I work with individuals in active substance use and about 51% of the 1,200+ individuals we serve don't have a permanent place to call home. Being able to fulfill harm reduction's creed to 'meet people where they are and don't leave them behind' through mobile services would have a cascading effect on their individual lives and our communities as a whole.

Given that SAMSHA cites 5 studies that show similar outcomes of individuals for both those with therapy requirements and those who do not engage with thearapy, I believe our OBOT requirements should reflect that by changing 'shall' to 'may' in part in section B8 of12VAC30-130-5060 

"8. Cognitive, behavioral, and other substance use disorder-focused counseling and psychotherapies, reflecting a variety of treatment approaches, MAY be provided to the individual on an individual, group, or family basis and shall be provided by CATPs working in collaboration with the buprenorphine-waivered practitioner who is prescribing buprenorphine products or naltrexone products to individuals with a primary opioid use disorder. These therapies can be provided via telemedicine as long as they meet DMAS requirements for an OBOT and for the use of telemedicine. (See the Medicaid Memo entitled "Updates to Telemedicine Coverage" dated May 13, 2014.) Preferred OBOTs may utilize CSACs and CSAC-supervisees to provide substance use disorder counseling and psychoeducational services within their scope of practice as defined in § 54.1-3507.1 of the Code of Virginia."