Today, NASADAD releases an updated fact sheet regarding the Substance Abuse and Mental Health Services’ (SAMHSA) Pregnant and Postpartum Women’s (PPW) Residential Program and State Pilot Program. The fact sheet “tells the story” of the PPW Residential Services program that has been housed within SAMHSA’s Center for Substance Abuse Treatment (CSAT) for a number of years. In addition, the brief reviews the evolution of the PPW State pilot program – an initiative first developed by Congress with NASADAD support as part of the Comprehensive Addiction and Recovery Act (CARA). The brief includes updated information describing outcomes data related to the PPW State Pilot Program; recent grantees; and recent action related to these programs moving in Congress.
NASADAD Recognizes September as Recovery Month
National Recovery Month is held each September to raise awareness and share the message that people do recover from substance use disorders. Recovery month has embraced the permanent theme of “Every person. Every family. Every Community.” Through this message, Recovery Month seeks to educate the public, stakeholders, and communities about addiction as a disease by sharing resources that elevate recovery practices and the effectiveness of treatment.
NASADAD’s members serve as the lead agency in each State or jurisdiction responsible for managing federal funds dedicated to addressing substance use prevention, treatment, and recovery. This month, our Members wear purple to celebrate recovery and promote awareness of substance use disorder issues. NASADAD is grateful for the work all of our members do in their States and jurisdictions to support recovery every day of the year.
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Letter Supporting The Protecting Moms and Infants Reauthorization Act
On Wednesday, July 12, NASADAD wrote a letter to the House Committee on Energy and Commerce’s Subcommittee on Health Chairman Representative Brett Guthrie (R-KY-2) and Ranking Member Anna Eshoo (D-CA-16) in support of H.R. 4092, “The Protecting Moms and Infants Reauthorization Act.” The legislation would reauthorize the Substance Abuse and Mental Health Services Administration (SAMHSA)/Center of Substance Abuse Treatment’s (CSAT) Pregnant and Postpartum Women’s (PPW) program for an additional five years.
The PPW program consists of the PPW Residential Services Program (PPW-R) and the PPW State Pilot (PPW-PLT) program. The PPW-R directs funding to support a comprehensive, family-centered approach to residential substance use disorder treatment and recovery services to pregnant and post-partum women, their minor children, and other family members. The PPW State Pilot (PPW-PLT) works to increase the accessibility and availability of comprehensive, family centered services for pregnant women in non-residential settings.
The bill is sponsored by Representatives Marie Gluesenkamp Perez (D-WA-3) and Young Kim (R-CA-40).
g Kim (R-CA-40).State Opioid Treatment Authority (SOTA) Role Explained
As the nation continues to experience record high tragic deaths from opioid overdose, access to high quality treatment using medications for opioid use disorder (MOUD) is critical. The State Opioid Treatment Authority (SOTA) plays a key role in providing oversight and support to the opioid treatment programs (OTPs) that use methadone and other Food and Drug Administration-approved medications and provide counseling and other services to individuals with opioid use disorder (OUD). NASADAD worked with SOTAs across the nation to develop a document that summarizes the core and common duties and responsibilities of their role, with input from Substance Abuse and Mental Health Services Administration (SAMHSA) and the NASADAD Board of Directors. The document below provides a summary of this document.
NASADAD/APHSA Release Publications on Improving Collaboration Between the Child Welfare and Alcohol and Other Drug Systems
Research has shown that if left untreated, parental substance use disorders (SUD) can have a negative impact on the entire family. According to a Substance Abuse and Mental Health Services Administration (SAMHSA) study published in 2017, approximately 1 in 8 children in the United States lived with a parent who had a past year SUD. While many children who are exposed to parental substance misuse will not experience maltreatment, they are at higher risk of maltreatment and child welfare involvement and are twice as likely to develop an SUD themselves. Intentional planning and coordination between state alcohol and other drug (AOD) and child welfare agencies are essential to prevent the negative consequences that SUD can have on families and prevent children from entering the foster care system.
To strengthen the collaboration and relationship between these agencies, the American Public Human Services Association (APHSA) and the National Association of State Alcohol and Drug Abuse Directors (NASADAD) launched a workgroup of state child welfare and AOD leaders. Through a series of meetings conducted throughout 2022, agency leadership worked together to understand the barriers and opportunities to align systems and improve services for shared populations. Those conversations initiated the development of foundational resources for both agencies that outlined shared outcome measures and examples of existing collaborations between the two systems. Guided by the workgroup, APHSA and NASADAD worked together to create two resources for AOD and child welfare agencies, as well as other organizations that work with child welfare-involved families impacted by substance use:
Shared Outcomes for Child Welfare and Substance Use Disorder Systems– This document aims to provide child welfare and AOD systems with guidance to start and deepen conversations by enabling state agencies to jointly assess the services offered to child welfare-involved families impacted by substance use.
Collaborative Programs Between Child Welfare and Substance Use Disorder Systems – This document provides state agencies with existing models of collaboration between child welfare and AOD agencies along with court systems.
Please direct any questions to Caroline Halsted (chalsted@nasadad.org).
President’s FY 2024 Budget: Overview of NASADAD’S Priority Programs
On March 9, the Biden-Harris Administration released their proposed budget for fiscal year 2024 (October 1, 2023 – September 30, 2024). NASADAD has developed a chart that outlines the proposed funding levels for NASADAD’s priority programs within the Department of Health and Human Services (HHS), Department of Justice (DOJ), and Office of National Drug Control Policy (ONDCP).
NASADAD Recommends Strategies to Address the Workforce Shortage to the Senate Committee on Health, Education, Labor and Pensions
On Monday, March 20, NASADAD responded to a stakeholder request for information from the Senate Committee on Health, Education, Labor, and Pensions on potential legislative solutions to alleviate the health care workforce shortage.
NASADAD’s response underscored the importance of working with the State alcohol and drug agency to ensure a coordinated approach across all levels of government. Additionally, our recommendations to strengthen federal workforce initiatives included:
- Amend current statute to make clear that States may allocate Substance Use Prevention, Treatment, and Recovery Services (SUPTRS) Block Grant funds to support certain substance use disorder workforce initiatives;
- Establish a discretionary grant in SAMHSA/CSAP to bolster the substance use disorder prevention workforce;
- Reinstate SAMHSA/CSAT’s Women’s Addiction Services Leadership Institute (WASLI);
- The importance of a report to be developed by the SAMHSA/CSAP on the state of substance use disorder prevention workforce; and
- Continue to support the SAMHSA/CSAP Fellowship program.
NASADAD Comments on NPRM 42 CFR Part 8
On December 13, 2022, the Substance Abuse and Mental Health Services Administration (SAMHSA) published a Notice of Proposed Rule Making (NPRM) to revise the regulations governing the accreditation and operation of opioid treatment programs (OTPs), clinics that are specially authorized to use methadone as a treatment for opioid use disorder (OUD). These are the most significant revisions to these regulations since 2016, and reflect experience gained from waivers and exceptions granted during the Public Health Emergency, as well as a need to expand access to medication for opioid use disorders (MOUD) due to the ongoing rising epidemic of opioid overdose deaths. The proposed regulations underscore support for the provision of comprehensive individualized treatment services for individuals receiving treatment in OTPs.
To understand the potential impact of the NPRM, NASADAD worked with State Directors and the Opioid Treatment Network (OTN), a NASADAD component group of State Opioid Treatment Authorities (SOTAs). NASADAD staff hosted meetings with the OTN Executive Committee and the Board of Directors Policy Committee to develop a response to the proposed rule on behalf of the Association. The response was submitted on February 14, 2023.
Below are highlights of the proposed regulations and NASADAD’s corresponding comments to the rule:
- NPRM proposal regarding take-home medications. Under the Public Health Emergency, SAMHSA issued guidance allowing states to permit considerable flexibility to OTPs in providing take-home medication to patients to reduce patient and staff exposure to COVID-19. These flexibilities allow less stable patients to take home up to 14 days of medication and more stable patients to take home up to 28 days of medication. The proposed regulations would allow up to seven days of take-home medication during the first 14 days of treatment, up to 14 days of take-home medication after the 15th day of treatment, and after 31 days of treatment, the patient could be allowed to take-home medication for 28 days.
NASADAD comments. NASADAD noted that the proposed schedule for take home medications is more liberal than the schedule permitted during the Public Health Emergency (PHE), and while the PHE flexibilities were evaluated regarding safety and efficacy, the proposed schedule has not been evaluated. NASADAD recommended, therefore, that each patient be evaluated for their ability to safely manage take home medications and that this evaluation be documented in the patient’s clinical record.
- NPRM proposal regarding admission restrictions. The proposed regulations would remove both the requirement that a person be addicted at least one year before admission, and the prohibition against treating individuals under the age of 18 without two documented unsuccessful attempts at short-term detoxification or drug-free treatment within a twelve-month period. The proposed regulations would replace these restrictions with requirements that are focused on medical assessments, and in the case of a person younger than 18 years of age, the proposed rule would require approval by a parent, guardian, or relevant state authority unless state law specifies that their approval is not needed.
NASADAD Comments. NASADAD strongly supported these changes, as they focus on specific needs of individual patients during a time of unprecedented risk of addiction or overdose.
- NPRM proposal regarding initiation of medication, screening and assessment. Under the proposed regulations, patients could begin utilizing medication for opioid use disorder (MOUD) after a screening (before the assessment is completed), and both the screening and the assessment could be provided by a non-OTP practitioner, provided that the OTP practitioner verified the screening and assessment. The proposed regulations describe the elements that must be included in a screening or assessment, and under certain conditions, these could be provided by audio-visual telemedicine or by audio device.
NASADAD Comments. NASADAD shared a concern that non-OTP practitioners may lack necessary knowledge to adequately assess opioid use disorders. In addition, the OTP practitioner may not have reviewed outside screenings and assessments before initiating the medication. We noted that many of our members are actively working to enhance the knowledge of community providers, such as Federally Qualified Health Centers and emergency room bridge programs. NASADAD recommended that the final regulation include a requirement that the OTP Medical Director, or his qualified proxy, document in the clinical record that the written patient evaluation conducted by a non-OTP practitioner has been reviewed and approved within a reasonable time period after initiating medication.
NASADAD also expressed that using audio-only devices to screen new patients for MOUD should be the exception, and only allowed in situations where there is a lack of access to in-person or telehealth assessment. NASADAD recommended that these situations should be documented in the patient record and examples should be provided in the final regulations. In addition, NASADAD recommended that the written assessment be verified by the OTP Medical Director within a reasonable time of initiating medication.
Several definitions were added, eliminated, or revised, including the following:
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- The proposed definition of Practitioner would include mid-level practitioners.
- The term medication-assisted treatment would be replaced by the term medication for opioid use disorder.
- The terms detoxification treatment, maintenance treatment, and opioid agonist treatment were eliminated.
- New terms proposed to be added include behavioral health services, care plan, continuous treatment, and harm reduction.
NASADAD Comments. NASADAD concurred with the changes to the definitions, with the exception of the addition of the term “behavioral health services,” which was defined very generally with no to reference to substance use disorders or recovery support services in OTPs. NASADAD recommended that the final regulations include specific definitions for mental health services and substance use disorder services, and that recovery support services be included in these definitions.
In summary, NASADAD was pleased to provide input on these important proposed rule revisions and look forward to working with SAMHSA to implement the final rule.