Adding MAT to an IOP: buprenorphine, naltrexone and OTP partners

The short answer

An IOP adds MAT by deciding who prescribes and where the medication comes from. Since December 29, 2022, any practitioner with a current DEA registration that includes Schedule III can prescribe buprenorphine for opioid use disorder where state law allows, with no X-waiver and no patient cap. So most outpatient programs pick one of three models: their own prescriber (often the medical director or a psychiatric nurse practitioner) prescribes buprenorphine or naltrexone that clients fill at a pharmacy; a partner prescriber does it under a referral and consent; or an opioid treatment program provides methadone or buprenorphine while the client attends your groups. Whichever you pick, write it into policy, admit clients who take these medications, and keep naloxone on site.

What changed when the X-waiver ended

• No waiver, no cap. Section 1262 of the Consolidated Appropriations Act, 2023 (the MAT Act) removed the federal requirement to file a Notice of Intent to prescribe buprenorphine for opioid use disorder. A standard DEA registration with Schedule III authority is enough, and there's no longer a limit on how many patients a prescriber may treat (SAMHSA, the MAT Act).
• Old "X" numbers don't matter. Prescriptions need only the prescriber's standard DEA number. If your policy manual, prescriber agreement or credential checklist still asks for a DATA waiver, update it.
• A one-time training attestation. Section 1263 (the MATE Act) requires practitioners to complete at least 8 hours of training on substance use disorders, attested once on a new DEA application or the next renewal since June 2023. Prescribers board-certified in addiction medicine or addiction psychiatry are deemed to meet it (American Academy of Pediatrics summary of the MATE Act).
• State law still applies. The federal change didn't override state rules on who can prescribe and how. In Texas, that means the prescription monitoring program check and the nurse practitioner delegation rules below.
• The old prescriber locator is gone. SAMHSA says it's decommissioning the waiver notification system from June 1, 2026, and individual buprenorphine prescribers are no longer searchable on FindTreatment.gov; treatment facilities stay listed. If you referred clients by searching that list, build your own list of local prescribers instead.

Three ways to offer MAT

We set this up as a step called "plan access to medication for addiction treatment" on every Texas SUD program roadmap, right after the medical director is chosen. The choice drives your staffing, your policies and what a surveyor will look for.

Model	How it works	What you need	Watch for
1. Your own prescriber	The medical director, a psychiatrist or a psychiatric NP evaluates the client and prescribes buprenorphine or naltrexone; the client fills it at a pharmacy	A prescriber with a Texas license and a Texas DEA registration; for an NP, a prescriptive authority agreement; PMP access; e-prescribing	Coverage when the prescriber is away; who bills the visits; induction protocol and follow-up schedule
2. Partner prescriber	A local addiction physician, primary care clinic or telehealth prescriber manages the medication; you provide counseling and groups	A written referral pathway, a Part 2 consent to share information, and a named contact at the partner	No referral fees or anything of value either way; delays between your admission and their first visit
3. Opioid treatment program (OTP)	The client gets methadone or buprenorphine at an OTP and attends your IOP	A coordination agreement with the OTP, consents, and a plan for dosing times that don't clash with group	Methadone for opioid use disorder can only come from an OTP; your program can't dispense it

Many programs combine them: their own prescriber for buprenorphine and naltrexone, and a coordination agreement with the nearest OTP for clients on methadone. For the full picture of prescriber staffing, see psychiatric services in an IOP.

The medications at a glance

Medication	Used for	Who can provide it	For the program
Buprenorphine (alone or with naloxone; film, tablet or long-acting injection)	Opioid use disorder	Any practitioner with a DEA registration covering Schedule III, where state law allows; also OTPs	Expect it on drug screens; check the Texas PMP before prescribing; storing it on site brings DEA and count rules
Methadone	Opioid use disorder	Only an opioid treatment program certified under 42 CFR Part 8; in Texas, an HHSC-licensed narcotic treatment program	Coordinate with the OTP; never require a client to taper as a condition of admission
Naltrexone (daily tablet or monthly injection)	Opioid use disorder and alcohol use disorder	Any licensed prescriber; it isn't a controlled substance	The client must be off opioids before starting; plan the hand-off from detox
Acamprosate, disulfiram	Alcohol use disorder	Any licensed prescriber; not controlled substances	Often overlooked; offer the conversation to every client with alcohol use disorder

Methadone programs are their own license. HHSC regulates narcotic treatment programs under Texas Health and Safety Code chapter 466 and 25 TAC chapter 229, subchapter J, alongside the federal OTP rules (HHSC, narcotic treatment programs). SAMHSA's 2024 rewrite of 42 CFR Part 8 made the pandemic-era take-home and telehealth flexibilities for OTPs permanent; it took effect April 2, 2024, with compliance required by October 2, 2024 (Federal Register). An IOP that wants to dispense methadone itself is opening a second program, not adding a service.

Setting up the prescriber

• A DEA registration in Texas. The prescriber needs a DEA registration for Texas with Schedule III authority, and storing or dispensing controlled substances at your site needs a registration for that address. If the prescriber is registered at another clinic and will only prescribe at yours, confirm with the DEA whether a second registration is required. Register through DEA Diversion Control; our roadmap budgets $888 for three years, but check the current fee when you apply. Texas ended its separate state controlled-substance registration in 2016, so the DEA registration is the one you need.
• The Texas PMP check. Texas prescribers must check the prescription monitoring program before prescribing opioids, benzodiazepines, barbiturates or carisoprodol (Health and Safety Code 481.0764). Buprenorphine is an opioid, so the check applies to every prescription. Build it into the prescriber's visit template.
• Nurse practitioners. A Texas APRN prescribes under a prescriptive authority agreement with a physician (Occupations Code chapter 157). Schedules III to V can be delegated, which covers buprenorphine; Schedule II is limited to settings such as hospital facility-based practice and hospice. The details are in our guide to opening a psychiatric NP practice in Texas.
• Telehealth. A DEA rule that took effect December 31, 2025 lets a clinician prescribe buprenorphine for opioid use disorder by telemedicine, including audio-only, for up to six months before an in-person evaluation is needed. Separately, DEA and HHS extended the broader telemedicine flexibilities for controlled substances through December 31, 2026 (Federal Register, fourth temporary extension; Pew summary). Check the rule in force before you build a telehealth-only model for 2027.
• Credential file and agreement. Texas license, DEA registration, MATE attestation, malpractice, exclusion checks every month, and a written agreement at fair market value for hours actually worked. Our staff credential file checklist lists every page.

Keeping medication on site, or not

The simplest model, and the one in the policy template we write for programs that don't run a medication room, is that the program keeps no medication except naloxone. Clients fill prescriptions at a pharmacy and keep their own medication at home. That avoids most of the storage, count and staffing rules.

If you will store or give medications, Texas rules for licensed chemical dependency treatment facilities (26 TAC chapter 564, subchapter J) apply, as of the March 2025 text we reviewed:

• Written procedures for storage, administration, documentation, inventory and disposal, and staff who give medication must be credentialed and trained (§564.1001).
• Locked storage that only authorized staff can reach; clients may keep their own medication only with written authorization from the program director; refrigerated medications kept apart from food (§564.1002).
• Counts: stored Schedule II, III and IV medications are inspected and counted at least daily, and any difference between the administration record and the count is explained in a signed note (§564.1003).
• Administration of prescription medication only by nurses and other staff legally authorized to give it (§564.1004).
• A DEA registration for the site if controlled substances such as buprenorphine are stored there, and disposal through DEA-compliant methods.

Read the current text of 26 TAC chapter 564 before you decide, and see our walk-through of 26 TAC 564 requirements for the rest of the chapter.

Don't turn clients away: the ADA

The U.S. Department of Justice's 2022 guidance explains that the Americans with Disabilities Act protects people with opioid use disorder who are in treatment or recovery, including people who take medication for it under a health professional's care, in health care settings among others (ADA.gov, opioid use disorder). Taking prescribed medication isn't "current illegal drug use."

In practice, the policy we write says:

• The program admits and treats people taking methadone, buprenorphine or naltrexone. Refusing someone because they take prescribed MOUD may be disability discrimination; confirm the wording with counsel.
• Staff never pressure a client to stop or taper a prescribed medication. A taper is the prescriber's decision with the client.
• Prescribed medications are expected to show on drug screens and are never treated as a violation (see our drug testing policy guide).
• "MAT-friendly" isn't a marketing line; it should be true at admissions, in group, and in your referral partners.

Building MAT into the clinical program

• At intake: the medication list is reconciled, and the assessment asks about past and current MOUD, overdose history and interest in medication. The admissions coordinator knows the answer to "do you take clients on Suboxone?" (yes).
• In the treatment plan: medication is a plan intervention like any other, with the prescriber named and how you'll coordinate.
• In group: our IOP group curriculum has a week-4 session on medications in recovery, facts and myths, with "questions to bring to the prescriber" as the skill.
• Coordination: with the client's written 42 CFR Part 2 consent, staff share relevant changes with the prescriber or OTP and plan for missed doses and travel. Our 42 CFR Part 2 guide covers the consent wording.
• At discharge: the aftercare plan continues any MOUD without a gap, names the next prescriber and appointment, and covers overdose risk. See discharge planning for an IOP.

Naloxone and the overdose plan

Every program that treats substance use should be ready for an overdose at any moment, whether or not it prescribes. From the medication policy in the kit we build programs on:

• Naloxone kept in marked, unlocked places staff can reach in under a minute, and checked monthly for expiration on the safety rounds.
• Every staff member trained at hire and every year, with a quarterly practice using a training device.
• The response, posted: check for response; call 911 and send someone for the naloxone and AED; give naloxone as the package directs; rescue breaths or CPR if not breathing normally; a second dose if there's no response in 2 to 3 minutes; recovery position and stay until responders arrive, because naloxone can wear off before the opioid does; incident report the same day.
• Overdose education, and naloxone in hand, for every client who returns to use and at discharge, since tolerance drops after a period of not using.

Launch checklist

1. Choose the model (own prescriber, partner, OTP, or a mix) and write it into the program description.
2. Confirm the prescriber's Texas license, Texas DEA registration (and one for your address if anything controlled is stored there), MATE attestation and PMP access.
3. For an NP, sign the prescriptive authority agreement and set the physician's chart review.
4. Decide whether any medication is kept on site; if yes, meet 26 TAC 564 subchapter J and the DEA rules first.
5. Write the induction and follow-up protocol with the medical director, including how often the prescriber sees clients.
6. Sign coordination agreements with the nearest OTP and partner prescribers, with no money changing hands for referrals.
7. Update the medication, admission, drug testing and discharge policies with the MOUD language.
8. Add the Part 2 consent for the prescriber or OTP to the intake packet.
9. Stock naloxone, train staff, and add it to the monthly safety check.
10. Confirm with each payer how prescriber visits are billed alongside your per diem, and credential the prescriber.

Adding MAT to a program that's already open? Consulting by the hour is $175 per hour, or book a free 30-minute call. Clinicians opening their own prescribing practice should see the Prescriber Practice Launch.

Questions

Do you still need an X-waiver to prescribe Suboxone?

No. Since December 29, 2022, a DEA registration with Schedule III authority is enough to prescribe buprenorphine for opioid use disorder, where state law allows, with no patient limit. Prescribers attest once to 8 hours of substance use disorder training on their DEA application or renewal.

Can an IOP prescribe buprenorphine?

The program doesn't prescribe; its prescriber does. A physician, or a nurse practitioner under a prescriptive authority agreement, with a Texas DEA registration can evaluate clients and prescribe buprenorphine that clients fill at a pharmacy. Storing or giving it on site adds Texas medication rules and DEA requirements.

Can our IOP require clients to come off methadone or Suboxone?

Don't. DOJ guidance says the ADA protects people taking prescribed medication for opioid use disorder, and refusing or discharging them for taking it may be discrimination. Tapering is a decision for the client and prescriber.

Can a nurse practitioner prescribe buprenorphine in Texas?

Yes, if the APRN has a DEA registration and a prescriptive authority agreement that delegates Schedule III prescribing. The Texas PMP must be checked before each prescription, as for any opioid.

Can buprenorphine be prescribed by telehealth in Texas?

Under a DEA rule in effect since December 31, 2025, buprenorphine for opioid use disorder can be prescribed by telemedicine, including audio-only, for up to six months before an in-person evaluation. The broader telemedicine flexibilities run through December 31, 2026. Check the DEA's current rule and Texas telemedicine law before relying on either.

Does MAT change how we bill the IOP?

The program's per diem (for example H0015 for SUD IOP) covers the program's services; the prescriber's visits are usually separate professional services under the prescriber's NPI. Each payer decides what's bundled, so read each contract. Our IOP and PHP billing codes guide lists the program codes.

Sources

• SAMHSA, Waiver elimination (MAT Act), including the 2026 decommissioning of the waiver notification system
• American Academy of Pediatrics, The Medication Access and Training Expansion (MATE) Act
• DEA and HHS, Fourth temporary extension of telemedicine flexibilities (Federal Register, December 31, 2025); Pew, telehealth buprenorphine rule
• SAMHSA, Medications for the Treatment of Opioid Use Disorder, 42 CFR Part 8 final rule (2024)
• Texas HHSC, narcotic treatment programs; Texas Health and Safety Code chapter 466 and chapter 481 (section 481.0764, PMP checks)
• Texas Occupations Code chapter 157 (prescriptive authority agreements)
• 26 TAC chapter 564, subchapter J (medication): Cornell LII (text current through March 2025 when reviewed)
• U.S. Department of Justice, The ADA and opioid use disorder (2022)
• DEA Diversion Control Division; eCFR, 42 CFR Part 2