Senate Finance Subcommittee Issues Testimony From Johns Hopkins University Professor
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Chairman Cardin, Ranking Member Daines, and members of the Health Care Subcommittee, thank you for inviting me to speak this afternoon. My name is
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Substance Use Disorders and Overdose Are Pervasive and Preventable Harms
The drug overdose crisis is a multigenerational challenge that undermines American life expectancy, economic productivity, and individual potential.1,2 The most recent data from the
Source: Analysis of
Overdose is the most visible harm, but substance use disorders (SUDs) are pervasive - recent data indicate that 49 million Americans meet screening criteria for an alcohol or drug use disorder.6 Overdose and SUDs affect all segments of American society, but have a disproportionate impact on people in federal health care programs, including lower-income people, people from minoritized communities, and those with disabilities.7 Moreover, overdose in recent years rose rapidly at the tails of the age distribution - among both adolescents and older adults, groups that are often enrolled in Medicaid, CHIP, and Medicare.8,9 Improving access and quality to substance use related health services in federal health care programs could make a major impact on overdose mortality, because we have lifesaving treatments. Unfortunately, only about one-quarter of all people who meet screening criteria for SUD have received any treatment in the past year, and often treatment is received for periods of time that are too short or they do not receive the best available treatments.6 For example, patients are often retained in opioid use disorder (OUD) treatment for less than six months.10 While important progress has been made over the last decade, most people with OUD still do not receive standard of care treatment with medications.6 In my testimony today, I will lay out three goals that can guide federal health care programs as they respond to this national challenge.
The goals I describe are interlinked - they focus on practical steps that can be taken in federal health care programs to ensure that all beneficiaries receive evidence-based care in the settings where they need it the most. These goals reflect the perspective that SUD care should be supported with the same resources, oversight, and standards as any other chronic diseases. National efforts to reform SUD care are still overcoming a deep-seated legacy of stigma and discrimination. SUD care should be considered part of mainstream health care. Rising to this challenge means meeting people "where they are at", which requires removing barriers to starting care, and working across disparate systems, payers, and cultures. Federal legislation can continue to expand the scope of health care to include non-traditional sources of support such as peer recovery workers and engage with other service systems, including social services, housing, child welfare, and the criminal legal system.
Goal 1: Align covered benefits with clinical consensus
It is important to give credit where it is due - there has been tremendous progress over the last decade and many gaps in the continuum of care have been closed through legislation. One example is coverage for methadone maintenance, a necessary and lifesaving treatment option for people with opioid use disorder. A decade ago, a dozen state Medicaid programs offered no coverage of methadone maintenance and Medicare excluded methadone maintenance entirely.
The SUPPORT Act closed these important coverage exclusions, so that OUD treatment services, including methadone, provided by federally regulated opioid treatment programs are now covered in Medicare Part B.13 In addition, with the passage of recent legislation, the SUPPORT Act's temporary requirement that state Medicaid programs cover all medications for the treatment of opioid use disorder, including methadone, along with related counseling services and behavioral therapy, has now been made permanent. Another example is Medicaid coverage of residential addiction treatment programs. The so-called Institutions of Mental Disease (IMD) exclusion in Medicaid has long prevented state programs from covering services in specialty inpatient or residential facilities with over 16 beds that primarily provide SUD care in the absence of special authorities.12 Recent legislation would make permanent the SUPPORT Act's state plan option to allow states to pay for SUD care in such facilities for up to 30 days per year, per beneficiary.
It is now crucial to build upon expanded coverage options in two concrete ways:
* Continuing to close gaps in the continuum of care. In Medicare, there is still a need to add coverage for non-hospital residential treatment,13 an important aspect of care for many patients with SUD. In Medicaid, coverage of medications for substance use disorder have improved though important gaps remain. For buprenorphine, this means ensuring that state Medicaid programs do not impose arbitrary limits on dosage and duration of treatment.14 Strengthening and enforcing requirements of federal parity laws can reduce clinically inappropriate limitations. For methadone, likewise, there are state laws that limit the ability of providers to take advantage of new federal flexibilities related to telehealth and extended take-home privileges.15 Some states even prevent the establishment of new methadone clinics that are urgently needed to increase access.16
* It is critical to ensure that federal health care programs have adequate provider networks in settings that are geographically proximate to beneficiaries. Patients routinely travel long distances to receive SUD care, which reduces their retention in care.17 One reason is that managed care plans do not always contract with a sufficient network of providers.18 Overcoming this problem requires implementing comprehensive network adequacy requirements with regular audits to ensure that contracted providers, especially addiction specialist clinicians, are willing and able to accept new patients. In many cases, network adequacy requirements do exist but are not consistently applied or do not draw on updated network information.19
* Hospital emergency departments: in 2019, there were 8 million visits to emergency departments for SUD related causes.26 Best practices for treating patients in hospitals after opioid overdose is to provide them with prompt access to medications for opioid use disorder and to initiate a warm handoff with continuing care. These models reduce risk of overdose and readmission.27 However, most US hospitals still lack the capacity to provide treatment with medications. According to legal analysis, hospitals may be violating federal laws such as the Americans with Disabilities Act (ADA) and the Emergency Medical Treatment and Labor Act (EMTALA).28 It should be a requirement for participation in federal health care programs that hospitals possess the capability to treat opioid use disorder with medications.
* Residential treatment facilities: residential treatment facilities provide clinically-managed 24 hours care for people with acute substance use needs, particularly those with complex comorbidities. While such facilities should be among the most carefully regulated, state and federal agencies often provide limited oversight of these programs. At the most egregious level, residential treatment facilities can be involved in deceptive or illegal practices such as patient brokering, often in coordination with unregulated "sober homes" not licensed to provide treatment.29 More commonly, residential treatment programs cannot deliver the full standard of care to patients. For example, only about one-third of all residential programs in the US can offer OUD treatment with medications,30 and audit studies find that even programs that can offer such treatment are discouraging patients from receiving them.31 Federal health care programs have leverage to require residential facilities to meet nationally recognized program standards, including providing access to medications. Medication requirements for residential facilities already exist in state regulations in Louisiana,32 New York,33 and California.34
* The criminal legal system: Release from a jail or prison has long been known to be a period of dramatically higher overdose risk, with mortality risk in the two weeks after release more than twenty-fold the rate of the general population.35 As was shown in
Goal 3: Reward quality care and de-adopt low-value care
Because of the longstanding exclusion of SUD treatment from mainstream health care, SUD treatment is lagging behind in adopting quality measurement and testing new models of care delivery that could deliver quality to beneficiaries and value to taxpayers. It is critical to accelerate efforts to create a market for quality care so that the system is more transparent and easy to navigate. Under the status quo, individuals in crisis must navigate a system that is incredibly opaque and for which there is limited public reporting of quality outcomes.
* Expand the use of quality measurement: the
* Support innovative care delivery models: a proliferation of innovative care delivery models now exist in substance use treatment, including "bridge clinics"42 (interim care locations that can be accessed on a "walk-in" basis), stabilization centers,43 mobile treatment units,44 street outreach teams,45 and co-located services in primary care and community health centers.46 A key advantage of these models is they provide timely onramps to care in settings that may be more accessible or person-centered. Bringing these models to scale, however, requires overcoming challenges with staffing and reimbursement.
* De-adopt low-value care: Low-value care is pervasive in the health care system,47 and unfortunately SUD treatment is no exception. Payers and purchasers need to phase out treatments that do not have demonstrated clinical effectiveness. One potential example is standalone opioid withdrawal management (sometimes called "detoxification") that does not include continuing care in the community,48 another is urine drug testing that is performed multiple times within the same "window of detection" (the amount of time in which drug metabolites can be detected by a test).49 A more complete process for grading the evidence and aligning evidence with coverage decisions could be convened by a national expert body in collaboration with the federal government.
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Conclusion
In closing, the nation is at a pivotal moment to reverse the course of our overdose and addiction crisis. Federal health care programs are an indispensable part of the solution. When a person in crisis does not receive prompt care, and when the system is not there to support their continued engagement with quality services, the risk of tragic outcomes is very high. But we have also seen that when doors to effective treatment are open, people can recover, thrive in their own health, fulfill their potential as neighbors, parents, and coworkers, and contribute to our collective success. I urge the committee to support legislation that removes outdated coverage obstacles and gives providers the tools to provide the highest standard of care to people seeking recovery. Thank you for the opportunity to testify and I would be happy to answer any questions you may have.
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Footnotes:
1. Harper S, Riddell CA, King NB. Declining Life Expectancy in
2. Luo F, Li M, Florence C. State-Level Economic Costs of Opioid Use Disorder and Fatal Opioid Overdose --
3. Spencer M, Garnett M, Minino A. Drug Overdose Deaths in
4.
5. Ciccarone D. The rise of illicit fentanyls, stimulants and the fourth wave of the opioid overdose crisis. Curr Opin Psychiatry. 2021;34(4):344-350. doi:10.1097/YCO.0000000000000717
6.
7. Kariisa M,
8. Friedman J, Godvin M, Shover CL, Gone JP, Hansen H, Schriger DL. Trends in Drug Overdose Deaths Among US Adolescents,
9. Humphreys K, Shover CL. Twenty-Year Trends in Drug Overdose Fatalities Among Older Adults in the US. JAMA Psychiatry. 2023;80(5):518. doi:10.1001/jamapsychiatry.2022.5159
10. Mintz CM, Presnall NJ, Sahrmann JM, et al. Age disparities in six-month treatment retention for opioid use disorder. Drug Alcohol Depend. 2020;213:108130. doi:10.1016/j.drugalcdep.2020.108130
11. ASAM. About The ASAM Criteria.
12. Houston MB. Medicaid's Institution for Mental Diseases (IMD) Exclusion. Congressional Research Services; 2023. Accessed
13. Parish W, Mark TL. The Cost of Adding Substance Use Disorder Services and Professionals to Medicare. Legal Action Center; 2022.
14. Prescription Drug Abuse Policy System.
15. SAMHSA. Methadone Take-Home Flexibilities Extension Guidance. Published
16. Doyle S, McGaffey F, Baaklini V, Gilbard K. Overview of Opioid Treatment Program Regulations by State.
17. Saloner B, Landis RK, Jayakrishnan R, Stein BD, Barry CL. A bridge too far? Distance to waivered physicians and utilization of buprenorphine treatment for opioid use disorder in West Virginia Medicaid. Subst Abuse. 2022;43(1):682-690. doi:10.1080/08897077.2021.1986882
18. Meiselbach MK, Drake C, Zhu JM, et al. State Policy and the Breadth of Buprenorphine-Prescriber Networks in Medicaid Managed Care. Med Care Res Rev MCRR. Published online
19. Bradley K, Wishon A, Donnelly AC, Lechner A. Network Adequacy for
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21. Larochelle MR, Bernstein R, Bernson D, et al. Touchpoints - Opportunities to predict and prevent opioid overdose: A cohort study. Drug Alcohol Depend. 2019;204:107537. doi:10.1016/j.drugalcdep.2019.06.039
22. Saloner B, Chang HY, Krawczyk N, et al. Predictive Modeling of Opioid Overdose Using Linked Statewide Medical and Criminal Justice Data. JAMA Psychiatry. 2020;77(11):1155. doi:10.1001/jamapsychiatry.2020.1689
23. Koyawala N, Landis R, Barry CL, Stein BD, Saloner B. Changes in Outpatient Services and Medication Use Following a Non-fatal Opioid Overdose in the West Virginia Medicaid Program. J Gen Intern Med. 2019;34(6):789-791. doi:10.1007/s11606-018-4817-8
24. Larochelle MR, Bernson D, Land T, et al. Medication for Opioid Use Disorder After Nonfatal Opioid Overdose and Association With Mortality: A Cohort Study. Ann Intern Med. 2018;169(3):137. doi:10.7326/M17-3107
25. Samples H, Nowels MA, Williams AR, Olfson M, Crystal S. Buprenorphine After Nonfatal Opioid Overdose: Reduced Mortality Risk in Medicare Disability Beneficiaries. Am J Prev Med. 2023;65(1):19-29. doi:10.1016/j.amepre.2023.01.037
26. Owens PL, Moore BJ. Racial and Ethnic Differences in Emergency Department Visits Related to Substance Use Disorders, 2019.
27. D'Onofrio G, O'Connor PG, Pantalon MV, et al. Emergency Department-Initiated Buprenorphine/Naloxone Treatment for Opioid Dependence: A Randomized Clinical Trial. JAMA. 2015;313(16):1636. doi:10.1001/jama.2015.3474
28.
29. Clingan SE, D'Ambrosio BM, Davidson PJ. Patient brokering in for-profit substance use disorder treatment: a qualitative study with people with opioid use disorder and professionals in the field. BMC Health
30. Huhn AS, Hobelmann JG, Strickland JC, et al. Differences in Availability and Use of Medications for Opioid Use Disorder in Residential Treatment Settings in
31. Beetham T, Saloner B, Gaye M, Wakeman SE, Frank RG, Barnett ML. Therapies Offered at Residential Addiction Treatment Programs in
32. RS 40:2159.1 - Residential Substance Use Disorder Facilities.
33. OASAS Services: General Provisions: Title 14 NYCRR Part 800.; 2022. Accessed
34. CA DHCS. Medication Assisted Treatment in Residential Treatment Facilities. State of
35. Cooper JA, Onyeka I, Cardwell C, et al. Record linkage studies of drug-related deaths among adults who were released from prison to the community: a scoping review.
36. Green TC, Clarke J,
37. Maruschak LM, Minton TD, Zeng Z, BJS Statisticians. Opioid Use Disorder Screening and Treatment in Local Jails, 2019.
38. Saloner B. A Chance to Modernize Health Care behind Bars -- Section 1115 Medicaid Inmate Exclusion Waivers. N Engl J Med. 2023;389(16):1449-1451. doi:10.1056/NEJMp2307641
39. Williams AR, Mauro CM, Feng T, et al. Performance Measurement for Opioid Use Disorder Medication Treatment and Care Retention. Am J Psychiatry. 2023;180(6):454-457. doi:10.1176/appi.ajp.20220456
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41. Medicaid and
42. Taylor JL, Wakeman SE, Walley AY, Kehoe LG. Substance use disorder bridge clinics: models, evidence, and future directions. Addict Sci Clin Pract. 2023;18(1):23. doi:10.1186/s13722-023-00365-2
43.
44. Chatterjee A, Baker T, Rudorf M, et al. Mobile treatment for opioid use disorder: Implementation of community-based, same-day medication access interventions. J Subst Use Addict Treat. 2024;159:209272. doi:10.1016/j.josat.2023.209272
45.
46. NIDA. Medication Treatment for Opioid Use Disorder in the Federally Qualified Health Center Setting. NIDAMED. Published
47. Colla CH, Morden NE, Sequist TD, Mainor AJ, Li Z, Rosenthal MB. Payer Type and Low-Value Care: Comparing Choosing Wisely Services across Commercial and Medicare Populations. Health
48. SAMHSA. Detoxification and Substance Abuse Treatment.
49. Incze MA. Reassessing the Role of Routine Urine Drug Screening in Opioid Use Disorder Treatment. JAMA Intern Med. 2021;181(10):1282. doi:10.1001/jamainternmed.2021.4109
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Original text here: https://www.finance.senate.gov/imo/media/doc/040924_saloner.pdf
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