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MATE Act Frequently Asked Questions

 

A federal law passed in December 2022 requires practitioners to complete a one-time education course on treating and managing patients with substance use disorders before applying for, or renewing, their DEA registration. The new training requirement, part of the Medication Access and Training Expansion (MATE) Act, starts June 27, 2023, and applies to all prescribers with a DEA registration, except veterinarians.

On June 1, TMA will make a new course available for all prescribers that fulfills the new DEA education requirement introduced by the MATE Act. The cost is $249. What sets the course apart is its applicability to all Tennessee prescribers.

Not only will it satisfy the DEA’s training requirement, but it will also satisfy the Tennessee licensing boards’ requirement for prescribers to complete a two-hour course on prescribing practices.

TMA recently hosted an All Member Virtual meeting on the topic. Attendees heard from two experts on the course: Tom Sullivan, Senior Vice President of Educational Strategy with Clinical Care Operations, and Yarnell Beatty, TMA Senior Vice President and General Counsel.

Members are encouraged to contact TMA with any questions at legal@tnmed.org.

Upon initial application, or the first renewal of a prescriber’s DEA registration (beginning on June 27, 2023), the prescriber will be asked to attest to having met one of the three requirements for training compliance:

  1. Do you hold a board certification from the American Board of Medical Specialties, the American Board of Addiction Medicine, or the American Osteopathic Association in addiction medicine or addiction psychiatry?
  2. Have you graduated in good standing from an accredited US (allopathic or osteopathic) medical school, dental school, PA program, or APRN school within the past 5 years and successfully completed a curriculum that included not less than 8 hours of training on treating and managing patients with opioid or other substance use disorders?
  3. Have you completed at least 8 hours of training (inclusive or incremental) with respect to the treatment and management of patients with opioid or other substance use disorder. Previous completion of the MAT Waiver Training satisfies this requirement?

If your answer to the above three questions currently stands at “No,” then you will need to complete a course that satisfies the training requirement before you renew your DEA certificate after June 27, 2023. 

TMA is preparing to launch a course that will satisfy the DEA’s training requirement and satisfy your Tennessee licensing board’s requirement to complete a two-hour course on prescribing practices. The course will be available June 1.

It is important to understand the differences between Tennessee licensure board requirements for prescriber continuing education and federal law MATE Act requirements for DEA registration.

Questions About the Eight-Hour MATE Act Training Course

How long do I have to complete this required eight-hour MATE Act training course?
The deadline for satisfying this new training requirement is the date of your next scheduled DEA registration submission—whether it is an initial registration or a renewal registration, that occurs on or after June 27, 2023. This one-time training requirement affirmation will not be a part of future registration renewals.

I do not write any prescriptions for controlled substances and do not even have a DEA license. Do I have to take the eight-hour MATE Act training course?
No. The requirement to take the course is only tied to an initial DEA registration or the first DEA registration renewal that occurs after June 27, 2023.

What makes TMA’s MATE Act training course different from others offering such courses?
TMA partnered with COO to create a course that meets the DEA's MATE Act training course requirements as well as the two-hour Tennessee-specific course on prescribing practices required by your licensing board for license renewal.

I am not a TMA member or a physician but would like to take TMA’s course. May I?
Yes.

I am dentist with a Tennessee dental license, will this course work for me?
Yes, the DEA did not specify that the training had to be specific to a profession; therefore, TMA’s course would be acceptable for any licensed health professional with a Tennessee license.

What would happen if I were to renew my DEA certificate on or after June 27, 2023, but not have taken the MATE Act training course?
Beginning on June 27, 2023, practitioners will be required to check a box on their online DEA registration form—regardless of whether a registrant is completing their initial registration application or renewing their registration—affirming that they have completed the new training requirement. 21 USC 843(d) states that any person who knowingly or intentionally furnishes false or fraudulent information in the application is subject to a term of imprisonment of not more than 4 years, and a fine under Title 18 of not more than $250,000, or both.

Once I have completed the eight-hour MATE Act training course, do I have to report this to my state licensing board?
No.

Will TMA’s eight-hour MATE Act training course count towards my licensing board’s continuing education requirement?
Yes. If you take the TMA course, completion of it will count toward your licensing board’s two-hour Tennessee-specific prescribing course requirement.

Will the two-hour Tennessee-specific prescribing course count towards compliance with the eight-hour MATE Act training course?
Yes.

How many years can I go back and use previously completed CME courses in order to meet the eight-hour MATE Act training course requirement?
The March 2023 DEA letter from DEA Acting Assistant Administrator Thomas Prevoznik states:

Past trainings on the treatment and management of patients with opioid or other substance use disorders can count towards a practitioner meeting this requirement. In other words, if you received a relevant training from one of the groups listed below— prior to the enactment of this new training obligation on December 29, 2022—that training counts towards the eight-hour requirement.

  • The American Society of Addiction Medicine (ASAM)
  • The American Academy of Addiction Psychiatry (AAAP)
  • American Medical Association (AMA)
  • The American Osteopathic Association (AOA), or any organizations accredited by the AOA to provide continuing medical education
  • The American Dental Association (ADA)
  • The American Association of Oral and Maxillofacial Surgeons (AAOMS)
  • The American Psychiatric Association (APA) 
  • The American Association of Nurse Practitioners (AANP) 
  • The American Academy of Physician Associates (AAPA)
  • The American Nurses Credentialing Center (ANCC)
  • Any other organization accredited by the Accreditation Council for Continuing Medical Education (AACCME) or the Commission for Continuing Education Provider Recognition (CCEPR), whether directly or through an organization accredited by a State medical society that is recognized by the ACCME or CCEPR Note: TMA is accredited by the AACCME and our CME will count since we are accredited.
  • Any other organization approved or accredited by the Assistant Secretary for Mental Health and Substance Use, the ACCME, or the CCEPR

The letter does not set a date back to which a course must have been taken. Should the DEA issue any guidance, TMA will update this FAQ. TMA cautions you, however, that you should maintain documentation of compliance. If you no longer have documentation of compliance from these sources, TMA strongly urges you only to count hours which can be documented should the DEA audit you for compliance.

I had a DEA-X registration at the time of the repeal of this waiver so I have previously taken the course to obtain a waiver. Am I required to take the eight-hour MATE Act training course?
No. You must have the documentation from this training. If you do not have the documentation to prove you’ve taken the required CME, you will have to take another eight hours.

Do I have to sit through eight straight hours of training?
The March 2023 DEA letter from DEA Acting Assistant Administrator Thomas Prevoznik states that training does not have to occur in one session. It can be cumulative across multiple sessions that equal eight hours of relevant training. TMA’s course is designed to be taken in multiple sessions or all at once.

I have taken two-hour continuing education courses on prescribing practices for my Tennessee license renewal requirement during the last several license renewal cycles. Can I just count the last four courses equaling eight hours and be in compliance with the MATE Act?
To date, no guidance has been issued by the DEA or any other federal agency. For now, TMA does not believe that counting the same course over several years will be considered in compliance. TMA will advise members if/when such guidance is issued.

Am I required to send proof of compliance to the DEA that I have completed the eight-hour MATE Act training course?
No. If the DEA requires you to prove completion of the course, follow instructions given to you by the DEA for submission of proof. Preserve a copy for your records.

How long should I maintain documentation of my completion of the eight-hour MATE Act training course?
To date, no guidance has been issued by the DEA or any other federal agency. TMA will advise members when such guidance is issued. TMA advises that prescribers maintain such documentation until guidance is issued. You should also keep a digital copy of your documentation in a secure location (i.e. a computer back-up, safety deposit box) in the event your paper copy is destroyed. If you lose your documentation you will not be able to prove that you obtained the required CME and might be considered in violation of the law.

What if I lose my proof of compliance of my completion of the eight-hour MATE Act training course?
If you take the TMA course, TMA will retain the documentation for up to six years.

 

Other Resources on the Eight-Hour MATE Act Training Course

• March 2023 DEA letter to registered practitioners includes FAQs

• Substance Abuse and Mental Health Services Administration

 

Questions About the Two-Hour Tennessee-Specific Prescribing Practices Course

I’m not exactly sure of my license renewal date. How do I find it?
You can find the expiration date on the Licensure Verification website for the Tennessee Department of Health. Click here to look it up.

Are there any exemptions to the requirement for the two-hour course related to proper prescribing?
Tennessee law (T.C.A. § 63-1-402) requires all DEA-registered practitioners to take this course. Unless they are:

  1. A veterinarian; or
  2. Board certified by the American Board of Medical Specialties (ABMS), or American Osteopathic Association (AOA), or the American Board of Physician Specialties (ABPS) in one (1) or more of the following specialties or subspecialties:
    1. Pain Management;
    2. Pain management;
    3. Anesthesiology;
    4. Physical medicine and rehabilitation;
    5. Neurology; or
    6. Rheumatology

Will the two-hour Tennessee-specific prescribing course count towards compliance with the eight-hour MATE Act training course?
Yes.

 

Other Resources on the Two-Hour Tennessee-Specific Prescribing Practices Course

• Tennessee Board of Medical Examiners (BME) CME FAQs

• Tennessee Board of Osteopathic Examination CME FAQs

 

About the MATE Act

On Dec. 29, the Consolidated Appropriations Act of 2023 enacted a new one-time, eight-hour training requirement for all Drug Enforcement Administration (DEA)-registered practitioners on the treatment and management of patients with opioid or other substance use disorders. Click here to review more information from the DEA.