Medications for the Treatment of Opioid Use Disorder
2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05 2023-05-05
SAMHSA-2023-0001-0007 SAMHSA-2023-0001-0014 SAMHSA-2023-0001-0017 SAMHSA-2023-0001-0019 SAMHSA-2023-0001-0020 SAMHSA-2023-0001-0042 SAMHSA-2023-0001-0027 SAMHSA-2023-0001-0040 SAMHSA-2023-0001-0047 SAMHSA-2023-0001-0045
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0007 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0014 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0017 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0019 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0020 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0042 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0027 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0040 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0047 https://api.regulations.gov/v4/comments/SAMHSA-2023-0001-0045
Kennedy Barbie Anonymous Howard Anonymous Anonymous Rose Scott Nichole Carl
Powell Zabielski Anonymous Edwards Anonymous Anonymous Muniz N Meyers Anderson
I think it would benefit greatly if Telemed appointments were permanently available for inductions/first visits. As a public health professional, I strongly urge SAMSHA to adopt the proposed changes to medications for opioid use disorder (MOUD) regulations to increase access to these lifesaving medications and enable people with substance use disorder (SUD) to successfully discontinue illicit drug use and reclaim their lives. I currently serve as deputy director of Virginia Harm Reduction Coalition, a 501(c)(3) nonprofit providing harm reduction services to people who use drugs (PWUD) in Southwest Virginia. I have witnessed firsthand the struggles our clients face in accessing MOUD, including not being able to afford to take time off work for appointments and facing stigma at work when they do, difficulties with getting childcare to facilitate appointments, and difficulties obtaining transportation to access appointments. I have witnessed clients struggle mightily to remain in treatment only to finally succumb to the weight of these barriers and relapse. The closest Medicaid-accepting methadone clinic to Roanoke, Virginia, is located 50 miles away in Martinsville. Methadone is much more effective for many of our clients than buprenorphine (especially since Virginia law makes obtaining buprenorphine without a naloxone component impossible for most patients). The availability of telehealth appointments for methadone patients and the ability of patients to receive up to 4 weeks worth of medication enables many more of our clients to enter and remain compliant with treatment. It is an absolute game changer.   While I absolutely believe addiction and addiction issues are a significant problem, I wanted to make sure that my understanding (and my doctors understanding is correct as it was told to me, a pain patient). The proposals wording leaves no choice for someone taking opioids to NOT be dependent either physically or mentally. Meaning, it is appropriate to code all patients claims who use opioids as at least opioid dependence diagnosis. They have no choice to do this even if their doctors have zero dependency concerns documented in the medical chart. Even if the patient has no dependency issues with the opioid(s) being taken. And I am assuming there will be some sort of protections for the patients to ensure that there will be no denial of organ transplants, should they ever be needed in the future because of this coding. Because again, the patient and doctor had no choice. Anything to make buprenorphine more easily accessible. It is by far the safest opioid. Its use to treat pain and opioid overdose should be studied and encouraged. It is safe enough to be dispensed over the counter to competent adults. H B Edwards, MDAddiction PsychiatristBehaveNet, LLC I am an OTP methadone patient. Ive watched as federal and state laws have provided easier access to treatment. However, this means nothing if the OTP or Methadone clinic does not adopt these rules. I have 14 years 100% compliant in my treatment but my clinic will not allow me to have more than 6 take home doses. According to Samhsa and my state law I should be getting up to 27 doses. People at other clinics with less time clean can get more takehomes than me. But because you make these changes and do not require these opioid treatment programs to follow, nothing will change. Its a shame. You just let people suffer and die and do nothing about it. I am told by the people who run the clinic that they get paid more when we have to show up in person more. So its become about these companies money and bottom lines and not peoples lives and treatment. You all should be quite ashamed of yourselves. I am totally NOT in favor of SAMHSA adopting the Proposed Rule as is, in its entirety because it will create a huge financial hardship on the agencies that receive funding based on being CARF accredited if given one year or a non-accreditation outcome for more than a few recommendations that could be resolved within 60-90-days. Without a lot of details regarding why SAMHSA is moving into this direction, it is very difficult to really assess the pros and cons.  However, one thing that I know is that agencies work hard to comply with CARF standards as well as overall service delivery to consumers and to put these stricter expectations as well as time restraints on these agencies appears to be a setup for failure.  No agency is perfect and to say an agency can only have a hand full of recommendation is not reality because of the overall diversity within all agencies.  It is not a one size fit all type of situation.  The reason why agencies have chosen to comply with CARF standards as initially written is because we were want to provide a high level of care to our consumer based on surveyors overall feedback within a reasonable amount of time to correct issues, etc.  This is not a agency at large friendly proposal.    I wanted to say that I think this is a good thing for MH  addicted patients, also think that MH patient for some if not most should not be taken away our rights to certain anxiety and panic attacks meds such as benzodiazepines. When I came to South Carolina from California I had to quit on my own wt benzodiazepines because no doctor here would refill it.I would like to suggest for more groups  resources for MH patients as is almost non existent here in SC. I dont think MH or addiction should be stigmatized anymore.!!! Thank you  To expect a treatment center to not have a singular standard (out of 1900) out of conformance seems like an unrealistic expectation.  If a surveyor finds one treatment plan out of all the charts that they look at and that treatment plan was completed a week after its due date.  Then that would be the one singular out of conformance that they are allowed to have for their entire survey (now they know they are only going to get a one year and they are stuck in compliance nightmares all year for every clinic they have).  This regulation would force surveyors to decide if they should make any recommendations to the clinic to help them improve or decide that it is crucial for the clinic to stay open to treat patients so they must ignore any issues and just issue a perfect 100% survey at every location to ensure access to treatment for patients.  It defeats the purpose of professional consultation and makes the survey process punitive. The proposed post-survey process described in Proposal  8.4(b)(1)(iii) and (b)(2)  is unreasonable and unduly burdensome to Opioid Treatment Programs (OTPs). First, it is unreasonable to require full conformance to all standards in order to obtain a Three-Year Accreditation or to maintain accreditation following a One-Year Accreditation. Although all accreditation standards are meaningful and promote quality performance, the facts and circumstances of each OTP are unique; therefore, conformance to particular standards may not be appropriateor even possiblefor every OTP at all times. Second, it is unreasonable to expect OTPs to be able to develop and implement all quality improvement activities for all recommendations within a period as short as 60 days. In fact, the implementation period would need to be much shorter than 60 days, so that accreditation agencies could perform verification within the 60-day period. Third, it is unduly burdensome for OTPs to be subject to verification surveys shortly following prior surveys for what are often relatively minor recommendations that may have no direct impact on persons served. Moreover, the indirect and direct costs of preparing for and obtaining such verification surveys would also be unduly burdensome and totally unnecessary, as the current resurvey process demonstrates a quarter century of significant quality improvement by OTPs during each three-year survey cycle without the cost and inconvenience of mid-cycle verification. The proposed changes to the rules for accreditation for OTP facilities are not only unnecessary, but would be nearly impossible to implement in a meaningful fashion.  Absent a serious health and safety violation that creates unsafe conditions, there is no need for an organization to be re-surveyed within 60 days.  It is also foolish to think that any program could complete a survey with no recommendations.  This proposed change goes against the principles of quality improvement and does nothing to improve service delivery or patient care.  Furthermore, it also creates a financial burden for organizations that would have to pay for another survey within 60 days.  These funds are better spent on providing care to low-income patients.  Please reconsider this change.  