Licensure Requirements for Telemedicine Prescribing of Controlled Substances

Core Licensure Requirements

• The American Academy of Child and Adolescent Psychiatry states that full licensure in the state where the patient is located is required for prescribing controlled substances via telemedicine, regardless of the prescriber's location 1, 2
• Licensure is required in the state where the patient is receiving the intervention, not where the patient resides, according to the American Academy of Child and Adolescent Psychiatry 1, 3
• Full licensure in both states (the prescriber's state and the patient's state) is usually required when providing cross-state telemedicine services, as recommended by the American Academy of Child and Adolescent Psychiatry 1, 3

Federal Controlled Substance Restrictions

• The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 requires at least one in-person evaluation before prescribing controlled substances (including Adderall) via telemedicine, as stated by the American Academy of Child and Adolescent Psychiatry 1, 2, 3
• The DEA has stated it does not intend to interfere with legitimate telemedicine prescribing of controlled substances, but has not finalized promised regulations since 2008, according to the American Academy of Child and Adolescent Psychiatry 1, 3

Limited Exceptions and Alternatives

• Several states offer limited licensure specific to providing services through telemedicine, which are usually obtained more quickly than full licenses but have scope restrictions, as reported by the American Academy of Child and Adolescent Psychiatry 1, 3
• The Interstate Medical Licensure Compact allows for streamlined multi-state licensure, with 18 states adopting the compact as of 2017, according to the American Academy of Child and Adolescent Psychiatry 1, 3

Critical Action Steps Before Prescribing

• The American Academy of Child and Adolescent Psychiatry recommends consulting the patient's state medical board guidelines and laws before initiating telepsychiatry services involving controlled substances 4, 2
• Reviewing DEA regulations, particularly the Office of Diversion Control guidelines regarding telemedicine, is crucial before prescribing controlled substances via telemedicine, as stated by the American Academy of Child and Adolescent Psychiatry 4, 2, 5

Practical Recommendation

• The American Academy of Child and Adolescent Psychiatry recommends obtaining full licensure in the patient's state before prescribing Adderall or any controlled substance as the safest and most legally compliant approach 1, 2, 3