Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
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
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11/6/24  4:03 pm
Commenter: Chesterfield County

Comments from Chesterfield County
 

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

  • Addresses transportation barriers: In areas where public transportation is limited or nonexistent, many individuals struggling with opioid use disorder (OUD) may not have the means to travel to a treatment center. Mobile MAT units bring services directly to them, removing this barrier.
  • Reaches remote or rural areas: Mobile MAT can serve patients in geographically isolated locations, ensuring that even those in the most remote parts of the community can access life-saving treatment.

2. Improved Health Outcomes

  • Timely intervention: Bringing MAT to individuals in need can reduce the likelihood of overdose, improve retention in treatment, and support better overall health outcomes.
  • Integrated care: Many mobile units provide not only medication (like methadone or buprenorphine) but also offer mental health counseling, primary care, and harm reduction services, which can holistically address the needs of people with OUD.

3. Reduced Stigma

  • More privacy: In communities where there is stigma associated with seeking treatment for substance use disorder, a mobile MAT program can provide more privacy than visiting a central clinic, making individuals more comfortable accessing services.
  • Community engagement: Mobile units often work in close partnership with local organizations and stakeholders, fostering community trust and reducing stigma associated with MAT and recovery.

4. Cost-Efficiency

  • Lower infrastructure costs: Operating a mobile MAT unit can be more cost-effective than building new treatment centers, particularly in areas where the demand may not justify a permanent facility. It also allows services to be flexible and respond to changing community needs.

5. Flexibility and Convenience

  • Convenient scheduling: Mobile units can operate on a flexible schedule, meeting individuals in various locations throughout the community on specific days and times, making it easier for patients to plan around their work or personal commitments.
  • Rapid response: In times of crisis or increased demand, mobile MAT units can quickly mobilize to deliver services where they are most needed, offering a dynamic approach to care.

6. Reduction in Crime and Overdoses

  • Lower opioid misuse: By expanding access to treatment, mobile MAT can help reduce the prevalence of opioid misuse, leading to fewer drug-related crimes in the community.
  • Decreased overdose rates: Increasing access to MAT has been shown to lower the incidence of fatal overdoses, which is particularly important in areas without immediate access to emergency care.

7. Continuity of Care-Ongoing support:

  • A mobile MAT unit can ensure that patients receive consistent care, even in areas where there is a shortage of healthcare professionals or addiction specialists. Many mobile units include follow-up services, ensuring that people stay engaged in long-term recovery.

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.

CommentID: 228805