or work in a qualified practice setting. More specific information on board certifications and qualified practice settings can be found in question two of this FAQ document from the American Society of Addiction Medicine (ASAM).
- Do not prescribe to the higher patient limit until you receive SAMHSA approval.
“Certain board certifications” include a board certification in addiction medicine or addiction psychiatry by the American Board of Addiction Medicine, the American Board of Medical Specialties or the American Society of Addiction Medicine.
As defined by SAMHSA, a qualified practice setting is a setting that:
- Provides professional coverage for patient medical emergencies during hours when the practice is closed;
- Provides access to case management services for patients, including referral and follow-up services for programs that provide or financially support medical, behavioral, social, housing, employment, educational or other related services;
- Uses health information technology if it is already required in the practice setting;
- Is registered for their state prescription drug monitoring program where operational and in accordance with federal and state law; and
- Accepts third-party payment for some services, though not necessarily for buprenorphine-related services and not necessarily all third-party payers.
- You must complete the buprenorphine waiver notification form to apply for an increase to your patient limit. There are no additional training requirements to apply for a patient limit increase unless you are applying for a patient limit increase from 30 to 100 and have not already completed the additional training.
- Time spent treating patients under the training exemption does not qualify practitioners to apply for the higher patient limit.
- After you complete the form, you will receive a confirmation email that your request has been received. You must reply to this email to complete the submission process, and you will receive a second notification submission acknowledgement in an email.
- You must submit an annual report to SAMHSA, which is due before the anniversary of your waiver renewal date. If SAMHSA does not receive this report, your 275-patient limit is automatically rescinded to the 100-patient level. You must also coordinate with anyone beyond the 100-patient limit to direct him or her to a new treatment resource because of your reduced patient capacity.
- You must practice according to nationally recognized evidence-based guidelines and have a diversion control plan. Additional information can be found on the ASAM website.
- PAs and APRNs are required to be supervised by, or work in collaboration with, a DEA registered physician if required by State law to work in collaboration with, or under the supervision of, a physician when prescribing medications for the treatment of opioid use disorder.
- This requirement does not apply to practitioners who are employees or contractors of a department or agency of the United States acting within the scope of such employment or contract.
- Only prescribers approved to treat 275 patients must renew their waiver. To renew the patient limit increase after the three-year approval term, practitioners must submit a renewal request, which includes the same information that is required for an initial patient limit increase request. The renewal request must be submitted at least 90 days before the expiration of the previous approval term. If SAMHSA does not reach a final decision on the renewal request before the expiration of the previous approval term, the approval term will be extended until SAMHSA reaches a final decision.
- Yes, SAMHSA reserves the right to deny a waiver renewal for prescribers approved to treat 275 patients. In the event of a renewal, you must stop prescribing buprenorphine immediately; there is no grace period for the transfer of patients.
- Patients receiving any formulation of buprenorphine for treatment of an opioid use disorder, including implantable and injectable buprenorphine, count toward the patient limit. These patients can be in different locations.
- No. The buprenorphine waiver is federal and just gives you a second DEA number that starts with an X.
- According to the Idaho State Board of Medicine, merely seeking treatment for OUD is not a basis to report. Providers need to report either themselves or other providers (MD, DO or PA) only if they believe there has been a violation of the Medical Practice Act. (A provider with OUD still seeing patients is not necessarily a violation of the Medical Practice Act.) If a provider believes that their OUD causes them to be unable to provide safe patient care or care that does not meet the community standard of care, then that provider must report him or herself to the Board. Failure to do so may lead to further discipline for the failure to report. Please note that the Board has a Disabled Physician Act within its Practice Act that gives the Board a non-disciplinary way to work with physicians or PAs who are disabled by their substance use issues. Similarly, if a licensee becomes aware that another licensee is unable to provide safe care, meet the community standard of care or has otherwise violated the Medical Practice Act, then that licensee has a duty to report that other licensee to the Board or possibly be disciplined for failure to do so despite knowing of the Practice Act violation. For more information, contact the Idaho State Board of Medicine.
- ECHO Idaho sessions on Opioids, Pain and Substance Use Disorders and Medications for Opioid Use Disorder (MOUD) Office Hours provide a wealth of information and real-time connection to other clinicians and providers across Idaho. You can also find recordings of past sessions and a list of ongoing resources.
- PCSS provides a mentoring program, which includes a discussion forum, one-on-one mentoring and the ability to ask a clinical question.
- Up-to-date prescriber numbers can be found at suboxone.com and samhsa.gov. It is possible that a provider has their X-waiver but is not listed on either website.
- As of September 16, 2019, Idaho had 437 X-waivered providers, but it is unclear how many use their waiver.
- 356 can treat up to 30 patients
- 244 MD/DO
- 79 APRN
- 33 PA
- 66 can treat up to 100 patients
- 45 MD/DO
- 19 APRN
- 2 PA
- 15 can treat up to 275 patients
- 15 MD/DO
- Additional X-waiver information can be found on the SAMHSA website.
- If you have questions about accessing the online portion of the PCSS X-Waiver Half and Half Waiver Training or retrieving your certificate, please email email@example.com.
- Ask us! Please email your question to firstname.lastname@example.org or call 208-364-4569.
ECHO Idaho is led by the University of Idaho, WWAMI Medical Education Program. Its X-Waiver Training program is made possible (in part) by grant no. 1H79TI081968 from SAMHSA. The views expressed in written conference materials or publications and by speakers and moderators do not necessarily reflect the official policies of the Department of Health and Human Services; nor does mention of trade names, commercial practices, or organizations imply endorsement by the U.S. Government.