March 24, 2020
Health Care Alert
Health Care Alert
The Substance Abuse and Mental Health Services Administration (“SAMHSA”) issued initial guidance to OTPs and practitioners on how to provide care to patients with opioid use disorder (“OUD”) during the COVID-19 pandemic, including permitted telehealth options and providing drugs during quarantine.
The United States Department of Health and Human Services (“HHS”) declared a public health emergency to address the national opioid crisis on October 26, 2017. Over two years later, while the country is still addressing the national opioid crisis, federal and state agencies, opioid treatment programs (“OTPs”), and practitioners seek to provide care to patients with opioid use disorder (“OUD”) during the COVID-19 pandemic. Last week, the Substance Abuse and Mental Health Services Administration (“SAMHSA”) issued initial guidance to OTPs and practitioners on how to provide care to this vulnerable patient population.
One of the essential elements of OTPs for a significant amount of patients, especially at the beginning of recovery, is being physically present at a clinic/facility and receiving daily or almost daily doses of prescribed medication for OUD. While this requirement provides some therapeutic benefit and decreases the likelihood of diversion for certain patients, such requirement increases the possibility of exposure to or transmission of COVID-19 among program staff, patients, and others. SAMHSA provided that all states can request blanket exceptions for all stable patients in an OTP to receive 28 days of take-home doses for OUD. SAMHSA notes that states can also request up to 14 days of take-home doses for OUD for patients who are less stable but an OTP determines could safely handle.
In response, states such as Pennsylvania have implemented the SAMHSA exceptions and are waiving their own state regulations regarding standard limitations of take-home doses. Pennsylvania allows county authorities to use grant funding from the Pennsylvania Department of Drug and Alcohol Programs to assist OTPs to provide clinical services using telehealth technology.
While SAMHSA states that federal law requires a complete in-person medical evaluation before a patient admission to an OTP, SAMHSA has the authority to grant exemptions to OTPs from certain federal requirements. SAMHSA determined to exempt OTPs from the in-person medical examination requirement so long as there can be an adequate examination of the patient via telehealth (including if needed the use of telephone).
SAMHSA issued guidance to OTPs on how to provide medication to patients quarantined at home.
SAMHSA hopes the guidance as discussed above will assist OTPs and practitioners that treat patients with OUD ensure that their patients receive their necessary medication while mitigating the spread of COVID-19. It is expected that SAMHSA will continue to review and revise its guidance as well as implement new guidance, perhaps regarding prescribing of methadone, moving forward.
For more information and thought leadership regarding COVID-19, visit our Coronavirus Response Team page. Additionally, we are hosting a webinar titled COVID-19: The latest updates and guidance for hospitals and health care entities, on Wednesday, March 25th, at 1:30 p.m. Eastern. If you are interested in participating, please click here.
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