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AATOD Letter to SAMHSA Regarding SMA-167

June 5, 2015

Summer King
Reports Clearance Officer
SAMHSA
I Choke Cherry Road
Room 2 – 1057
Rockville, MD 20857

Re: Federal Register Notice Vol.
80, No.65 Notification Form
(SMA – 167)
Dear Ms. King,

I am writing in response to the Department’s notification with SAMHSA conceming data collection activities for DATA 2000 reporting. I am specifically referencing the notification form (SMA-167) that SAMHSA uses with regard to provider notification as part of the Drug Abuse Treatment Act of 2000 and its subsequent amendments.

The Department’s primary question is whether the proposed collection of information, obtained through the above referenced notification form, is necessary for the proper performance and functions of the Substance Abuse and Mental Health Services Administration. The obvious answer from our Association’s point of view is yes. Our Association represents approximately 1,000 Opioid Treatment Programs (OTPs) throughout the U.S., which are all certified through SAMHSA.

We think it is important when any DATA 2000 practitioner wishes to increase the number of patients being treated as part of their practice from 30 to 100 patients to provide sufficient information to SAMHSA to guide SAMHSA’s decision making.

We believe that it is fair to state that SAMHSA does not currently collect adequate information about the care being provided within DATA 2000 practices. Illustratively, no one has any idea of how many patients are treated through DATA 2000 practices at any given point in time. No one has any centralized data on what kinds of services are offered to patients, including counseling and other clinical support services, beyond the prescribing of Schedule III opioids to treat opioid addiction. No one has any idea if DATA 2000 practices are conducting toxicology testing to guide therapeutic decision making. No one has any centralized data collection with regard to DATA 2000 practices checking PDMP databases either prior to admitting the patient and throughout the patient’s care.

These are not academic questions. Accurate lesponses will provide SAMHSA with an understanding if the existing DATA 2000 practices are following SAMHSA’s Best Practices recommendations in treating opioid addiction (TIP 40), in addition to the recently released National Practice Guidelines from the American Society of Addiction Medicine.

In our judgment, SAMHSA should collect such information on a routine basis from DATA 2000 practices. This kind of information could easily be captured as such practices are transitioning from a 30 patient capacity to a 100 patient capacity.
In order to avoid significant burden to DATA 2000 practitioners who are filing such forms, the form could simply add a few basic elements that answer the following important patient care questions:

• How many patients are currently in treatment and how many patients do
  you intend to care for?
• What kinds of clinical support services do you provide to your patients
  directly? Through case management referral?
• Do you check PDMP databases before the patient is treated and
  throughout the patient’s care?
• On average, how long does the patient remain in continuous treatment in
  your practice?
• What is your patient drop out rate?
• Do you conduct toxicology tests during the course of the patient’s care?
  If so, what is the frequency of toxicology collection and what drugs are
  being tested?
• What percentage of patients have discontinued the use of illicit drugs?

These are some basic questions that should be added to the form, in addition to the currently collected information including the state medical license number, DEA registration number, address of primary location, telephone, fax, and email addresses to gain an understanding of the type of care being provided in DATA 2000 practices.

From our Association’s point of view, adding such elements to the form will provide SAMHSA with some of the basic information that it should have as part of its decision making to certify such DATA 2000 practices and provide increased opportunities to treat patients in their practices. Further, it will allow SAMHSA to understand whether these practices follow best practice guidelines, as contained in SAMHSA’s Clinical Guidelines for the Use of Buprenorphine in the Treatment of Opioid Addiction (TIP 40), as referenced above, and the recently released and comprehensive National Practice Guideline for the Use of Medications in the Treatment of Addiction Involving Opioid Use (American
Society of Addiction Medicine).

Thank you for taking these comments into account.

Sincerely yours,
Mark W. Parrino
President

Opioid Treatment Program Survey

The American Association for the Treatment of Opioid Dependence, Inc. (AATOD) is conducting an evaluation of hepatitis and Opioid Treatment Programs (OTPs). Each OTP in the country is encouraged to complete this brief survey in order to acquire up-to-date information about hepatitis and OTPs.

The survey is web-based, user-friendly and can be completed within 15-20 minutes or less. If you have an OTP with multiple locations, please note that the survey should be completed for each location. Your responses are analyzed by a third party and will be kept confidential.

To begin the survey, please CLICK HERE or cut and paste this link into your web browser: https://www.surveymonkey.com/s/TDR95XP

We appreciate your willingness to participate and value your feedback. Thank you if you already completed the survey. However, please forward this survey invitation to any other OTP within the United States.

If you have any questions, please email carleen.maxwell@aatod.org.

Thank you!

2015 AATOD Conference in Atlanta, GA

>> Click to download the full conference PDF

Letter from the Conference Chair

Dear Friends and Colleagues,

On behalf of the American Association for the Treatment of Opioid Dependence, Inc.
(AATOD), it is my pleasure to invite you to the 2015 AATOD Conference being held
March 28–April 1, 2015 at the Hyatt Regency in Atlanta, Georgia. The 2015 Conference
is sponsored by the Georgia Department of Behavioral Health and Developmental
Disabilities along with the Opioid Treatment Providers of Georgia.

AATOD has a history of providing an outstanding conference which continuously
strives to provide conference attendees with new and exciting avenues for learning and
growth, 2015 will be no different. In fact, for this conference we will have a first ever
Documentary Screening. The documentary The Fix: The Feeling is Mutual is one way
to accomplish this. What a unique opportunity to be both enlightened and trained! The
conference will be filled with an abundance of other opportunities to socialize with
those in the Medication Assisted Treatment (MAT) field and to gain knowledge about
opioid overdose prevention, research within MAT, current ideas, and issues through Hot
Topic Round Table Discussions, and a variety of other treatment related concerns. One
of the most important issues that will be addressed at this conference will be the health
crisis America faces as it relates to opioid dependence.

The conference theme is “Addressing a Public Health Crisis: Opioid
Dependence” and the event comes at a unique time in American history. In their
2014 National Drug Control policy, President Obama, and the Office of Drug Control
Policy (ONDCP) proclaimed that the United States is in an Opioid Epidemic. In
addition, ONDCP has officially stated “we are significantly bolstering support for
Medication Assisted Opioid Treatment.” It is important for us to take the opportunity
of MAT becoming more recognized and accepted as a valid and essential piece of the
recovery puzzle. We have a responsibility to those we treat to remain proficient in our
knowledge of treating this disease. Our plenary speakers have been chosen to assist
us in reaching this goal. To name a few, we expect CDC Director, Dr. Thomas Frieden,
SAMHSA Administrator, Pamela Hyde, and ONDCP Director, Michael Botticelli as
featured speakers.

The largest gathering of the MAT community will be at the 2015 AATOD Conference.
AATOD and its membership are the authority on MAT. Although these modalities of
treatment have been available since the 60s, with growing support there is a renewed
interest in MAT. This conference has been designed to meet the needs of everyone
from novice personnel to seasoned MAT providers, with offerings of the Clinicians
Course, Workshops, Hot Topic Round Tables, Patient Advocate Training, and vendors
for products and services that will benefit clinic business. This conference is intended
for anyone who has an interest or concern about the opioid epidemic we are facing.
It is our hope that this event is a catalyst for change in this public health crisis. Your
participation is vital to the success of the conference.
Please join us for the 2015 AATOD Conference in Atlanta.
Sincerely,

Jonathan P. Connell, MA
2015 AATOD Conference Chair

 
>> Click to download the full conference PDF