Last week, Secretary Milgram and Commissioner Califf released a letter regarding the stimulant shortage. I appreciate that this is a complex issue requiring interagency coordination to protect public health and safety. However, I am troubled by the letter’s tepid, responsibility-avoiding, and clinically misinformed message. At a minimum, I wonder who is advising the DEA and FDA’s decision-making and communication?
While absolute prescription numbers have increased, this does not inherently reflect overprescription. Let’s address the core factors:
- Remote work created new challenges for individuals with ADHD formerly coping pre-pandemic, increasing treatment needs.
- Telehealth improved care access, particularly for those who struggle with complex in-person visits. Easier access enabled appropriate diagnosis and treatment.
- No diagnostic method is perfect. We should minimize false results while recognizing they occur. There is no evidence of rising prevalence rates of inappropriate use or public harm. Some false positives do not indicate worsening public health approaches. Most research shows telehealth’s benefits for behavioral healthcare access.
- The IQVIA study only shows increased prescribing, not causes. Inferring causes without consulting experts would be premature. Antidepressant growth patterns are similar, without FDA concerns.
- Have supply chain factors been explored with pharmaceutical companies? The report shows companies used just 70% of DEA quotas. What does this indicate for inventory? It is promising the FDA/DEA identified a pharma-level issue. What solutions are being discussed? What dialogue is had?
Ultimately, patients are impacted. ADHD is not benign; treatment works remarkably well. It would be tragic to lose sight of solutions while passing responsibility. I ask that you take this seriously and work toward constructive solutions.
