Dear Distinguished Member of the Kentucky General Assembly,
I am a resident of Kentucky writing to share my deep concerns about the Kentucky Board of Medical Licensure’s (KBML) proposed changes to buprenorphine regulations for treating opioid use disorder.
These rules retain and increase unnecessary, burdensome, and stigmatizing barriers to treatment that could put lives at risk in the middle of an overdose crisis.
I respectfully ask that the General Assembly exercise its oversight role and continue to urge the KBML to revise or repeal these regulations. Some of the most troubling provisions include:
- Excessively Frequent Visits: Mandating visits — every 10 days for the first month, every 14 days the second month, and monthly for two years — fails to consider individual patient needs. This rigid schedule creates serious obstacles for Kentuckians with jobs, caregiving duties, or limited access to transportation — making it harder for people to stay in treatment.
- Mandatory Counseling Requirements: Tying medication access to counseling or 12-step participation is not supported by clinical evidence. While counseling can help some, requiring it for all patients creates unnecessary hurdles and discourages people from starting or staying in care.
- Overly Frequent Drug Testing: Weekly or monthly drug testing far exceeds what’s required for other forms of treatment like methadone and adds cost, logistical strain, and stigma — without improving outcomes.
- Inadequate Dosing Limits: Capping initiation doses at 4mg and daily doses at 16mg is out of step with best practices and could increase the risk of relapse or overdose. Clinicians need flexibility to treat patients based on their medical needs.
- Punitive Responses to “Non-Compliance”: Increasing appointments or drug testing as punishment for missed doses or positive tests can backfire — pushing people away from treatment rather than supporting their recovery.
As a Kentuckian, I urge you to stand up for evidence-based care and advocate for regulations that prioritize patient health, dignity, and access. Kentucky is in the midst of an overdose crisis, and we cannot afford policies that make it harder — not easier — for people to get the care they need.
Thank you for your time and service to our community.