Call for Public Comments on new Federal Regulations for MOUD
The federal regulations in 42 CFR Part 8 (that oversee the use of buprenorphine and methadone in opioid treatment programs/”methadone clinics”) are being revised! There is a Notice of Proposed Rulemaking (NPRM) currently open in the federal register where organizations and individuals may leave public comments on the proposed new rules.
Overall, the proposed revisions to the federal regulations are positive and are aimed and increased flexibility for unsupervised doses of medication (“take homes”) and reducing administrative barriers for opioid treatment programs (OTPs) that will increase access to methadone for opioid use disorder.
Points to make in public comments:
-I am a methadone (or buprenorphine) patient (or patient advocate). Include any other relevant information about yourself and your experience as a patient, patient advocate, or provider.
-I support the proposal for use of telehealth in methadone and buprenorphine induction in OTPs.
-I urge SAMHSA and other federal agencies to take all possible steps to encourage alignment of state and territorial regulations with the intent of these proposed federal regulations, including the withholding of grant funding to states who do not align with the intent of these proposed federal regulations.
-The proposed section in Part 8.4(b)(1)(iii) and b(2) on accreditation should be re-written in a way there is no chance it increases administrative burden and costs for programs, as such increased burdens will result in higher patient fees and discourage the continued expansion of facilities that can provide methadone for OUD.
-Interim Maintenance treatment should be allowed through all OTPs and not just public and private not-for-profit OTPs.
-I support increased clinical flexibility for unsupervised doses of medication (“take homes”), and I encourage SAMHSA to eliminate time in treatment requirements altogether versus moving from one arbitrary time framework to another arbitrary time framework.
-In the absence of a joint NPRM with the DEA that would allow prescribing of methadone for stabilized patients to pharmacies, please include historic models of medical maintenance for stable patients in the final rule that, to-date, have only been established under exceptions.
Using the suggested comments above and adding individualized information and experiences, we ask that all NAMA Recovery advocates and stakeholders file individual public comments in the federal register here: https://www.federalregister.gov/documents/2022/12/16/2022-27193/medications-for-the-treatment-of-opioid-use-disorder
DEADLINE FOR PUBLIC COMMENTS IS 11:59pm EASTERN on TUESDAY, FEBRUARY 14th!