Action | Integration of the Final Federal Rule: Registration Requirements for Narcotic Treatment Programs with Mobile Components into the Licensing Regulations |
Stage | Fast-Track |
Comment Period | Ended on 11/20/2024 |
DBHDS Office of Regulatory Affairs
1220 Bank Street, 4th Floor South
Richmond, VA 23219
C/O Susan H. Puglisi/Regulatory Research Specialist
Dear Ms. Puglisi,
We believe there are many benefits to mobile Medication-Assisted Treatment (MAT) services for our community. As a large and diverse locality, transportation is often a barrier that prevents access to services. We are optimistic of the benefits this initiative would provide and how it could help close the gap by increasing access to those with substance use disorders (SUD), outlining some of the benefits below:
1. Increased Access to Treatment
2. Improved Health Outcomes
3. Reduced Stigma
4. Cost-Efficiency
5. Flexibility and Convenience
6. Reduction in Crime and Overdoses
7. Continuity of Care-Ongoing support:
As a resource for our jail, having the medicines delivered directly to our facility would be very helpful. Currently, we verify the prescriptions for each inmate, then must travel to the original prescribing clinic and pick up the doses at a specific time each day. The current system is ineffective for retrieving these medicines, but because we believe in MAT, knowing that it saves lives, we are willing to do whatever it takes to secure these treatments for our community.
Additionally, once an inmate still in recovery has been released, having someone come to them rather than having to set up transportation and get them to appointments would be a significant benefit. Many recently released inmates are very overwhelmed in the first 30 days, putting them at the greatest risk of overdose in the first two weeks post-release.
As outlined above, there are many benefits to access MAT more effectively. However, there must also be careful considerations for how the regulations are established. Of note, notification to Community Services Board (CSB) is essential, and establishing procedures around notification method, appropriate next steps for the CSBs and additional responsibilities identified in advance will clarify the role of all stakeholders in this important process.
Further, based on our experience and the scale at which we utilize these treatments today, it would be helpful for there to be a system to manage all requests, appointments, disbursements, ultimately collecting data for use and distribution metrics.
We look forward to further progress on this topic and offer our assistance if needed to effectively implement better access to MAT services.