Fairfax- Falls Church Community Services Board agrees and supports all the comments/feedback to date below:

1. Preferred Office-Based Opioid Addiction Treatment (OBAOT) Providers, pages 8-9: Preferred OBAOT Providers, also previously known as “Preferred OBOTs”, deliver addiction treatment services to members with opioid use disorders OUD as well as other primary SUD. Preferred OBAT services are required to be provided by buprenorphine-waivered practitioners working in collaboration and co-located with Credentialed Addiction Treatment Practitioners Professionals providing psychosocial treatment in public and private practice settings (12VAC30- 130-5020). Credentialed Addiction Treatment Professional means: an individual licensed or registered with the appropriate board in the following roles: (i) an addiction-credentialed physician or physician with experience or training in addiction medicine; (ii) physician extenders with experience or training in addiction medicine; (iii) a licensed psychiatrist; (iv) a licensed clinical psychologist; (v) a licensed clinical social worker; (vi) a licensed professional counselor; (vii) a certified psychiatric clinical nurse specialist; (viii) a licensed psychiatric nurse practitioner; (ix) a licensed marriage and family therapist; (x) a licensed substance abuse treatment practitioner; (xi) a resident who is under the supervision of a licensed professional counselor (18VAC115-20-10), licensed marriage and family therapist (18VAC115-50-10), or licensed substance abuse treatment practitioner (18VAC115-60-10) and is registered with the Virginia Board of Counseling; (xii) a resident in psychology who is under supervision of a licensed clinical psychologist and is registered with the Virginia Board of Psychology (18VAC125-20-10); or (xiii) a supervisee in social work who is under the supervision of a licensed clinical social worker and is registered with the Virginia Board of Social Work (18VAC140-20-10).

• Comments/feedback: On pages 8-9, the new definition for Creditable Addiction Treatment Providers as Licensed Providers and/or Licensed Providers in Residency, does not include CSAC’s in the definition. This change and exclusion of the CSAC and the CSAC-A will impact service delivery in programs, and require additional staffing resources to meet clinical needs which will place a burden on the agency. It is highly recommended that CSAC and CSAC-A be included in the definition to alleviate this burden.

2. Opioid Treatment Programs (OTP), page 12: OTPs may also utilize CSAC-A’s (as defined in §54.1-3507.2) as well as Certified Registered Peer Recovery Specialists within their scope of practice (12VAC30-130- 5160 et al). Peer Recovery Support Services are an evidence-based model of care which consists of a qualified peer support provider who assists individuals with their recovery. Peer Recovery Specialists may deliver services in-person or through telehealth or audio-only.

• Comments/feedback: On page 12, it specifies that Peer Recovery Specialists may deliver services in-person or through telehealth or audio-only. The service delivery option for in-person, telehealth, and audio only is supported and is recommended to be expanded to all services within the new OBAT Program.

3. Service Delivery, pages 18- 19: Preferred OBAOT Service Components Develop the initial ISP within 24 hours of initiation of services and complete the comprehensive ISP within 7 calendar days from intake. Providers must ensure that all interventions and the settings of the interventions are defined in the ISP.

• Comments/feedback: On pages 18-19, it specifies that providers must ensure that all interventions and settings of the interventions are defined in the ISP. This new requirement will add additional steps to the ISP process, along with other ISP requirements that are currently in place. We ask to please consider not making this a change as a new requirement.

4. Risk Management for Preferred OBAOT and OTPs, pages 37-38: Preferred OBAOT and OTPs must include the following activities, which must be documented in each member’s record: · Random urine drug screens per the “Urine Drug Testing Guidance” section in this Supplement. · Virginia Prescription Monitoring Program checked at least quarterly for all members. · Opioid and other SUD overdose prevention education including the prescribing of naloxone for all members. · At least weekly visits by the buprenorphine-waivered practitioner or Credentialed Addiction Treatment Professional during the first three months when initiating treatment. Member must be seen at least weekly for at least three months with documented clinical stability before spacing out to a minimum of monthly visits with buprenorphine-waivered practitioner or Credentialed Addiction Treatment Professional. The IPOC must be updated to reflect these changes. · Periodic monitoring of unused medication and opened medication wrapper counts when clinically indicated.

• Comments/feedback: On pages 37-38, the existing regulations specifies that at least weekly visits by the buprenorphine-waivered practitioner or Credentialed Executive Summary Addiction and Recovery Treatment Service Addiction Treatment Professional during the first three months when initiating treatment. Member must be seen at least weekly for at least three months with documented clinical stability before spacing out to a minimum of monthly visits with buprenorphine-waivered practitioner or Credentialed Addiction Treatment Professional. The IPOC must be updated to reflect these changes. This was expanded from only OUD to include all Substance Use Disorders.  Clarity is needed regarding whether weekly visits are required for all other Substance Use Disorders (i.e. Alcohol). It is also recommended to provide flexibility for the other SUDs to be more person centered in the service delivery and allow for a greater amount of time between visits based on the individuals needs.