Unintended Impact on Hospice Community: DEA Proposed Production Quotas for Schedule II Controlled Substances

Submit your comments to the DEA on the Proposed CII Production Quotas for 2019 by September 19, 2018

The United States Drug Enforcement Administration (DEA) recently released its proposed production quotas for Schedule II Controlled Substances (CIIs) for 2019. The announcement shows the DEA intends to continue to cut the quotas for production of CIIs DEA affecting hospice iconthat are critical for the care of hospice patients – namely fentanyl, hydromorphone and morphine.

As you are well aware, the hospice community continues to struggle with a shortage of parenteral opioids and liquid morphine.

Enclara Pharmacia believes further cuts to production quotas are unwarranted in light of the challenges hospice and palliative care providers are currently facing.

We also contend that any cuts to the quotas should follow a cost-benefit analysis that weighs patient care needs against the potential reduction in diversion risk. Enclara has not seen any evidence that demonstrates cuts to production quotas reduces the risk of opioid diversion or misuse, so once again we believe these cuts are not warranted.

The DEA’s proposal invites members of the public to submit comments. Enclara submitted our comments to the DEA and a copy of our letter can be found here.

We encourage the hospice community to comment as well. It is important for the DEA to hear from the hospice community on the potential negative impact of these reduced production quotas.

Comments should be submitted by September 19, 2018 to the following:

Uttam Dhillon
Acting Administrator
Drug Enforcement Administration
Attention: DEA Federal Register Representative/DRW
8701 Morrissette Avenue
Springfield, VA 22152

Enclara Pharmacia is committed to advocating for the hospice community with the needs of caregivers and patients in mind. Contact Enclara Pharmacia with any questions on this proposal or if you would like assistance in submitting your comments to the DEA. Together, we can have an impact.