What follows are a number of AATOD policy recommendations with regard to OTP development and oversight. We believe it is important to expand the footprint of OTPs throughout the United States, especially in suburban and rural areas. In considering such matters, it is important to point out that to have a positive impact in how OTPs function in a post COVID-19 environment, changes in state oversight need to be aligned with changes in federal oversight. This alignment is an important recommendation since a number of state regulations are not necessarily based on evidence-based practices. Illustratively, some state regulations require that OTPs use pharmacists to administer and/or dispense medication. In an environment of shortages in pharmacists, such regulations are burdensome and significantly add to the cost of treatment. No one has provided any evidence to support how pharmacists offer superior care in the OTP setting when compared to nursing or clinical personnel. Additionally, a number of state agencies or Medicaid authorities require patient-to-staff ratios without providing any particular rationale for doing so. Some state agencies/licensing bureaus have strict requirements in siting OTPs, especially if they are located near business districts, churches or learning centers. Additionally, some states have census capacity limits for OTPs, which are not based on occupancy standards. Federal and state oversight must also be aligned with third-party reimbursement practices including Medicare, Medicaid and private insurance. This integration is especially daunting but essential to guarantee success in any sweeping policy change in this sector. Accordingly, the following recommendations are primarily focused on OTP development.
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