Proposed Rule on Buprenorpine Dispensing In Opioid Treatment Programs
2009-08-17 2009-08-17 2009-08-17 2009-08-17 2009-08-05 2009-08-05
HHS-OS-2009-0007-0006 HHS-OS-2009-0007-0008 HHS-OS-2009-0007-0010 HHS-OS-2009-0007-0009 HHS-OS-2009-0007-0005 HHS-OS-2009-0007-0004
04:00:00 04:00:00 04:00:00 04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0006 https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0008 https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0010 https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0009 https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0005 https://api.regulations.gov/v4/comments/HHS-OS-2009-0007-0004
Ronald Elizabeth Robert Farrouk Mark Charles
Pike Stanton md Newman Shamsi Parrino Walton
Comment 4 see attatched file Comment from Robert Newman, M.D. August 17, 2009 Re: Dockett No. CSAT 001, Proposed Rule Change for Buprenorphine Take Homes for Opioid Treatment Programs (OTPs)  At Texas Clinic, we started utilizing buprenorphine, specifically Suboxone, soon after it was approved for usage in our OTP.  We have had great success with this medication, as it seems to have reached a new population of individuals addicted to opiates. Our main problem from the very beginning in giving buprenorphine to our patients has been the cumbersome take home restrictions identical to those placed on methadone dispensing. We are constantly having to get exception requests for take homes while our colleagues in private practice were simply able to prescribe or dispense Suboxone with no such restrictions. The take home restrictions have definitely been a deterrent to successful treatment.  Over the years, we have had patients drop out of treatment while waiting for their take homes to be processed for approval or simply switch to a private practice (which actually cost them more) because they had freedom to work, go to school, or manage their household more easily. We would strongly be in favor of lifting any take home restrictions on buprenorphine in OTPs and, therefore, amending the Federal OTP regulations as soon as possible.  In this vain, we would further propose that an emergency order be issued, lifting such restrictions immediately, to avoid the possibility of any other patients leaving treatment, relapsing, and going back to a life of abusing opioids. Thank you for allowing us to comment on this proposed rule change. Sincerely,Farrukh Shamsi, MBAExecutive DirectorTexas Clinic Fulton6311 Fulton St.Houston, TX 77022(713) 694-8100 AATOD From: Charles Walton Sent: Tuesday, July 21, 2009 4:03 PMTo: SAMHSA DPT_InterimruleSubject: Eliminaton of Buprenorphine takehome dispensing schedule under Section III I am pleased to support the Secretarys decision in this matter.  It will serve to increase access to a most successful treatment for opioid dependency.  I am the Medical Director of an opiate maintenance clinic and would suggest that physicians in this field, such as myself, are every bit as, or more, capable of determining which patients are safe to have multi-day or multi-week prescriptions of Suboxone as are the orthopods or internists or family physicians who have had only the 8 hour training in its OBOT use.  Opiate maintenance clinic staff focus on issues of diversion, actually do callbacks to count pills left, actually do provide counseling, and actually do random UA, all of which are poorly applied in community suboxone prescribing.  Mr. Secretary, thank you for taking this logical move.  It will make many patients lives better through easier access and genuine treatment resource availability.  Charles W. Walton, MDMedical Director DHUT, DHUC, DHTV, DHLT