You have spent a lot of time on this. Kudos. I am also an attorney. I am not as well read on this as you–is there a phase in provision? There appears to be two provisions–one is 90 days and another is 18 months. Can you speak to this? Thanks.
The current version of the bill has an effective date of 180 days for all provisions with the exception of the telemedicine regulations.
“(1) IN GENERAL- Except as provided in paragraph (2), the amendments made by this Act shall take effect 180 days after the date of enactment of this Act.”
The telemedicine provisions have a phase in provision:
“(2) DEFINITION OF PRACTICE OF TELEMEDICINE-
(A) IN GENERAL- Until the earlier of 3 months after the date on which regulations are promulgated to carry out section 311(h) of the Controlled Substances Act, as amended by this Act, or 15 months after the date of enactment of this Act–
(i) the definition of the term
Thanks so much for your reply. Wow. That language leaves a lot unknowns as to when this will be effective…sounds like the earliest is three months after regs are promulgated to implement the Act. That is anyone’s guess from what I can see…
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You have spent a lot of time on this. Kudos. I am also an attorney. I am not as well read on this as you–is there a phase in provision? There appears to be two provisions–one is 90 days and another is 18 months. Can you speak to this? Thanks.
MH,
The current version of the bill has an effective date of 180 days for all provisions with the exception of the telemedicine regulations.
“(1) IN GENERAL- Except as provided in paragraph (2), the amendments made by this Act shall take effect 180 days after the date of enactment of this Act.”
The telemedicine provisions have a phase in provision:
“(2) DEFINITION OF PRACTICE OF TELEMEDICINE-
(A) IN GENERAL- Until the earlier of 3 months after the date on which regulations are promulgated to carry out section 311(h) of the Controlled Substances Act, as amended by this Act, or 15 months after the date of enactment of this Act–
(i) the definition of the term
Thanks so much for your reply. Wow. That language leaves a lot unknowns as to when this will be effective…sounds like the earliest is three months after regs are promulgated to implement the Act. That is anyone’s guess from what I can see…
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