Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
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9/24/24  8:18 am
Commenter: Lee Tannenbaum, M.D., ARS

12VAC35-105-990 Take-Home Medication; 12-VAC35-105-980
 

12VAC35-105-990: Section C.2

"A maximum of a five-day consecutive supply of take-home doses from 8 days of treatment to 30 days of treatment."   I would suggest/ask if this could be increased to a 6 day supply. 

I would also like to ask that 12-VAC-35-105-980 Section B, requiring weekly urine drug testing on patients who continue to use illicit drugs be eliminated. This requirement makes no sense from a medical/toxilogical standpoint, is significantly stigmitizing to our patients, requires a great deal of provider/clinician time and effort for no significant clinical return,  overrides the ability to provide more than 6 take home doses to those who continue to use illicit drugs but might benefit from additional takehomes in conflict with SAMHSA guidelines, and costs the state a lot of money in unnecessary lab fees for no clinical benefit. No other state requires drug testing this frequently. 

CommentID: 227892