Dear Susan Puglisi,

I would like to object to the proposed Fast Tracking of mobile units to be deployed for the purpose of MAT expansion.

MAT availability has increased tremendously since the new ARTS guided programs were rolled out in 2016. In the year 2018, when preferred OBATS were gaining traction, the overdose rates reversed and dipped substantially. Since then, MAT programs have soared in number-- making MAT (predominantly buprenorphine) available to the point of being virtually “over the counter.”  Overdose rates reversed course again and trended back upward .

The success in 2018 was most likely due to programs being of better quality. Patients were held more accountable in their recovery. Extrinsic motivations imposed by conscientious programs enabled  motivational interviewing techniques, a more comprehensive milieu, and better control of controlled substances. Patients became  more intrinsically motivated when a better understanding of the psychosocial impact and risks for overdose and death were gained.

When more treatment options were made available,  patients would simply choose a more permissive program and receive “pill mill” quantities of MAT without the milieu of therapies and without being held accountable. Instead of seeking recovery, patients would often seek providers allowing the easiest access to abusable, (un)controlled substances.

To allow Mobile Unit delivery of MAT without leverage for a more comprehensive program would only lead to more abuse of substances, worsening of opioid use disorders, overdose, and death.

Gene Germano MD

Medical Director and Founder

GHR Center for Addiction Treatment and Recovery

850 Tidewater Drive Suite A

Norfolk, VA 23504

Main Phone: 757-333-6992

Fax: 757-383-6399

Email: GGermanoMD@GHRCenterAddiction.com