Premier Provides Input on Proposed Rule to Expand Access to Opioid Use Disorder Treatment

Premier submitted comments on the Substance Abuse and Mental Health Services Administration (SAMHSA) proposed rule on medications for the treatment of opioid use disorder. The proposed rule seeks public comment on SAMHSA’s proposals to update opioid treatment program (OTP) accreditation and certification standards, treatment standards for medications for OUDs and requirements for individual practitioners eligible to dispense certain types of OUD medications. SAMHSA also proposes to update regulation text to reflect the removal of the Drug Addiction Treatment Act of 2000 (DATA-2000) waiver requirements, consistent with statutory requirements in the Consolidated Appropriations Act of 2023 (CAA 2023).

In its comments, Premier supports SAMHSA’s commitment to enabling access to high-quality, equitable care for OUDs and specifically recommends that SAMHSA:

• Finalize removal of DATA-2000 waiver (also known as the “X waiver”) from the Code of Federal Regulations, consistent with current law;
• Finalize proposals to codify pandemic-era flexibilities that allow take-home doses of methadone and the use of telehealth in initiating buprenorphine for OTPs;
• Collaborate with the Drug Enforcement Agency (DEA) to permanently codify practitioners’ ability to prescribe controlled substances via telehealth;
• Expand the definition of an OTP “practitioner” to include advanced practice pharmacists with board certification and/or residency training in OUD;
• Finalize proposals to expand OTP services to include evidence-based care delivery models aligned with public health goals;
• Work alongside other federal agencies to standardize the collection and use of social determinant of health (SDOH) data in order to identify and scale the most appropriate evidence-based public health solutions for health disparities among individuals with OUDs; and
• Finalize proposals to expedite access to OTP services by removing arbitrary admission criteria and empowering clinically appropriate, joint decision-making between providers and patients.