March 2023 DEA letter to registered practitioners includes FAQs Substance Abuse and Mental Health Services Administration. 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.

I have retired from active practice and no longer have an office or see patients. Do I need to take the eight-hour MATE Act training course?
It depends. If you decide to maintain the registration of your DEA certificate after your next DEA certificate renewal after June 27, 2023, then yes, you are required to take the 8-hour MATE Act training course.

Do I even need a DEA certificate if I do not prescribe controlled substances?
Technically no. However, many provider agreements with health plans require you to have an active DEA certificate, and some hospitals require you to have one in order to qualify for privileges.

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 a 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 (ACCME) 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 ACCME 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.

Will the DEA or other federal agency audit for compliance of completion of the 8-hour MATE Act training course?
To date, neither the DEA nor any other federal agency has issued any description as to how compliance will be enforced.

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.

If I take the TMA course, how long will TMA keep a record that I took it?
TMA can produce certificates of completion for six (6) years.

How much does the TMA course cost?
The cost of the course is $299. However, you may save $50 by entering the code TN50 upon registration.

If I purchase the TMA course and allow other prescribing staff in my office to attend, can all of them get credit for completing the course?
No, only one certificate of course completion is issued per person. Each prescriber must register individually. That is not TMA’s rule, that is the rule of the body that accredits TMA to offer the course. The ACCME accredits TMA.

I used to have a DEA-X waiver to prescribe MAT. Am I required to take the MATE Act required training course?
No, former DEA-X holders are specifically exempt from having to complete the eight-hour course. You still have to meet your licensing board’s requirement for a two-hour prescribing course every renewal period.

Is the TMA course in-person?
The eight-hour course is modularly designed so you can take it at your own pace online as you have time. You do not need to sit through the entire eight hours in one sitting. We can offer an in-person option, but class size must be a minimum of 100 and the cost is about $400 per person. Contact education@tnmed.org for more information if this option is preferred.

Will the course count towards my maintenance of certification (MoC) for my specialty board?
For 21 boards, yes. For a list of those boards contact Tom Sullivan with CCO at tsullivan@clinicaloptions.com.

Some residents prescribe under a generic or institutional DEA certificate. Do they have to take the eight-hour course?
No. Unless an individual prescriber has to self-register or renew DEA registration, the course is not required. Most residents will also be exempt under the exception for having graduated in good standing from an accredited US (allopathic or osteopathic) medical school, dental school, PA program, or APRN school within the past five years and successfully completed a curriculum that included not less than eight hours of training on treating and managing patients with opioid or other substance use disorders. Underscore accredited US school; the exception does not apply for foreign medical school graduates.

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