Registration Requirements for Narcotic Treatment Programs with Mobile Components
2020-04-15 2020-04-17 2020-04-27 2020-04-28 2020-04-28 2020-04-28 2020-04-28 2020-04-28 2020-04-28 2020-04-28
DEA-2020-0005-0024 DEA-2020-0005-0027 DEA-2020-0005-0053 DEA-2020-0005-0078 DEA-2020-0005-0080 DEA-2020-0005-0076 DEA-2020-0005-0077 DEA-2020-0005-0081 DEA-2020-0005-0085 DEA-2020-0005-0082
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https://api.regulations.gov/v4/comments/DEA-2020-0005-0024 https://api.regulations.gov/v4/comments/DEA-2020-0005-0027 https://api.regulations.gov/v4/comments/DEA-2020-0005-0053 https://api.regulations.gov/v4/comments/DEA-2020-0005-0078 https://api.regulations.gov/v4/comments/DEA-2020-0005-0080 https://api.regulations.gov/v4/comments/DEA-2020-0005-0076 https://api.regulations.gov/v4/comments/DEA-2020-0005-0077 https://api.regulations.gov/v4/comments/DEA-2020-0005-0081 https://api.regulations.gov/v4/comments/DEA-2020-0005-0085 https://api.regulations.gov/v4/comments/DEA-2020-0005-0082
Stephanie Anonymous Casey Thomas Paul Benjamin Anonymous Amanda Victor Cheryl
Garrison Anonymous Bohrman Cole Joudrey Locklair Anonymous Cowan Rodionoff Ho
As a current staff member of Mental Health America helping those with mental illness, substance abuse and addiction, I firmly support this proposed rule. To create an environment easier for those battling addiction and exerting efforts to get help, its essential to eliminate the tedious repetitive steps that could be avoided. To best support those overcoming addiction, national, state and local ratings, and accredited narcotic treatment programs (NTPs), it is important to factor waiving separate registration. By creating multiple steps of repetitive registration, some addicts and those in need may be deterred from completing the NTP. Its important to consider the advantages of modern technology to create alternate strategies. I firmly agree that this proposed rule and regulation change would support detoxification treatments and have far greater benefits than deficits on the American people. While creating more widely available services with less tedious steps of registration, in return, it will reduce the likelihood of relapse. As stated in Part II Scope of the Proposed Rule, as long as requirements of this rule honor HIPAA and protect patients through security, record-keeping and reporting, this would be a step in the right direction to combat the opioid crisis in the U.S.  I would like to support the Drug Enforcement Administration (DEA) proposed revision to the existing regulations for narcotic treatment programs (NTPs) to allow a mobile component associated with the registered program to be considered a coincident activity. This revision could eliminate a potential barrier to programs that are reaching to areas that are underserved. It coincides with the Center for Disease Controls overarching goal of achieving health equity, eliminate disparities, and improve the health of all groups while decreasing premature death. People in rural areas have a complex mix for lack of access to care. In addition to being rurally located often times 200 miles from a provider, they tend to live below the poverty level. These compounded barriers reduce the chance of patients obtaining treatment that is greatly needed. Opening opportunities to reach the communities at need can potentially decreasing the triple fold opioid overdose death rate that has occurred over the years. This proposal is consistent with public health and safety in providing a much-needed service to an otherwise unreachable area that can satellite to multiple areas but stay within the confined of the state. Mobile units can be a safe, budget friendly approach to brick and mortar building that involve costly expenses and overhead. Research has proven that patients receiving medication assisted therapy are more likely to remain in treatment and less likely to partake in illicit opioid use. Something more has to be done. We are losing this battle at the cost of over 70,000 American lives.  As a social worker and a professor Iwrite in support of this change. I am deeply concerned about peoples access to treatment during this pandemic and feel that this change could help saveLives.  I support this proposal to revise DEA regulations for narcotic treatment programs to allow a mobile component associated with the registered program to be considered a coincident activity. Increasing access to life saving opioid use disorder treatment is paramount in mitigating the consequences of our Countrys opioid epidemic. Going forward, we should continue to increase access to medications for opioid use disorder, rather than re-implement archaic polices that restrict access to care and cause additional harms and restrictions to and on people who use opioids. We must continue to use science to guide our decisions, while reflecting on how our bias and subjective experiences impact how we react to these deviant and negative health behaviors.    I am primary care physician, addiction medicine specialist and instructor at Yale School of Medicine. My research aims to improve the health of people with opioid use disorder. Myself and colleagues have previous demonstrated there exists a substantial urban-rural disparity in geographic access to methadone for opioid used disorder (https://doi:10.1001/jama.2019.12562 and  https://doi.org/10.1016/j.drugalcdep.2020.107968) which creates a large mismatch in demand for methadone treatment services and supply of such services within the Unites States. I support the proposed change by the DEA to again allow mobile NTP within the United States to begin to address this disparity in geographic access to methadone. Resistance to expanding access to methadone for opioid use disorder is often grounded in concerns about diversion and overdose due to greater methadone use. However, these concerns continue to overstate (or fail to define) the actual risk of harm due to these concerns. The likely harm from diversion of methadone   is small compared to the risk of overdose and death from continued use of heroin or fentanyl. Therefore, even if small levels diversion and methadone overdose are associated with actions which expand methadone access, these harms are likely to be easily overshadowed by the overdose deaths prevented by allowing people with opioid use disorder to switch from using heroin or fentanyl to methadone treatment. It should be noted that while suboxone is an alternative medication for this population it also faces shortages in access and does not meet all patients needs make methadone access essential. This change in policy is long overdue and it is worth stating that these changes alone will not address the disparities in methadone access our team has previously described, but it is a small step in the write direction. Additional regulatory and systems changes will be need to ensure universal access to methadone. Sincerely,Paul J Joudrey, MD, MPHProgram in Addiction MedicineYale School of Medicinepaul.joudrey@yale.edu April 14, 2020Uttam DhillonActing AdministratorDrug Enforcement AgencyUnited States Department of Justice8701 Morrissette DriveSpringfield, VA 22152Dear Acting Administrator Dhillon:I am writing on behalf of the City of Philadelphias Department of Behavioral Health and Intellectual disAbility Services (DBHIDS) to communicate support for the Drug Enforcement Agencys (DEA) proposed rule regarding registration requirements for narcotic treatment programs (NTPs) with mobile components, as published in the Federal Register on February 26, 2020. DEA proposes to revise the existing regulations for NTPs to allow a mobile component associated with the registered program to be considered a coincident activity that does not need a separate registration.DBHIDS supports a range of services for children, adults, and families, including mental health services, substance use treatment services, early intervention services, and intellectual disAbility services. Our mission is to strengthen and serve individuals and communities so that all Philadelphians can thrive.DBHIDS unreservedly supports the proposed rule as a measure to make effective and appropriate substance use treatment services available to those people who most need them. The families and communities of Philadelphia have struggled greatly with the current opioid crisis, and despite the diligent and creative work of dedicated public servants across various City agencies the toll in morbidity, mortality and human suffering of opioid use disorders is still mounting. While our City continues to work on addressing this crisis in innovative and flexible ways, more is clearly needed.In the course of our work serving people who have opioid use disorders, we have become convinced of the value of medication assisted treatment (MAT) in promoting recovery and limiting the harms caused by the disease of addiction. MAT, which entails the administration of opiate agonists such as methadone or buprenorphine, has been shown to improve outcomes when delivered as part of a comprehensive behavioral health treatment program, or when delivered alone. Accordingly, we support measures such as this proposed rule which will tend to increase the availability of MAT to people who could benefit from it.Many of the individuals we serve experience disadvantages in multiple intersecting respects. They are far more likely to be impacted by the social determinants of health. They may suffer the impact of systemic racism. They may live in impoverished communities, or lack reliable access to transportation resources. They may experience insecurity in their access to food or housing. A recent study of the New Jersey Medication Assisted Treatment Initiative (NJ-MATI) indicated that people facing these challenges were most effectively served by mobile medication units (MMUs), which were more accessible and therefore better able to meet the needs of these individuals, as well as individuals who presented with more severe symptoms of opioid use disorders.For these reasons, DBHIDS believes that the proposed NTP mobile component rule will be an aid to us in our mission to promote the thriving of all Philadelphians. We applaud the efforts of the DEA in this regard and look forward hopefully to the promulgation and implementation of this rule.Sincerely,David T. JonesCommissionerDepartment of Behavioral Health and Intellectual disAbility Services I support the  proposal to allow mobile Narcotic Treatment Programs to operate without separate registration. The proposal would make maintenance and detoxification treatment more available while requiring safeguards to minimize the risk of methadone and other controlled substance diversion. I support the DEAs proposal to revise regulations for narcotic treatment programs to allow a mobile component alongside the brick and mortar building. As someone who works at the intersection of those experiencing homelessness, leaving incarceration and OUD, this is something we have long been championing and asking for. Being able to prescribe with fewer barriers and reach the client where they are, is the definition of evidence based treatment- which MAT is considered the gold star.  This is something that is brought up regularly within provider meetings and I am very happy to see this being researched.  As a healthcare provider, I know that methadone is an important and effective intervention for opioid use disorder and helps prevent deaths from overdose. You must allow mobile delivery of this life-saving medication   As a physician who is certified in both Internal Medicine and Addiction medicine who works with homeless communities, I completely support this effort. I think the way that NTPs are structured now, more vulnerable segments of the population are often missed.Having a mobile component would facilitate treatment expansion for more marginalized communities.THis would benefit rural settings as well