R Street Letter to MD Governor Wes Moore in Support of MD HB 838 and SB 562: Pharmacist Prescribing of MOUDs
April 15, 2026
The Honorable Westley Moore
Governor of Maryland
State House
100 State Circle
Annapolis, MD 21401
Re: R Street Institute’s Support for House Bill 838 and Senate Bill 562
My name is Stacey McKenna and I am a resident senior fellow and associate director in Healthier Communities at the R Street Institute. R Street is a nonprofit, nonpartisan public policy research organization focused on solving complex public policy challenges, including opioid use disorder (OUD), through free markets and limited, effective government.
OUD is complicated and people’s journeys are rarely linear. Consequently, successful recovery for many people means having access to a comprehensive continuum of evidence-based, individualized treatment options, including low-barrier access to medications for opioid use disorder (MOUD).[1] It’s for this reason we support for House Bill 838 and Senate Bill 562, which would help overcome the many structural barriers hindering such access by reducing unnecessary overregulation.[2] By increasing medication availability it will become easier for individuals with OUD to get the care they deserve and need to begin and remain in recovery.
Maryland has already demonstrated its commitment to treating OUD by employing pragmatic policy that expands access to a range of interventions, from evidence-based treatment in jails to life-saving strategies like point-of-service drug checking.[3] Thanks to this approach, drug overdoses in the state have fallen every year for the past four years, and hit a 10-year low in 2025.[4] This is commendable work that has had a measurable impact saving lives and improving health. However, Maryland and the rest of the United States remain submerged in an overdose crisis. Last year, despite the dramatic improvements, 1,315 people still died of a drug overdose.[5] Estimates suggest that between 30,000 and 100,000 Maryland residents are living with an OUD, many undiagnosed or unable to access treatment.[6]
OUD and overdose affect our communities as a whole: More than 40 percent of people in the United States now know someone who has died of a drug overdose.[7] In addition to the emotional costs associated with losing a loved one or watching a friend struggle with addiction, each case of OUD costs Maryland $1.4 million annually in criminal justice and healthcare expenses, lost productivity and more.[8]
Buprenorphine is an FDA-approved MOUD and one of the most effective treatments for OUD, reducing the health, economic and even social harms associated with problematic opioid use.[9] Because buprenorphine binds to the same receptors in the brain as opioids such as heroin and fentanyl but activates them differently, it prevents withdrawal symptoms and reduces cravings.[10] People taking buprenorphine are less likely to use illicit drugs or engage in criminal activity, and are approximately 60 percent less likely to overdose.[11] Compared to non-medication treatment, people taking buprenorphine or other MOUD are more likely to remain in recovery long-term and build healthy, productive lives in their communities.[12]
Despite these benefits, buprenorphine has long been overregulated in the United States, leading to a dearth of prescribers.[13] In December 2022, Congress passed the Mainstreaming Addiction Treatment (MAT) Act, which reduced barriers for healthcare providers to prescribe buprenorphine and expanded permissions to pharmacists operating in collaboration with clinicians.[14] More recently, the “SUPPORT for Patients And Communities Reauthorization Act of 2025” authorized accredited continuing education for pharmacists wanting to prescribe buprenorphine.[15] HB 838 and SB 562 capitalize on the opportunity provided by these critical reforms to federal law by developing a framework in which Maryland pharmacists appropriately registered with the Drug Enforcement Administration can prescribe this life-saving and life-changing medication.
Pharmacists have historically played an important role in healthcare, not just dispensing, but also prescribing a range of medications in many states, including contraception, overdose reversal medications and drugs to prevent HIV.[16] With roughly 1,000 pharmacies in the state of Maryland, expanding pharmacists’ scope of practice to allow them to prescribe buprenorphine would dramatically increase the state’s pool of potential buprenorphine prescribers.[17] At least 10 states currently allow pharmacists to prescribe buprenorphine under collaborative practice agreements—as HB 838 and SB 562 would do—and two states allow pharmacists to independently prescribe the medication.[18]
Expanding access to buprenorphine via pharmacist prescribing has been shown to improve outcomes for people with an OUD, leading to better medication management and patient care.[19] In a study of a Veterans Affairs pharmacist prescribing program, 90-day treatment retention was 86.9 percent.[20] In addition, authorizing pharmacist prescribing of buprenorphine can lower the cost of care, making it more accessible to uninsured and underinsured individuals as well as reducing the burden on taxpayers when patients are covered by public healthcare.[21]
Furthermore, expanding access to buprenorphine is safe for communities. Diversion—when prescription drugs are distributed or accessed outside of formal medical channels—of buprenorphine and other MOUD is rare, and when it does happen, it is typically for therapeutic purposes.[22] For example, individuals may use diverted buprenorphine to stem their use of illicit opioids, avoid withdrawal symptoms or self-medicate when treatment is unavailable.[23] Therefore, when there is insufficient OUD treatment access in a community relative to need, buprenorphine diversion does sometimes increase; however, even those rare increases actually reduce overdose rates because buprenorphine is far safer than illicit opioids.[24] By the same logic, expanding buprenorphine access through pharmacy prescribing is unlikely to increase diversion because it would greatly increase and simplify formal treatment access. It could lead to less diversion if it connects enough people to formal treatment channels to reduce the need for self-medication.[25]
This approach is accepted by the medical community, both among the clinicians who have typically been responsible for prescribing MOUD and by pharmacists.[26] The American Pharmacists Association has been an active advocate for expanding the role of pharmacists in fighting the overdose crisis.[27] This support for the scope of practice expansion suggests that HB 838 and SB 562 would be feasible and uptake would be strong, increasing the likelihood of having a real impact on Maryland communities.
By expanding access and reducing barriers to evidence-based treatment for OUD through pharmacist prescribing of buprenorphine, HB 838 and SB 562 would prepare Maryland to continue its fight against the overdose crisis. It would save lives, improve people’s health and well-being, increase community safety and reduce costs to taxpayers. Therefore, we urge you to sign HB 838 and SB 562.
Thank you for your time and consideration.
Best regards,
Stacey McKenna, PhD
Resident Senior Fellow and Associate Director
Healthier Communities
R Street Institute
(970) 443-8063
smckenna@rstreet.org
Cc: Jeremy Baker, Chief Legislative Officer, Office of Governor Westley Moore
Myles Hicks, Deputy Legislative Officer, Office of Governor Westley Moore
[1] The ASAM National Practice Guideline for the Treatment of Opioid Use Disorder: 2020 Focused Update, American Society of Addiction Medicine, 2020. https://www.asam.org/quality-care/clinical-guidelines/national-practice-guideline.
[2] Ibid.
[3] Lindsey Culli, “Maryland’s State-Mandated Opioid Treatment in Jails Helps Recovery, But Implementation Gaps Remain,” Department of Health Policy and Management, Johns Hopkins Bloomberg School of Public Health, May 8, 2025. https://publichealth.jhu.edu/2025/marylands-state-mandated-opioid-treatment-in-jails-helps-recovery-but-implementation-gaps-remain; Rapid Analysis of Drugs (RAD), The Overdose Response Program, Maryland Department of Health, Nov. 24, 2025. https://health.maryland.gov/pha/NALOXONE/Pages/RAD.aspx.
[4] “Governor Moore Announces Maryland Overdose Deaths Falling for Fourth Straight Year, Reaching 10-Year Low,” The Office of Governor Wes Moore, press release, Jan. 30, 2026. https://governor.maryland.gov/news/press/pages/Governor-Moore-Announces-Maryland-Overdose-Deaths-Falling-for-Fourth-Straight-Year,-Reaching-10-Year-Low.aspx; Scott Maucione, “Maryland sees steep drop in opioid overdose deaths,” WYPR, Feb. 5, 2025. https://www.wypr.org/wypr-news/2025-02-05/maryland-sees-steep-drop-in-opioid-overdose-deaths.
[5] “Governor Moore Announces Maryland Overdose Deaths Falling for Fourth Straight Year, Reaching 10-Year Low.” https://governor.maryland.gov/news/press/pages/Governor-Moore-Announces-Maryland-Overdose-Deaths-Falling-for-Fourth-Straight-Year,-Reaching-10-Year-Low.aspx.
[6] Opioid Tracker, 2025: Maryland, FAIR Health. 2025. https://s3.amazonaws.com/media2.fairhealth.org/infographic/asset/Opioid-2024/Maryland.pdf; “Health Insurance Coverage of the Total Population,” KFF, 2024. https://www.kff.org/state-health-policy-data/state-indicator/total-population/?dataView=1¤tTimeframe=0&sortModel=%7B%22colId%22:%22Location%22,%22sort%22:%22asc%22%7D; Deborah Dowell et al., “Treatment for Opioid Use Disorder: Population Estimates – United States, 2022,” Morbidity and Mortality Weekly Report, 73:25 (June 27, 2024), pp. 567-574. https://www.cdc.gov/mmwr/volumes/73/wr/mm7325a1.htm.
[7] Alison Athey et al., “An Overlooked Emergency: More Than One in Eight US Adults Have Had Their Lives Disrupted by Drug Overdose Deaths,” American Journal of Public Health, 114: 3 (March 2024). https://www.rand.org/pubs/external_publications/EP70412.html.
[8] Rylee Wilson, “The cost of opioid use disorder, by state,” Becker’s Behavioral Health, May 21, 2025. https://www.beckersbehavioralhealth.com/behavioral-health-public-health/the-cost-of-opioid-use-disorder-by-state.
[9] “Information about Medications for Opioid Use Disorder,” U.S. Food and Drug Administration. Dec. 26, 2024. https://www.fda.gov/drugs/information-drug-class/information-about-medications-opioid-use-disorder-moud.
[10] Buprenorphine, Substance Abuse and Mental Health Services Administration, Dec. 23, 2025. https://www.samhsa.gov/substance-use/treatment/options/buprenorphine.
[11] Hillary Samples et al., “Buprenorphine After Nonfatal Opioid Overdose: Reduced Mortality Risk in Medicare Disability Beneficiaries,” American Journal of Preventive Medicine, 65: 1 (July 2023). https://pubmed.ncbi.nlm.nih.gov/36906496; Elizabeth A. Evans et al., “Recidivism and mortality after in-jail buprenorphine treatment for opioid use disorder,” Drug and Alcohol Dependence, (Feb. 1, 2022). https://pubmed.ncbi.nlm.nih.gov/35063323; Rachna Kumar et al., Buprenorphine, StatPearls Publishing, National Library of Medicine, National Institutes of Health, January 2025. https://www.ncbi.nlm.nih.gov/books/NBK459126.
[12] Ibid.
[13] “Expanding Access to Buprenorphine,” Maryland Addiction Consultation Service. Accessed Feb. 26, 2026. https://health.maryland.gov/pdmp/Documents/Clinical%20Docs/X-Waiver%20Update.pdf.
[14] Jennifer Athay Adams et al., “Opportunities for pharmacist prescriptive authority of buprenorphine following passage of the Mainstreaming Addiction Treatment (MAT) Act,” Journal of the American Pharmacists Association, 63:5, September-October 2023. https://www.sciencedirect.com/science/article/abs/pii/S1544319123001681.
[15] PR Newswire, “APhA secures key congressional win allowing pharmacists to prescribe buprenorphine with specialized training,” Yahoo Finance, Dec. 2, 2025. https://finance.yahoo.com/news/apha-secures-key-congressional-win-193900778.html?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2xlLmNvbS8&guce_referrer_sig=AQAAAAV5jAlXBTmpzjr3ADvmq7utLV9OeqGJqEWEOKxZ6lwphculAkoJHVLv6qfNMLr-wsql0b__z6UsCQ6VVQix7SYFcP3C5DNQpaHA7Vzu6A9BBR3Oqtu2gcSJeoPl5k5jsN96ScYU-S7o8LJx55OQ2wO_fZK-V2KVobhH8DImBhL5.
[16] Stacey McKenna, “Helping Health Providers Become Harm Reduction Advocates,” R Street Institute Policy Study No. 267, Oct. 26, 2022. https://www.rstreet.org/research/helping-health-care-providers-become-harm-reduction-advocates; Chelsea Boyd, “Harm Reduction at the Pharmacy,” R Street Institute Policy Short No. 115, July 20, 2022. https://www.rstreet.org/research/harm-reduction-at-the-pharmacy.
[17] C.P. Peters, “Table 1: Number of Retail and Independent Pharmacies, by State, March 2007,” Medicaid Payment for Generic Drugs: Achieving Savings and Access, Issue Brief No. 839, National Health Policy Forum, Sep. 30, 2010. https://www.ncbi.nlm.nih.gov/books/NBK560328/table/ib839.tab1;
[18] Jennifer Athay Adams et al., “Opportunities for pharmacist prescriptive authority of buprenorphine following passage of the Mainstream Addiction Treatment (MAT) Act,” Journal of the American Pharmacists Association, (September-October 2023). https://www.sciencedirect.com/science/article/abs/pii/S1544319123001681.
[19] Ibid. Jacob D. Baylis et al., “Clinical pharmacist practitioners prescribing of buprenorphine for opioid use disorder,” Drug and Alcohol Dependence, 271 (June 2025). https://www.sciencedirect.com/science/article/abs/pii/S0376871625001164.
[20] Baylis et al.
[21] Ibid.
[22] Theodore J. Cicero, et al., “Understanding the use of diverted buprenorphine,” Drug and Alcohol Dependence, 193 (Dec. 1, 2018). https://www.sciencedirect.com/science/article/pii/S0376871618307245.
[23] Ibid.
[24] Joëlla W. Adams et al., “Examining buprenorphine diversion through a harm reduction lens: an agent-based modeling study,” Harm Reduction Journal, 20:150 (Oct. 17, 2023). https://link.springer.com/article/10.1186/s12954-023-00888-6.
[25] Stacey McKenna, “Better Access to MOUD Reduces Diversion,” R Street Institute Analysis, Feb. 11, 2026. https://www.rstreet.org/commentary/better-access-to-moud-reduces-diversion.
[26] Miguel Lopez et al., “Evaluating practitioner attitudes toward pharmacist clinician prescribing of buprenorphine for the treatment of opioid use disorder,” Journal of the American College of Clinical Pharmacy, 8:7 (Apr. 11, 2025). https://accpjournals.onlinelibrary.wiley.com/doi/abs/10.1002/jac5.70031.
[27] PR Newswire. https://finance.yahoo.com/news/apha-secures-key-congressional-win-193900778.html?guccounter=1&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2xlLmNvbS8&guce_referrer_sig=AQAAAAV5jAlXBTmpzjr3ADvmq7utLV9OeqGJqEWEOKxZ6lwphculAkoJHVLv6qfNMLr-wsql0b__z6UsCQ6VVQix7SYFcP3C5DNQpaHA7Vzu6A9BBR3Oqtu2gcSJeoPl5k5jsN96ScYU-S7o8LJx55OQ2wO_fZK-V2KVobhH8DImBhL5.