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. 

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. 

I would take out the requirement for weekly drug screens being administered to patients who are still actively using because the new 8-point criteria does not take into account illicit drug screens. Patients are going to be able to receive take homes even with illicit use so drug testing them weekly is contradicting due to this not being something that is factored into getting the take-home medication. 

I believe when it comes to not taking into consideration the illicit substances and the danger it can cause the patient of providing take-home of methadone while testing positive for multiple benzodiazepines or other substance, the chances of potential overdose will be very high resulting an increase on overdose death rate. 

12VAC35-105-960.D This change in language that does not specify a "physical examination" and instead states an "examination" can be manipulated by the provider, it is important to specify a physical examination.  

12VAC35-105-970. The individual's progress in treatment should still be documented and evaluated.  This should be specified in the regulation.  

12VAC35-105-990. Regular attendance of counseling in accordance to an Indvidual's treatment plan should be taken into consideration of take homes, given that it has been clinically proven that counseling as a combination of MAT is the most successful for recovery.  Also, the other additions that state "absence of" how is the treatment provider determining there is an "absence of" this needs to be defined more....is it by assessment? and if so, what type of assessment? 

Requesting a 7 day maximum supply of take home medications to allow for clinics that are not open on weekends. 7, 14 and 28 day take home supplies allow the client to come in the clinic on the same day of the week. This allows room for mandatory court days, and clinic closings on the weekends.