1. The “real-world” experience of OTPs and patients suggests that SAMHSA considers a change in take-home requirements. 
  2. Our Association is renewing its recommendation to have SAMHSA change the ability of OTPs to admit new patients to treatment with methadone via telehealth. 
  3. Changes in state oversight need to be better aligned with changes in federal oversight. 
  4. CMS Medicare/Medicare in addition to state Medicaid reimbursement rates need to be aligned as changes are made to federal and state oversight requirements.  
  5. AATOD recommends SAMHSA continue to monitor how states use funds to ensure the expansion of mobile vans connected to OTPs wherever they are needed to expand access to care to treat opioid use disorder.   
  6. AATOD recommends SAMHSA remove the two primary barriers in expanding access to interim maintenance treatment, which include removing the restriction for for-profit entities and allowing patients to have take-home medication during the period of interim maintenance. 
  7. AATOD recommends the expanded use of satellite medication units to work in conjunction with licensed OTPs. We recommend that SAMHSA coordinate this effort with the DEA and State Opioid Treatment Authorities. We believe SAMHSA needs to amend the existing regulatory guidance to OTPs from 2015 and clearly define what services can be provided in satellite medication units.  
  8. AATOD recommends that federal and state authorities develop additional and creative/innovative options to treat our patientsSuch innovations include deliveries to home bound patients during times of crisis in addition to working with an expanded number of partners in mental health and residential settings. With regard to creating such innovative change, it is important to reference the three whitepapers that AATOD developed for SAMHSA during 2016/2017: “Models of Integrated Patient Care through OTPs and DATA 2000 Practices,” “Integrated Service Delivery Models for Opioid Treatment Programs in an Era of Increasing Opioid Addiction, Health Reform, and Parity” and “Increasing Access to Medication Assisted Treatment for Opioid Addiction in Drug Courts and Correctional Facilities and Working Effectively with Family Courts and Child Protective Services.” 
  9. AATOD recommends SAMHSA encourage states to widen flexibilities in regard to staffing ratios so OTPs can balance the needs of patients with both their level of risk and the availability of various workforce components (i.e., physicians, physician extenders, nurses and counselors/therapists) in a way that, while not always ideal, allows for the provision of adequate care under various environmental conditions. 
  10. AATOD recommends a review of patient admission criteria. Illustratively, the current regulations indicate the following: “A person under 18 years of age is required to have had two documented unsuccessful attempts at short-term detoxification or drug-free treatment within a 12-month period to be eligible for maintenance treatment.” These provisions should be eliminated. 
  11. AATOD recommends SAMHSA work with the approved accreditation entities with regard to how such entities are interpreting SAMHSA regulations and guidelines.
  12. AATOD recommends against the use of pharmacies dispensing methadone hydrochloride products through physician prescribing.  
  13. AATOD recommends SAMHSA work in conjunction with other agencies within DHHS, ONDCP and other federal agencies, which have the ability to create loan forgiveness opportunities so that individuals in the health profession are given the opportunity to work in OTPs to fulfil their obligations in receiving student loans. 





















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