Civil Unrest Q&A Offsite Dosing Option

Drug Enforcement Administration
Diversion Control Division
Civil Unrest Emergency Guidance Document
Title: Civil Unrest Q&A Narcotic Treatment Program Offsite Dosing Options
Question: Our Narcotic Treatment Program (NTP) is located in an area of civil unrest and
clients are unable to get to the clinic for dosing. 	What are our options for dosing at alternate
locations?
Answer: 	While not necessarily an exhaustive list, the following are a few suggested options for
providing doses to NTP patients during civil unrest:
1. 	An NTP may coordinate with another NTP for guest dosing. 	To do so, the NTP may
refer patients to another NTP for dosing.
2. 	At this time, under the COVID-19 public health emergency, DEA is permitting NTPs to
repeatedly use the same alternate location to deliver take-home methadone doses to their
patients without separately registering that location with DEA. Off-site location delivery
of methadone is only available for patients who are authorized to take home doses of
methadone to use on their own and is not available for patients who must have individual
doses of methadone administered or dispensed directly to them by the OTP each day. For
additional information please see the DEA guidance document on registered NTPs
dispensing methadone during the public health emergency. 	DEA is also permitting
NTPs to regularly use the same off-site location to deliver take-home buprenorphine
doses to their patients without separately registering that location with DEA during the
public health emergency. For additional information on providing take-home
buprenorphine doses, please see the DEA guidance document on registered NTPs
dispensing buprenorphine. 	The delivery of take-home methadone and buprenorphine
doses through off-site unregistered locations is subject to the conditions and limitations
described in the DEA guidance documents at the links above.
3. 	An NTP may also authorize an NTP staff member, law enforcement officer, or National
Guard personnel to make doorstop deliveries of take-home doses of methadone or
buprenorphine in an approved lock-box, as allowed by another exception granted by
DEA during this public health emergency. Please see the letter announcing this exception
on DEA’s website. Delivery of take-home doses in this manner is subject to the
conditions and limitations described in that letter.
Your state’s opioid treatment authority may impose additional requirements; please consult with
your state’s opioid treatment authority to ensure your actions are compliant with both state and
federal law. Please contact your local DEA Field Office for assistance with any of these
activities.

Guidance documents, like this document, are not binding and lack the force and effect of law,
unless expressly authorized by statute or expressly incorporated into a contract, grant, or
cooperative agreement. Consistent with Executive Order 13891 and the Office of Management
and Budget implementing memoranda, the Department will not cite, use, or rely on any guidance
document that is not accessible through the Department’s guidance portal, or similar guidance
portals for other Executive Branch departments and agencies, except to establish historical
facts. To the extent any guidance document sets out voluntary standards (e.g., recommended
practices), compliance with those standards is voluntary, and noncompliance will not result in
enforcement action. Guidance documents may be rescinded or modified in the Department’s
complete discretion, consistent with applicable laws.
EO-DEA163, June 9, 2020