Developing a Workplace Supported Recovery Program: A Strategy for Assisting Workers and Employers with the Nation’s Opioid and Substance Use Disorder Epidemics:  Request for Information
2020-04-14 2020-07-17 2020-07-24 2020-07-21 2020-03-24 2020-07-13 2020-04-23 2020-04-22 2020-02-28 2020-04-15
CDC-2020-0001-0007 CDC-2020-0001-0020 CDC-2020-0001-0024 CDC-2020-0001-0021 CDC-2020-0001-0004 CDC-2020-0001-0019 CDC-2020-0001-0011 CDC-2020-0001-0010 CDC-2020-0001-0002 CDC-2020-0001-0008
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https://api.regulations.gov/v4/comments/CDC-2020-0001-0007 https://api.regulations.gov/v4/comments/CDC-2020-0001-0020 https://api.regulations.gov/v4/comments/CDC-2020-0001-0024 https://api.regulations.gov/v4/comments/CDC-2020-0001-0021 https://api.regulations.gov/v4/comments/CDC-2020-0001-0004 https://api.regulations.gov/v4/comments/CDC-2020-0001-0019 https://api.regulations.gov/v4/comments/CDC-2020-0001-0011 https://api.regulations.gov/v4/comments/CDC-2020-0001-0010 https://api.regulations.gov/v4/comments/CDC-2020-0001-0002 https://api.regulations.gov/v4/comments/CDC-2020-0001-0008
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Inclusion in a Workplace Supported Recovery Program (WSRP) is pertinent to ending the opioid epidemic in the U.S. Resources, such as alternatives to opioids for pain relief, should be at the forefront of this initiative. It could be increasingly difficult for employees struggling with opioid use working in larger companies to get all of the resources they need, as they may need specialized attention that cannot be given in a large company. Employers should be fully aware of the recoverees past and be able to recognize the signs of an eminent relapse. This will require some sort of training for employers or managers and their willingness to participate fully in being a part of a (WSRP). Although employers may be weary of the time-consumption this program could take, they may be more willing to partake if there is some sort of incentive to them to participate. However, the incentive should be regulated as to prevent employers from taking advantage of the incentives without fully holding up their end of the deal as well.  I am interested in researching this project in Hawaii. Local communities of recovery have historically been the place for persons in early recovery to find and obtain a job.  Any future workplace recovery program should be developed collaboratively with recovery community organizations who know of recovery supportive employers.Any future workplace supported recovery program should - provide potential employers information on the benefits of hiring persons in recovery  - be inclusive of and collaborative with grassroots recovery community organizations familiar with local and regional recovery friendly employers - consider incentivizing the hiring or persons in recovery as a way to expand opportunities for persons in early recovery and improve recovery outcomes- reduce barriers to employment for person in recovery who may have historic arrest records that would keep them out of productive employment.Thank you for the opportunity to commentWilliam Stauffer LSWThe Pennsylvania Recovery Organizations - Alliance  On behalf of our more than 100,000 member physical therapists, physical therapist assistants, and students of physical therapy, the American Physical Therapy Association appreciates the opportunity to submit comments in response to the Centers for Disease Control and Preventions request for information on Developing a Workplace Supported Recovery Program: A Strategy for Assisting Workers and Employers with the Nations Opioid and Substance Use Disorder Epidemics.APTA thanks CDC for the opportunity to comment on this proposed rule. We look forward to working with the agency in the future to help promote access to nonpharmacological options to pain management, including physical therapy. Should you have any questions regarding our comments, please contact Steve Postal, Senior Specialist of Regulatory Affairs, at stevepostal@apta.org or 703/706-3391. Thank you for your consideration.  General Questions1. What elements, attributes, activities, and resources should be involved in a Workplace Supported Recovery program (WSRP)? Describe why inclusion would benefit a WSRP.--I think it would be helpful to have some kind of flowchart that would direct an employer on whether a person with a criminal history and SUD should proceed with hiring. This would require research into WSRP and outcomes so employers could understand which applicants would have the highest chance at success. It may need to be unique to certain industries or job types (e.g., manual labor, office work, etc). It should include modifiable factors that the person could change to increase their odds of success, not just demographics that the person could not alter.2. How do the elements, attributes, activities, and resources that make up WSRPs vary by industry and establishment size?--I think further research would be needed on this. see #1.3. What WSRPs or related approaches are you aware of? Do any of these programs have evaluation or other outcome measures available?--I am not familiar with WSRP approaches and the research behind them.4. Are you aware of any programs that may help employers fund or otherwise develop WSRPs? If so, what are they?--No, I am not.5. What information is available about possible benefits for employers in hiring and/or retaining workers who are in recovery from substance misuse or a substance use disorder?--Not sure6. What are the biggest concerns, fears, or challenges around WSRPs? If available, please provide any data or information to support these concerns.--From what Ive heard: fear of ongoing criminal activity, substance use at work or under the influence on the job, fear of worker injury7. What training related to this effort would be of value to managers/supervisors? To workers?--SUD as a medical issue, not necessarily a legal issue.Questions About Workplaces8. Are you aware of policies that organizations (including yours) have in place to address substance misuse and substance use disorder and, if so, what are they? (e.g., pre-employment drug testing, hiring, dismissal, disability, medical leave, benefits, and compliance with or implementation of Fair Labor Standards Act provisions)--We have pre-employement drug testing and can be randomly drug tested, although Im not sure random, ongoing drug testing is utilized much if at all.9. Which parts of your organization are involved in issues related to substance misuse or substance use disorders among your workers? (e.g., employee bargaining units, occupational health, safety department, human resources department, Employee Assistance Program)--Employee health, HR, EAPQuestions About Workplaces With a Recovery Program in Place10. What services are offered as part of the program? Are there any limits or restrictions on these resources (e.g., position in organization, duration, eligibility)? If so, what are they?--Not aware of any services11. Are any of these services available to employees dealing with the substance use disorder of another person, such as a spouse/partner, child, parent, or close friend? If so, what are they?--EAP12. What major challenges and successes has your program had?--No program, but there should be one in my opinion and adequate research for it to be evidence-based to provide employee an employer adequate confidence that both will remain safe while the employee works and continues to support their recovery. July 12, 2020To: National Institute for Occupational Safety and HealthNIOSH Docket Office1090 Tusculum AvenueMS C-34Cincinnati, Ohio 45226-1998Federal e-Rulemaking Portal: www.regulations.govRegarding Developing a Workplace Supported Recovery Program: A Strategy for Assisting Workers and Employers with the Nations Opioid and Substance Use Disorder Epidemics: Request for InformationI support the development of a workplace support and recovery program for employers to help assist employees struggling with a substance use disorder.  The United States is in the midst of an opioid epidemic and specific programming needs developed to assist employers in their quest to help employees struggling with any type of substance use disorder.  Although employee assistance programs offer many needed services to help employees struggling with  mental health and substance use disorders, they are not enough to target the emerging trend of polysubstance use disorders and dual diagnosis disorders.  Specific drug and alcohol programming could help target this evolving epidemic and help restore wellness and recovery through the convenience of employee offered services.  Sincerely,Lisa Lewis PHMNP, MSN, RN A Workplace Recovery Program would be beneficial to many employees who struggle with a substance abuse disorder. A program would help decrease the number people each year in the United States who die from a drug overdose. Workplaces without a drug free policy are experiencing the negative affects of employees with a substance abuse problem then workplaces where a drug free policy is in place. Companies without a drug policy in place tend to experience morale problems and damage to the reputation of the company (Milios, 2017). If a company has an employee who part takes in drug use this said employee will experience negative workplace incidents and violence. By creating a Workplace Recovery Program companies will see a change in the reputation and experience less employee incidents and violence. Employers would not struggle to keep employees would are talented from a substance abuse disorder (Sammer, 2018). Employees could return to work after treatment is finished and still be productive. Research has shown that having a Workplace Recovery Program helps improve employees productivity, health, and quality of life (Milios, 2017). If a company has a Workplace Recovery Program, they can save $4 in health care cost. From past research it was been discover that there are several advantages to having a Workplace Recovery Program to address substance abuse issues. The first advantage is that companies have a framework in place for those with a substance abuse disorder. Someone who has a problem does not want to lose their only source of income. This allows the employer to request certain demands from the employee by having them acknowledge they have a problem. It is hard to cover up a substance abuse problem at work. Your peers can notice strange behavior that may not seem normal. If employers notice an employee abusing drugs during work hours, they can take note of it. When an employee does agree to seek treatment by participating in a work recovery program the employer can monitor the employee (Milios, 2017). The employer can check in to see that the employee is actively engaging and making progress. If the employee is not making progress and leaves meeting early the employer can pull them aside and talk to them. In the United States you will see that 97% of companies with greater than 5,000 employees, 80% of companies with 1,000 to 5,000 employees, and 75% of companies with 250 to 5,000 employees have some sort of program in place (Milios, 2017). In the end a Workplace Recovery Program would be a win for everyone. They help employees with life changing addiction and are extremely cost effective for employers. By providing a recovery program it can only make things better instead of worse. It can help improve the worker safety, health, productivity, and profitability.ReferencesMilios, R. (2017). Why your workplace should support substance abuse treatment. Retrieved from: https://www.recovery.org/pro/articles/why-your-workplace-should-support-substance-abuse-treatment/Sammer, J. (2018). Time for new approaches to employee substance abuse and addiction? Retrieved from: https://www.shrm.org/resourcesandtools/hr-topics/benefits/pages/new-approaches-employee-substance-abuse-addiction.aspx Please see the attachment for a brief overview, I hope this review sparks questions that we can take a deeper dive intoI would love an opportunity to discuss in more detail... Q1. What elements, attributes, activities, and resources should be involved in a Workplace Supported Recovery program (WSRP)? Describe why inclusion would benefit a WSRP.I would advocate the adoption of SBIRT, Screening, Brief Intervention and Referral to Treatment for alcohol and substance use disorder, this is a public health approach to universally screen employees for risky or hazardous alcohol or substance use. SBIRT emphasizes using a validated screening tool to better understand the risk score the their employees substance use which will help better understand if they employee would benefit from a brief intervention or needs a referral to treatment with a outpatient or inpatient facility. SBIRT training also includes developing motivational interviewing techniques to help motivate the employee toward positive behavior change. SBIRT is cheap to train and adopt. Implementation does not require any special equipment but simply a empathetic person to help ask the right questions and navigate the EAP system with them. Q7. What training related to this effort would be of value to managers/supervisors? To workers?Substance use education is very limited to most professions and within the public school system. We have an abstinence-only approach to substance use, which is not successful. I think having mangers and supervisors undergo a 1-hour CE regarding addiction, how to recognize it and what to with an employee with an addiction, would be highly beneficial. This will help them understand that addiction is a chronic disease and we have ways to treat it.  The challenge of workplace recovery programs is in creating something that works and is valued by all participants. First and foremost is the primary issue of protecting the life of an addict and turning them into productive and stable citizens. The second issue is motivating employers, because while employers may be the first to see the effects of opioid addiction through missed work, it may be easier to simply fire the individual. Employers unable to carry the financial burden of providing support for known recovering addicts will simply avoid the issue by terminating employment. It would seem that job security would serve to disincentivize addicts, but perhaps job performance benchmarks could be devised in cooperation with employers and a third party. While addicts can sometimes hide discovery from family, employers can find themselves in a position of providing motivation for recovery, but at what cost to business? Will employers be required to pay for programs? Oftentimes employees who struggle with addiction are late to work or miss their shift, leaving employers and co-workers to recover the workload. Recovering addicts pose an increased rate of death by overdose, placing them in a unique situation with employers, who may be in a position to help them-IF the addict demonstrates a desire to recover. Any workplace protocols or measures set in place to help recovering addicts must be based on worker transparency (with employer) and willingness on both employee and employer to cooperate with the recommended program. Effective support measures for recovering addicts must also include an aspect of psychological monitoring, again not at the expense of the employer. I would like to know how employer support would address addictive and psychological behaviors in opioid users? In cases where there is a supportive family unit or established case history of addictive behaviors and possibly rehabilitation efforts, it seems reasonable that workplace measures would be most effective when coordinated through a third party to maintain privacy laws. Due to the variation of jobs impacted by those facing opioid additions, one approach might be to assign a third-party counselor, similar in scope to the probation officer. This recovery advocate would be assigned to individuals who have been referred by a supervising doctor, following an application process and interview. The recovery advocate then works with the individual and the employer, in cooperation with current psychiatric support to devise meaningful support in keeping with the goals of the employee and concerns of the employer. 