H.R. 2482 (116^th): Mainstreaming Addiction Treatment Act of 2019

This position statement was submitted by The Levenson Foundation on Aug 4, 2019.

As experts in SUD and co-occurring mental health challenges, and former owner/operators of one of the nations leading, largest and best-known private providers of dual diagnosis impatient treatment responsible for the treatment of tens of thousands of Americans, and now as a philanthropic organization as well as for-profit advisors to government, Fortune 500 and providers of treatment, we believe this legislation will have immediate and positive effects on public health and are in full support of it, as drafted. Critically, it will overcome the ideological resistance to this lifesaving care within the abstinence-only treatment field by decentralizing their monopoly-like control over the provision of treatment and allow physicians, who otherwise can prescribe and treat any other illness, the ability to write medication orders for a type of opioid which has extremely low abuse rates and a massive likelihood of abating mortality. The medications are the best in the formulary to immediately satiate opioid withdrawal in PWUO or the OUD, and interrupt the cascade of potential crime and death that occur when that specific medical condition goes unmet.

This position statement was submitted by Reynolds Consultants on May 12, 2019.

As a Psychiatric Pharmacist that has practiced for 38 years I have a great deal of knowledge about the clinicians who treat Opiate Use Disorders. This is not a topic taught in medical school, nor is it a skill that is developed during routine medical education. Instead this is a very specialized field that requires special education over and above that of the general medical training. This was recognized in the Drug Addiction Treatment Act of 2000 (DATA 2000) where the use of Buprenorphine for dependence and withdrawal was specially restricted so that the clinicians who used this drug demonstrated competency in treating opiate induced disorders by receiving a training “waiver”.

Now there is a movement to withdraw the required waiver under the mistaken reasoning that broadening clinician access to Buprenorphine will help deal with our nation’s opiate issues. I find the logic of this bill fallacious. Wanting the same clinicians that have caused the excessive use of opiates to now be able to prescribe Buprenorphine without the training verification required by the waivers is ridiculous. The necessity of proper training in the use of Buprenorphine is supported by a recent publication: Lofwall MR, Walsh SL. A review of buprenorphine diversion and misuse: the current evidence base and experiences from around the world. J Addict Med. 2014;8(5):315–326. doi:10.1097/ADM.0000000000000045 Which demonstrated the potential problems in the misuse of Buprenorphine by the general medical public.

It is without a doubt a mistake to allow HR 2842 to proceed as written. Removing the “waiver” requirement will not address the Opiate Abuse issue it states as its purpose. It will open the door to to illegitimate use of the drug and worsening of the problem. What is needed is more clinicians to be properly educated in Opiate Use Disorder so that they too can get certified to use Buprenorphine. The bill should be changed to fund this need.

Charles A. Reynolds, PharmD, BCPP Reynolds Consultants