Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
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11/21/17  5:16 am
Commenter: Brittany Mentor

Methadone Clinic Treatment Regulations
 

For Therapeutic reasons a Counselor’s caseload should not exceed 40 individuals and a supervisor should not oversee more than 200 total cases. When these numbers are exceeded, patients are less likely to receive quality care. Additionally, greater numbers result in a higher burnout rate among clinical staff. It is currently hard enough to find employees who want to work in the MAT field. We should be doing everything in our power to keep the ones we have.

We should also be looking more closely at Co-Occurring treatment facilities. So often we have patients who come in with a range of conditions and we are told to refer these patients out. Looking into a Co-Occurring treatment facility license for a wide range of conditions would be extremely beneficial to the population we serve.

Felons are also, for all intents and purposes prohibited from practicing the field. This is hindering people who could truly help the MAT population. Many times we have patients who when they were younger made a huge mistake; who hasn’t? To punish someone their whole life for something that may have happened once is harsh and unfair.  These limitations, including the barrier crimes list and means for felons to seek exception to gain employment in a DBHDS-regulated facility, should be looked at and revised. We teach patients everyday that just because you detour off the road does not mean you can’t get right back on track and make it to your destination; with this mandate we are not practicing what we preach. How are our patients supposed to believe that we are not judging if we are not allowing them to be our equals.

Medicaid will open so many doors for MAT patients which is why I think anyone with a CADC and a bachelor’s degree or higher should be able to easily endorse into the CSAC. This will allow providers to increase accessibility to Medicaid consumers and increase the workforce able to provide services according to Medicaid standards.

Currently in the state of Virginia nurses cannot pour take homes due to Board of Pharmacy regulating OTP’s. Virginia is one of the only states (if not the only?) that requires a pharmacist and pharmacy technician(s) to provide takehome medication to patients, adding an extra step and extra risk in the takehome process. By allowing nurses to pour take home bottles, as is allowed in most other states, we are eliminating an extra step which eliminates extra risk.

 Currently MAT Facilities are not allowed to be built within a half mile of a daycare or school, drawing an uncomfortable parallel with rules for sex offenders. No other modality of medical treatment requires that the treatment center be some distance from schools and daycare centers, and this further ostracizes and stigmatizes individuals with opiate addiction. MAT patients are people like you and me. They have a stigma society has branded on them and often times I find my patients scared to tell loved ones they are in treatment because of this stigma. This hinders their treatment and recovery process as a whole. We should be working toward eliminating the stigma society has created not highlighting it by codifying it into the law! The fact that this law was created in general is shameful and should never have happened.

CommentID: 63284