Legal
Controlled Substances Policy
Last reviewed August 14, 2026
Effective August 14, 2026 · Last updated August 14, 2026
1. Our Approach
Bloom360, Inc. (“Bloom360,” “Company,” “we,” “us,” or “our”) provides technology, administrative, and operational support to Bloom360 Medical PLLC and its affiliated professional medical entities (the “Practice”). The Practice employs or contracts with licensed healthcare professionals (“Providers”) who deliver medical care and exercise independent clinical judgment. Bloom360, Inc. does not practice medicine. Bloom360, Inc. does not employ Providers in the practice of medicine, does not own or control any prescription, and receives no compensation tied to whether or what a Provider prescribes.
Bloom360 is a preventive primary care platform focused on proactive, whole-person health. While our clinical model emphasizes prevention and long-term wellness, the Practice's Providers may prescribe controlled substances in limited circumstances where clinically appropriate, subject to applicable federal and state laws and regulations. Prescribing decisions are made exclusively by licensed healthcare professionals. Bloom360, Inc. does not direct or influence those decisions. A prescription is never guaranteed, and not all medications can be prescribed via telehealth.
We'd rather over-explain this part than have you find out mid-visit: controlled substance prescribing in telehealth is one of the most heavily regulated areas of medicine, and our Providers take that seriously. This policy explains how the Practice approaches controlled substances, what the regulatory landscape looks like, and what to do if you need help managing a medication we can't prescribe through our platform.
This policy is general information about how we operate. It is not medical advice, and it does not create any right to a particular medication.
2. What Is a Controlled Substance
A controlled substance is a drug or medication whose manufacture, possession, and use is regulated by the U.S. government under the Controlled Substances Act (CSA).
The Drug Enforcement Administration (DEA) classifies controlled substances into five schedules based on their accepted medical use, potential for abuse, and likelihood of causing dependence:
- Schedule I: High potential for abuse, no currently accepted medical use in the United States (e.g., heroin, LSD, ecstasy).
- Schedule II: High potential for abuse, accepted medical use with severe restrictions, may lead to severe physical or psychological dependence (e.g., oxycodone, fentanyl, Adderall, Ritalin).
- Schedule III: Moderate to low potential for physical and psychological dependence (e.g., testosterone, ketamine, Tylenol with codeine).
- Schedule IV: Low potential for abuse and dependence (e.g., Xanax, Valium, Ambien, tramadol).
- Schedule V: Lower potential for abuse, contain limited quantities of certain narcotics (e.g., cough preparations with less than 200 mg of codeine per 100 mL, Lyrica).
3. How We Approach Controlled Substance Prescribing
The Practice's Providers may prescribe controlled substances in limited, clinically appropriate circumstances. This is not a routine part of our care model. Our focus is prevention and primary care, but we recognize that some patients have legitimate medical needs that involve scheduled medications.
When a Provider considers prescribing a controlled substance, the following principles apply:
- Clinical appropriateness comes first. Providers will only prescribe a controlled substance when it is clinically indicated, supported by the patient's medical history, and consistent with accepted standards of care. A request alone is never sufficient justification.
- Federal and state law governs what is possible. Whether a controlled substance can be prescribed via telehealth depends on the specific medication, the patient's state of residence, and current federal regulations. Some substances cannot be prescribed through a telehealth platform regardless of clinical appropriateness.
- Monitoring and follow-up may be required. Controlled substance prescribing often requires ongoing monitoring, prescription drug monitoring program (PDMP) checks, and documented clinical follow-up. Providers will communicate any such requirements clearly.
- A prescription is never guaranteed. Bloom360 does not guarantee that any particular medication will be prescribed. All prescribing decisions rest solely with the treating Provider.
What we do not prescribe through the platform
If you are currently taking a controlled substance prescribed by another healthcare provider, that is perfectly fine. The Practice's Providers can work alongside your existing prescriber to coordinate your overall health plan. In many cases, it may be most appropriate to continue that relationship for controlled substance management while your Bloom360 Provider focuses on your broader preventive care.
4. Common Controlled Substance Categories
The following is a non-exhaustive list of DEA-scheduled controlled substances that may require additional clinical evaluation, ongoing monitoring, or may not be appropriate for prescribing via telehealth depending on applicable federal and state law. This list is for informational purposes and does not mean these medications are categorically unavailable through the Practice. It means they require careful clinical consideration. Where a category appears in the list above of what we do not prescribe, that limit controls.
- Pain medications and opioids: Oxycodone (OxyContin, Percocet), hydrocodone (Vicodin, Norco), morphine, codeine, tramadol (Ultram), fentanyl (Duragesic), hydromorphone (Dilaudid), methadone (when used for pain or opioid use disorder), buprenorphine (Suboxone, Subutex)
- Anxiety and sedative medications, benzodiazepines: Alprazolam (Xanax), lorazepam (Ativan), clonazepam (Klonopin), diazepam (Valium), temazepam (Restoril), midazolam (Versed)
- Sleep medications: Zolpidem (Ambien), eszopiclone (Lunesta), zaleplon (Sonata), suvorexant (Belsomra)
- ADHD and stimulant medications: Amphetamine/dextroamphetamine (Adderall), methylphenidate (Ritalin, Concerta), lisdexamfetamine (Vyvanse), dextroamphetamine (Dexedrine), modafinil (Provigil), armodafinil (Nuvigil)
- Weight loss medications (DEA-scheduled): Phentermine (Adipex-P, Lomaira), phentermine/topiramate (Qsymia), diethylpropion (Tenuate), benzphetamine (Didrex)
- Other controlled substances: Pregabalin (Lyrica), butalbital combinations (Fioricet, Fiorinal), carisoprodol (Soma), testosterone (a Schedule III controlled substance under federal law), medical cannabis and marijuana products (Schedule I under federal law regardless of state legalization)
GLP-1 medications such as semaglutide and tirzepatide are not controlled substances and are not governed by this policy.
5. Non-Controlled Medications Prescribed With Extra Caution
Some medications are not classified as controlled substances by the DEA but may have abuse potential, significant side effects, or require special monitoring. The Practice's Providers may prescribe these medications on a case-by-case basis with appropriate clinical oversight:
- Gabapentin (Neurontin): Used for nerve pain and seizures. While not federally scheduled, some states classify gabapentin as a controlled substance due to abuse potential.
- Pseudoephedrine (Sudafed): An over-the-counter decongestant that is regulated due to its use in the manufacture of methamphetamine. Available without prescription but tracked at point of sale.
- Promethazine (Phenergan): An antihistamine and antiemetic that may be prescribed with caution due to sedative effects and abuse potential when combined with other substances.
- Clonidine (Catapres): Used for blood pressure management and sometimes prescribed off-label for ADHD or anxiety. Requires careful monitoring for blood pressure effects.
- Muscle relaxants: Certain muscle relaxants (e.g., cyclobenzaprine, methocarbamol) may be prescribed with appropriate monitoring and for limited durations.
6. Regulatory Framework
The Practice's approach to controlled substance prescribing is governed by a layered set of federal and state requirements. Here is what you should know:
- Controlled Substances Act (CSA): The federal law that establishes the framework for regulating controlled substances in the United States, including scheduling, manufacturing, distribution, and dispensing. All prescribing by the Practice's Providers must comply with CSA requirements.
- Ryan Haight Online Pharmacy Consumer Protection Act: Federal law generally requires at least one in-person medical evaluation before a controlled substance may be prescribed via telemedicine. Temporary flexibilities enacted during the COVID-19 public health emergency have allowed certain controlled substances to be prescribed via telehealth without a prior in-person visit — but these flexibilities are time-limited.
- Telemedicine Prescribing Flexibilities, Important Notice: Federal rules currently permitting controlled substances to be prescribed via telemedicine without a prior in-person examination are in effect on a temporary basis and are scheduled to expire on December 31, 2026. This is the fourth such temporary extension, issued jointly by DEA and HHS on December 31, 2025. If those rules change or expire without extension, the Practice's prescribing practices for controlled substances via telehealth will change accordingly, and some medications that are currently available through our platform may no longer be. We will update this policy if and when that happens, but we want to be transparent about this now.
- DEA Regulations: The DEA enforces regulations related to the prescribing, dispensing, and record-keeping of controlled substances. DEA-registered Providers must comply with all applicable federal and state requirements, including prescription drug monitoring program (PDMP) obligations. All controlled substance prescriptions are transmitted electronically to the pharmacy you choose. Bloom360 does not dispense, stock, ship, or mail medications of any kind.
- State Laws: Individual states may impose additional restrictions on the prescribing of controlled substances via telehealth, including requirements for in-person evaluations, PDMP checks, and quantity or duration limitations. The rules vary meaningfully by state. What is permissible for a patient in one state may not be permissible for a patient in another. Any state-specific terms that apply to you are set out in the state addendum to your Telehealth Informed Consent.
The Practice's approach to controlled substance prescribing reflects both clinical judgment and the realities of this complex, evolving regulatory landscape. Our goal is to deliver responsible care that is fully compliant with applicable law, not to find workarounds.
7. What We Ask of You
If a Provider does prescribe a controlled substance for you, a few things are non-negotiable. They protect you first and us second.
- One prescriber. Tell us about every controlled substance you are taking and who prescribes it. Do not seek the same or a similar medication from more than one prescriber at the same time.
- We will check the PDMP. By requesting a controlled substance, you agree that your Provider may review your state prescription drug monitoring program records, which in Michigan is MAPS, before and during treatment.
- No early refills or replacements. We do not replace lost, stolen, or damaged prescriptions, and we do not fill early.
- Your medication is yours alone. Sharing, selling, or otherwise diverting a controlled substance is a crime, and it ends the relationship.
- We may require more. A Provider may condition continued prescribing on a treatment agreement, periodic check-ins, urine drug testing, or an in-person evaluation.
- We can stop. The Practice may decline or discontinue controlled substance prescribing at any time for clinical, legal, or safety reasons. If we do, we will tell you why, help you avoid an abrupt discontinuation where that would be unsafe, and help you find alternative care.
8. If You Need a Controlled Substance
If you have a medical condition that requires a controlled substance, here is how we recommend approaching it:
- Talk to your Provider. If you believe a controlled substance may be clinically appropriate for your condition, raise it with your Bloom360 Provider. They will evaluate your situation and let you know what is and isn't possible through our platform given your clinical needs and applicable law.
- Continue with your existing prescriber. If you currently receive a controlled substance from another healthcare provider, continue that relationship. The Practice's Providers can coordinate with your existing prescriber to ensure integrated, consistent care across your health plan.
- Seek an in-person evaluation when appropriate. Many controlled substances, particularly those for pain management, mental health, and addiction treatment, are best managed through an in-person clinical relationship with appropriate monitoring. Your Bloom360 Provider can help you understand when an in-person evaluation is the right next step.
- Request a referral. The Practice's Providers can refer you to an appropriate specialist or in-person provider who can manage your controlled substance needs. Let your Provider know, and our care coordinator can assist with finding resources in your area.
9. If You Are Struggling With a Medication
Dependence is a medical condition, not a character flaw, and telling us about it will never get you dropped as a member. Talk to your care team. We will help you find the right kind of care, and we will not judge you for asking.
- 988 Suicide and Crisis Lifeline: call or text 988.
- SAMHSA National Helpline: 1-800-662-HELP (4357), free and confidential, 24/7.
- Emergency: call 911 or go to the nearest emergency room.
10. Changes to This Policy
This is a fast-moving area of law, and this policy will change with it. When we make material changes, we will post the updated policy with a new effective date and may notify members through the platform or by email. The version and date at the top of this page tell you which policy is currently in effect.
11. Contact Us
If you have questions about this Controlled Substances Policy or need guidance on managing your medications, please contact us:
- Email: care@bloom360.com
- Phone: (833) 348-3044
- Mail: Bloom360, Inc., Attn: Patient Services, 4444 2nd Ave Ste 30674, Detroit, MI 48201