AATOD 5 – Year Plan
2022 – 2026

Our treatment system is entering a major period of transition in 2022. There have been legislative and regulatory recommendations that seek to make medication the singular treatment, rather than a comprehensive array of clinical services to provide care to patients with a complex medical disorder. In our judgment, this is risky if it is widely applied to newly admitted patients. We are also in an era of shifting opioid use with fentanyl as the dominant opioid being used by untreated individuals in combination with powerful stimulants. We have found that it is more difficult to stabilize such patients and a number of Opioid Treatment Programs (OTPs) are accelerating induction schedules and increasing doses to achieve clinical stability.

In addition, we are in an era of expanded opportunities to increase access to care, especially with the recent Drug Enforcement Administration (DEA) approved policy to open more mobile van systems in the country and with the updated Substance Abuse Mental Health Service Administration (SAMHSA) policy of increasing access to bricks-and-mortar medication units, which can act as spokes to the OTP hub sites. The point here is that we are in a shifting regulatory framework and are waiting for recommendations, which will come from the National Academies of Sciences, Engineering, and Medicine (NASEM). We anticipate that NASEM may make helpful recommendations to move the system forward, but we remain concerned about the direction that some of the policies might take. We are opposed to providing clinicians with prescriptive authority where such clinicians could write a prescription for methadone for a 30-day supply and have that prescription filled by pharmacies without much tracking or accountability. As a reminder, this is exactly what happened over 20 years ago, as doctors were writing prescriptions for methadone to treat pain. This resulted in significantly increased methadone related mortality as detailed in the five nationally published reports at that time, beginning in 2003 and extending through 2010. The findings of these five reports reached consensus in determining that the cause of increased methadone mortality was directly connected to the prescribing of methadone to treat pain and having the medication distributed through pharmacy channels. As new policy recommendations are made, we want to be careful that we are not creating a different problem, which could also result in compromising the integrity of the treatment system. We are also waiting to read the recommendations from SAMHSA with regard to proposed changes in regulatory oversight for OTPs.

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