TRICARE; Removal of the Prohibition to Use Addictive Drugs in the Maintenance Treatment of Substance Dependence in TRICARE Beneficiaries
2012-01-03 2012-02-14 2012-01-03 2012-01-03 2012-01-10 2012-02-27 2012-02-14 2012-02-22 2012-01-17 2012-02-27
DOD-2011-HA-0085-0002 DOD-2011-HA-0085-0017 DOD-2011-HA-0085-0003 DOD-2011-HA-0085-0004 DOD-2011-HA-0085-0007 DOD-2011-HA-0085-0026 DOD-2011-HA-0085-0015 DOD-2011-HA-0085-0019 DOD-2011-HA-0085-0011 DOD-2011-HA-0085-0023
05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00
https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0002 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0017 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0003 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0004 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0007 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0026 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0015 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0019 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0011 https://api.regulations.gov/v4/comments/DOD-2011-HA-0085-0023
Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous Anonymous
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Dear Sir/Maam,Please note my strong support FOR the proposed rule change.  The exclusion of maintenance therapies for addiction treatment because they are addictive ignores best practices in the medical treatment of substance use disorders, ties the hands of service providers, and makes recovery from chemical dependence harder for patients to achieve.The proposed rule change would increase the effectiveness of treatment for this life-threatening and widespread illness.Thank you, William AprillLCSW-BACS, LAC, CCGC Patients enrolled in a methadone clinic accept a high level of supervision and demonstrate a commitment to their recovery. I have submitted the comment below on letterhead using the file upload function.  Here is the text.As a researcher and clinician in the addiction field, I am writing to express my strong support for the proposed inclusion in TRICARE of coverage for methadone and buprenorphine maintenance for drug dependent individuals.   Extensive research  much of it conducted with former military personnel receiving care in the Veterans Health Administration  indicates that opiate substitution therapies sharply reduce illicit drug use and risk of fatal overdose.  These therapies have also been proven highly cost-effective.At a time when a growing number of U.S. military personnel are reporting problems with prescription and non-prescription opioids, the addition of this benefit to TRICARE is critically important.  For the regulatory change to be maximally beneficial to the health of our military personnel and their families, it should be coupled with extensive outreach to TRICARE providers to make them aware of the new insurance benefit.Thank you for proposing this major step forward for the TRICARE program. The use of opioid maintenance therapy on a long term basis has not been proven to improve functionality or reduce mortality or relapse. Most tests of the efficacy of opioid treatment therapy have been conducted on a short term basis. Research has shown that on a short term basis, those given methadone or buprenorphine reduce their use of other opioids, but only for as long as they are on the drugs. Many continue to use other substances such as alcohol, and continue to be at risk of overdose. Methadone overdoses have increased 400% from 2004-2008. Harm reduction philosophy (upon which use of an addictive substance is sanctioned to treat dependence on another substance) is an enabling philosophy that continues addiction, rather than treat it. As long as the person remains dependent on an abusable substance, he or she can never realize his/her potential as a whole, infinite spiritual being. It is a disrespectful and demeaning approach to the plight of the addict and keeps him/her shackled to the progression of this dangerous mental disorder and foreshortens his/her life. The use of chronic opioid therapy for chronic noncancer pain has created this epidemic of opioid dependent persons and yet so little is being done to stop the production of opioid dependent persons and much is being propagated about the evidence-based need for the use of more opioids to treat the problem. This is insane! The proposed change reflects the best evidence-based practice in the treatment of opioid dependence.  I fully support this change in the applicable regulation.I speak from the experience of prescribing buprenorphine (Suboxone/Subutex) since 2004 in the treatment of opioid dependence in the context of a comprehensive treatment program by our agency of which I am the medical director.  I also support Opioid Treatment Programs that prescribe methadone in the treatment of opioid dependence along with counseling.I am Board-certified in Internal Medicine and Addiction Medicine and have been working in the field of addiction medicine since 1989. Dear Sir or Madam,On behalf of the Ohio Department of Alcohol and Drug Addiction Services (ODADAS) Clinical Roundtable Committee, I am pleased to submit the following comments on the proposed rule related to TRICARE benefits, Removal of the Prohibition to Use Addictive Drugs in the Maintenance Treatment of Substance Dependence in TRICARE Beneficiaries (Document ID DOD-2011-HA-0085-0001).The Clinical Roundtable -- comprised of six senior clinicians and supervisors with established expertise in the clinical treatment of addictive disorders, drawn from ODADAS-certified treatment agencies from across the state -- strongly supports extending the benefit so that maintenance regimens of Medicated-Assisted Treatment (MAT) will be covered by TriCare. Scientific literature supports provision of MAT on an ongoing basis as being far more efficacious than alternative approaches, including detoxification-only or short-term utilization of MAT. Furthermore, several Roundtable members are familiar with the use of opioid replacement therapies (MAT) on an ongoing basis in their own agencies and have found it to be effective and practical.The Clinical Roundtable also recommends addressing barriers that limit access to other clinical services (counseling, case management) within the TRICARE system. MAT is considerably more likely to be effective when combined with counseling and case management services; however, community agencies with the highest level of expertise in providing such services have found that they cannot receive reimbursement through TRICARE. While the Clinical Roundtable fully supports and recommends immediate action on the MAT proposal, there is a strong consensus that further access to addiction-related services needs to be addressed as well.Thank you for this opportunity to provide comment. Please do not hesitate to call or email if I can be of additional assistance.Sincerely,Orman Hall, DirectorODADAS On behalf of NAADAC, the Association for Addiction Professionals, which represents the professional interests of more than 75,000 addiction counselors, educators and other addiction-focused health care professionals in the United States, Canada and abroad, we thank you for this opportunity to submit comments to the Department of Defense regarding the TRICARE:   Removal of the Prohibition to Use Addictive Drugs in the Maintenance Treatment of Substance Dependence in TRICARE Beneficiaries (RIN 0720AB54).  NAADAC applauds the proposed change in TRICARE policy regarding the use of therapeutic drugs in maintenance treatments for substance dependence.  There is a wealth of medical evidence available that supports the belief that medication-assisted treatments are safe and highly effective.  The extension of benefits to include these treatments increases the quality of treatment options available to TRICARE beneficiaries.  The use of medication-assisted treatments is not for everyone.  Thus, we would recommend that included in the rule is a requirement that all individuals undergo an assessment prior to starting any medication-assisted treatment to ensure that they are receiving the appropriate care.  We also recommend that there be a requirement that anyone receiving medication-assisted treatments also take part in a comprehensive psychosocial treatment program to be administered concurrently.  We believe these added components will serve to prevent further dependence by assisting counselors in obtaining an ongoing assessment of the treatment.While NAADAC does not have an official written statement outlining support for medicated assisted treatment for individuals with addiction problems, since 2005 we have been active in the development of training experiences surrounding this topic for addiction treatment professionals.  Through a training program entitled NAADACs Life Long Learning Series five different training experiences have been developed and trained to  As an addiction psychiatrist working with active duty servicemembers, I support the rule change in its proposed form as it allows lower echelon agencies the ability to refine its policies congruent with the needs of the service and servicemember alike.  The rule change also takes quite a bit of anxiety off the clinician as well, in clarifying and supporting the role of buprenorphine in the treatment of opioid dependence for the active duty population.  Thank you very much for ensuring federal regulations keep up with advances in addiction treatment. Sirs/Madam, My issue is the stopping of prescription for Methadone from legal Pain Management Offices owned and run by MDs. I have been takeing Methadone for about 8 or 9 years for sever lower back pain and withot it I would problably not be able to get out of bed in the morings. I take no other durg and have never taken any, I am 66 years old and from what I hear and have investegated on the internet the withdrawal symthoms are not very plesant and take a long time. I live alone and have Enfezema and I and on oxegen 24 hours 7 days a week, with a heart condition high blood pressure and it is very hard for me to get around. Also any other drug that can replace Methedone is also taken off the list, is there no special consideration for older people such as myself? Thank You John W. Rosmini February 24, 2012Submitted via http://www.regulations.gov Department of Defense 1160 Defense Pentagon OSD Mailroom 3C843 Washington, DC 20301-1160Re: Support for proposed rule: TRICARE; Removal of the Prohibition to Use Addictive Drugs in the Maintenance Treatment of Substance Dependence in TRICARE Beneficiaries, RIN 0720-AB54To Whom It May Concern:The McDermott Center (dba Haymarket Center) welcomes the opportunity to express our support for the proposal to remove the prohibition against use of medications in the treatment of substance dependence for TRICARE beneficiaries.  For over 30 years, Haymarket Center has served as the Chicago Metropolitan Areas largest nonprofit substance abuse treatment provider. While treating over 22,000 clients annually, on any given day Haymarket has 400 patients in residential treatment, detoxification, outpatient treatment or recovery homes.  Haymarkets substance abuse treatment efforts include services for pregnant and post-partum women, as well as programming for families and fathers. Buprenorphine, methadone, and suboxone have been shown through multiple clinical studies to be effective medications when used for detoxification, short- and long-term maintenance treatment.  While these drugs are themselves addictive, when administered in an appropriately controlled manner they are safe and effective methods of opioid treatment.  By removing the prohibition on addictive medications, returning veterans with substance-abuse disorders and TRICARE recipients will receive a higher quality of care, with a decreased likelihood of an addictions relapse. Haymarket Center strongly urges the Department of Defense to remove the prohibition on addictive medications for TRICARE patients.  Should you have questions, please contact Dr. Dan Lustig Psy.D. CADC MISA II, Vice President of Clinical Services, by phone at: (312) 226-7984 ext. 488.Sincerely,Ray Soucek PresidentHaymarket Center