CLAAD Letter to Tennessee General Assembly
Transcription
CLAAD Letter to Tennessee General Assembly
March 25, 2015 Tennessee General Assembly House Subcommittee on Health 301 6th Avenue North Nashville, TN 37243 Dear Committee: The Center for Lawful Access and Abuse Deterrence (CLAAD) is concerned about House Bill 929 (HB 929) and the implications it has on access to care for individuals with substance use disorders seeking addiction treatment. CLAAD is a national, not-for-profit organization working to reduce prescription drug abuse while protecting patient access to care. Since 2009, CLAAD’s National Prescription Drug Abuse Prevention Strategy has called for the expansion of interventions and referrals to treatment for individuals with substance use disorders.1 The National Strategy has earned the endorsements of over 30 not-for-profit organizations, including the Drug Free America Foundation, National Family Partnership, the American Chronic Pain Association, Community Anti-Drug Coalitions of America, and NAADAC – The Association for Addiction Professionals. As the nation addresses what the Centers for Disease Control and Prevention has identified as a prescription drug abuse epidemic with more than 16,000 opioid-related overdose deaths each year, medication-assisted therapy (MAT) provides individuals with substance use disorders the opportunity to focus on their psychosocial recovery efforts and lead healthy, productive lives. In their current form, HB 929 and Senate Bill 829 (SB 829) require nonresidential treatment centers providing MAT to more than 150 patients, including those on the premises of a physician’s office, to obtain a certificate of need (CON) by July 1, 2016. While CON requirements already apply to methadone providers, these bills would expand CON requirements to buprenorphine treatment providers. Unlike methadone, a Schedule II controlled substance, buprenorphine is a long-acting partial opioid agonist that is classified as Schedule III and thereby poses a lower degree of risk.2 These bills have the potential to eliminate access to care for Tennesseans living in areas where physicians at community-based, CON-approved facilities have met federal prescribing limits, or where facilities exist that do not possess a CON and, therefore, MAT is restricted. In fact, if physicians are required but unable to obtain CONs in order to practice MAT, their patients may be left without a treatment provider and are more likely to relapse to substance use or seek diverted buprenorphine from pill mills or other illicit sources in order to self-medicate. 1 http://claad.org/wp-content/uploads/2013/10/Nat_Prescipt_Drug_Abuse_Prev_Strat_2009.pdf Mori J. Krantz, MD; Philip S. Mehler, MD, "Treating Opioid Dependence: Growing Implications for Primary Care," Archives of Internal Medicine, (Chicago, IL: American Medical Association, February 2004), Vol. 164, p. 281. http://archinte.jamanetwork.com/article.aspx?articleid=216641. 2 Center for Lawful Access and Abuse Deterrence 1000 Potomac Street NW, Suite 150-A • Washington, D.C. 20007 • (202) 599-8435 • www.claad.org • @CLAAD_Coalition In 2013, 22.7 million persons aged 12 or older needed treatment for an illicit drug or alcohol use problem, and yet, 89 percent went untreated.3 There is currently a shortage of physicians licensed to practice MAT, and due to federal patient limits imposed on practitioners under the Drug Addiction Treatment Act of 2000, those who are licensed to practice MAT often have long waitlists of patients that they are unable to treat. By adding yet another restriction on the practice of MAT, HB 929 and SB 829 place further barriers in the path of individuals at high risk of suffering overdose-related death without proper treatment. More effective ways exist to address concerns around buprenorphine diversion and the proliferation of pill mills. We would be pleased to work with you to advance prescriber education requirements, mandatory prescribing standards, professional sanctions and rehabilitation, and referrals to law enforcement when public health authorities identify criminal activity. According to the Substance Abuse and Mental Health Services Administration (SAMSHA), 475 physicians and 24 opioid treatment programs are currently providing opioid-substitution therapy in Tennessee.4 With limits already in place on physicians prescribing buprenorphine for addiction treatment,5 a CON could further restrict access. Further restricting access to care could lead to the prescribing of higher dosages and diversion to others seeking buprenorphine, resulting in misuse and abuse. As we have already seen with the prescription drug abuse epidemic, restricting access to treatment can result in unintended consequences on public health and safety, including emergency department visits, the spread of infectious diseases, increased costs to taxpayers for publicly-funded health care, lost productivity, increased crime, and overdose-related deaths. Buprenorphine permits individuals with substance use disorders to function normally within their families, jobs, and communities.6 As policy makers, law enforcement, health care practitioners, and stakeholders, including CLAAD, continue to address prescription drug abuse, it is critical that we avoid enacting policies that restrict access to addiction treatment. Thank you for the opportunity to voice our concerns about HB 929 and SB 829. If you have any questions, please contact us at (202) 599-8435 or ksimon@claad.org. Sincerely, Kyle Simon Director of Policy and Advocacy 3 Results from the 2013 National Survey on Drug Use and Health: Summary of National Findings, Substance Abuse & Mental Health Servs. Admin. (2014), http://www.samhsa.gov/data/sites/default/files/NSDUHresultsPDFWHTML2013/Web/NSDUHresults2013.pdf. 4 http://buprenorphine.samhsa.gov/pls/bwns_locator/ 5 https://www.naabt.org/30_patient_limit.cfm 6 Substance Abuse and Mental Health Services Administration, Center for Behavioral Health Statistics and Quality. (April 23, 2013). The N-SSATS Report: Trends in the Use of Methadone and Buprenorphine at Substance Abuse Treatment Facilities: 2003 to 2011. Rockville, MD, p. 2. http://archive.samhsa.gov/data/2k13/NSSATS107/sr107-NSSATS-BuprenorphineTrends.pdf 2