America's Health Insurance Plans Issues Public Comment on DEA Rule

WASHINGTON, Dec. 30 -- Kate Berry, senior vice president at America's Health Insurance Plans, has issued a public comment on the Drug Enforcement Administration rule entitled "Implementation of the Substance Use-Disorder Prevention That Promotes Opioid Recovery and Treatment for Patients and Communities Act: Dispensing and Administering Controlled Substances for Medication-Assisted Treatment". The comment was written on Dec. 23, 2020, and posted on Dec. 29, 2020:

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No one should suffer the tragedy of addiction. On behalf of the members of America's Health Insurance Plans (AHIP),/1 we thank you for the opportunity to comment on the Drug Enforcement Administration (DEA) Interim Final Rule on Dispensing and Administering Controlled Substances for Medication-Assisted Treatment (MAT).

The opioid crisis is devastating its victims, their families, and their communities across the country. Health insurance providers are working closely with state and federal leaders, as well as with physicians and other clinicians, to address it even amidst the COVID-19 crisis, by combining education, prevention, behavioral health care, and evidence-based treatment, insurance providers have been making real progress in addressing the opioid epidemic and improving the health and well-being of families and communities.

There is a well-documented shortage of behavioral health clinicians, particularly those administering MAT. Further exacerbating the shortage is the fact that many clinicians who can prescribe MAT are not treating at full capacity.

We support the DEA's proposals to build upon the Substance-Use Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act of 2018 and further expand providers' abilities to prescribe MAT to individuals suffering from substance use disorders (SUD). This includes the efforts of the DEA to expand the workforce allowed to prescribe MAT by raising the maximum number of patients a provider can treat, making permanent the provisions allowing nurse practitioners and physician assistants to prescribe MAT, and expanding the definition of a "qualifying provider" eligible to prescribe MAT.

We also commend the DEA for making recent medical school graduates eligible to prescribe MAT if the individual has received appropriate training on the subject.

We support the provision in the Interim Final Rule allowing pharmacies to permanently provide medications for maintenance or detoxification treatment to providers' registered locations for use in treatment. However, we encourage the DEA to work with these providers to ensure that there are adequate safety protections in place to prevent diversion or other fraudulent, wasteful, or abusive activities. While pharmacies have experience with safe storage and handling of medications with abuse potential, some provider offices may not have such experience. The DEA should issue guidance on how providers can protect MAT medications.

In addition to the provisions outlined in the rule, we feel that the DEA can take a more significant step in expanding access to MAT. The DEA should consider modifying or eliminating the DATA 2000 waiver to further expand access to treatment and recovery services.

While we absolutely concur that providers must receive appropriate training in SUD treatment and recovery in order to prescribe MAT, we are concerned that the waiver process may pose a hurdle that restricts access to care and services. The DEA and other federal partners should explore ways to eliminate this hurdle and streamline processes to promote access to treatment.

Some clinicians may be reluctant to treat or be unfamiliar with treatments for patients with SUD. Federal stakeholders, including the DEA, can help ensure appropriate education of clinicians on SUD and treatment by providing or requiring continuing medical education (CME), training, tools, care plans, and other resources to encourage them to work with patients suffering from SUD. By providing training and resources for providers and eliminating the specialized MAT waiver, the DEA can expand the capacity for treatment and recovery services.

Thank you for considering our views on these important issues. We are encouraged by your commitment to build on the important progress made with passage of the SUPPORT Act and address ongoing challenges related to SUD treatment. We stand ready to provide any additional assistance or information that would be helpful as you continue your effort to improve access to SUD treatment.

Sincerely,

Kate Berry

Senior Vice President

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Footnote:

1/ America's Health Insurance Plans (AHIP) is the national trade association representing the health insurance community. AHIP's members provide health and supplemental benefits to millions of Americans through employer-provided coverage, the individual insurance market, and public programs such as Medicare and Medicaid. AHIP advocates for solutions that expand access to affordable health care coverage to all Americans through a competitive marketplace that fosters choice, quality, and innovation. AHIP's members have broad experience working with hospitals, physicians, patients, the federal government, and other health care stakeholders to ensure patients have access to needed treatments and medical services at an affordable price.

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The rule can be viewed at: https://beta.regulations.gov/document/DEA-2020-0031-0001

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