I would request and recommend that section D - "No individual younger than 18 years of age may be admitted to maintenance treatment unless without parent, legal guardian, or responsible adult designated by the relevant state authority consents in writing to such treatment " be reviewed and updated to better reflect federal guidance and ASAM best practices. Some adolescents do not have access to supportive parent/guardian support for treatment and best practices indicate that this should not be a barrier to access and maintain treatment.  

The overall document also is confusing in language choices, whereas majority of the updates and language appears to be directed at methadone specific treatment, the broader terminology of medications for opioid use disorder encompasses Suboxone, Naltrexone and other medications and could be misconstrued to provide tighter restrictions on treatment options in other settings. I recommend clarification of the intended target of Opioid Treatment Programs to clarify if this pertains to centers that utilize methadone or all programs that prescribe medications for opioid use disorder.