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Authors Posts by Jason Snyder

Jason Snyder

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Despite opposition and concerns from substance use disorder (SUD) treatment providers, single county authorities, primary contractors, and behavioral health managed care organizations, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) will begin licensing telehealth-only SUD treatment providers.

DDAP will issue a licensing alert on Wednesday, December 4, detailing the new licensure category.

Organizations newly licensed under this tele-only category will be able to provide intake, evaluation, and referral services, as well as outpatient treatment, including partial hospitalization services, via telehealth only, without a physical plant location in Pennsylvania.

DDAP’s intention in licensing telehealth-only providers is to hold them to the same standards as facility-based providers as a way to ensure equity and maintain operational standards. DDAP will continue to monitor complaints and unusual incidents for all licensed providers, as well as the number of telehealth-only license applications that are made over time, looking for any trends that could require additional action.

RCPA and its provider members opposed creation of the new license, citing patient safety and quality concerns, as well as potential erosion of the community-based provider system. RCPA hosted DDAP for a discussion about its concerns, met one-on-one with the department, and provided written feedback to DDAP. In addition, RCPA met with the governor’s Policy Office, to discuss provider concerns.

DDAP will attend RCPA’s next SUD Committee meeting at 11:00 am on Tuesday, December 10. RCPA has asked DDAP to discuss the new license category. RCPA members wanting to attend this meeting can register here.

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As RCPA previously communicated, the Drug Enforcement Administration (DEA), jointly with the U.S. Department of Health and Human Services (HHS), has extended the temporary COVID-19 telemedicine flexibilities through December 31, 2025. These flexibilities enable prescribing of controlled medications via telemedicine. As such, the Pennsylvania Department of Drug and Alcohol Programs’ (DDAP) suspension of 28 Pa. Code § 715.9(a)(4), which allows an initial evaluation for a person who will be treated by an opioid treatment program (OTP) with buprenorphine to be completed via telehealth, is also extended.

DDAP’s complete Information Bulletin 03-2024 is available here.

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On behalf of its opioid treatment program (OTP) provider members, RCPA submitted comments to the Independent Regulatory Review Commission (IRRC) in support of a final-omitted regulation that would allow an initial physical examination required for prescribing, administering, and dispensing controlled substances through an OTP to be conducted via telehealth under certain circumstances under Pa. 49 Code § 16.92.

This final-omitted regulation would enable the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to grant a statewide exception to 28 Pa. Code § 715.9(a)(4), which today requires Pennsylvania OTPs (called narcotic treatment programs in DDAP regulations) to conduct a face-to-face determination of whether an individual is currently physiologically dependent on an opioid.

IRRC will consider the final-omitted regulation at a public meeting on December 5.

In its comments, RCPA wrote:

“Enabling OTPs to conduct the initial examination required as part of induction into methadone or buprenorphine treatment through telehealth significantly improves and expedites patient access to the gold standard treatment for OUD without sacrificing quality or safety. In a treatment environment where finding qualified physicians, physician assistants and certified registered nurse practitioners is challenging, telehealth bridges a significant gap. Physicians would no longer need to be physically on site at the OTP where treatment is to take place to examine a patient as part of the induction process. Rather, from anywhere in the commonwealth, a physician can examine more patients, who can then begin treatment with medication faster at a facility near their home. In fact, with this final-omitted regulation, OTPs will have the ability to accommodate same-day or walk-in admissions instead of scheduling intake appointments days later.”

The final-omitted regulation, submitted by the Department of State, Bureau of Professional and Occupational Affairs, State Board of Medicine, along with comments in support from the Department of Drug and Alcohol Programs and RCPA, can be viewed on the IRRC website.

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Photo by Chris Montgomery on Unsplash

Registration is now open for the 32nd Annual PA Forensic Rights and Treatment Conference, titled “What We Know: Myths or Facts.” Sponsored by Drexel University’s Division of Behavioral Healthcare Education, College of Medicine, the virtual conference will be held December 4 and 5 with both live and pre-recorded presentations addressing topics such as trauma-informed care; working with victims of trafficking and partner violence; neuro and gender diversity; and identifying methods to enhance belonging and inclusion.

The conference brochure includes the schedule, workshop descriptions, plenary bios, and registration information. CE credits will be available.

For more information, email Drexel or visit the BHE conferences website.

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To address Pennsylvania’s high maternal mortality rate, the Commonwealth, through a partnership with Governor Shapiro’s office and the Departments of Health, Human Services, Drug and Alcohol Programs, and Insurance, is developing a statewide Maternal Health Strategic Plan. Interested stakeholders are invited to share their opinion through the Commonwealth of Pennsylvania’s Maternal Health Strategic Plan survey, which will remain open through November 4.

The vision for Pennsylvania’s Maternal Health Strategic Plan is a Pennsylvania where every pregnant and birthing person has easy access to high-quality perinatal, birth, and postpartum care that is person-centered, comprehensive, equitable, and affordable and that results in healthy outcomes and long-term good health and well-being.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) announced the availability of $9 million in funding to expand or enhance recovery support services for individuals in recovery from opioid use disorder (OUD) and other substance use disorders (SUD).

DDAP will award approximately six grants of up to $1.5 million each. Applicants must have at least two years of experience as of July 1, 2024, in providing recovery support services and be able to demonstrate the capacity to provide those services to individuals in recovery from OUD and other concurrent SUDs.

DDAP is placing a focus on health equity as a part of this grant opportunity. Based on a variety of criteria from the Pennsylvania Department of Health’s 2022 overdose death data, DDAP will select two grantees located in Philadelphia, two grantees located in Allegheny County, and two grantees from the remaining 19 qualifying counties located within Pennsylvania with a crude death rate higher than the state average.

Funding for these grants is provided through the federal Substance Abuse and Mental Health Services Administration’s (SAMHSA) State Opioid Response (SOR) IV grant program. The SOR program aims to help reduce unmet treatment needs and opioid-related overdose deaths nationwide through state-by-state allocations.

Read the full press release.

You can send questions electronically regarding the grants and the application process.

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Photo by National Cancer Institute on Unsplash

This week, the Drug Enforcement Agency (DEA) submitted a final rule regarding virtual prescribing of controlled substances to the White House’s Office of Management and Budget (OMB). Though the final rule is not yet publicly available, the OMB registry posting, titled “Third Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications,” suggests an extension is coming that will go beyond the current expiration date of December 31, 2024.

Without a new rule or extension of the current flexibility beyond December 31, virtual prescribing of controlled substances without a prior in-person evaluation would no longer be allowed.

DEA received more than 38,000 public comments following its proposed rule in February 2023 for telemedicine prescribing of controlled substances. Subsequently, the telehealth flexibilities were extended to the current December 31, 2024, expiration date.

RCPA will continue to monitor progress on the final rule and communicate the details of the final rule once it is made public.

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Act 66 of 2023 requires the Pennsylvania Department of Drug and Alcohol Programs (DDAP) to conduct quarterly evaluations on workforce issues, including the barriers to entry into the workforce and efforts to address it. Results from this survey, which also asks providers which of the regulatory flexibilities enabled through Act 66 they are using, will be used to provide an annual report to the General Assembly. The report will only include aggregated – not provider-specific – data. Surveys must be completed by Oct. 25, 2024. The survey is available online. Email all questions regarding this survey to DDAP’s Bureau of Program Licensure.

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The Pennsylvania Department of Health (PA DOH) and Philadelphia Department of Public Health (PDPH), in collaboration with the Center for Forensic Science Research & Education (CSFRE), are providing virtual trainings to clinicians and non-clinicians on best practices for caring for individuals with xylazine-associated wounds. These trainings are offered at no-cost to attendees.

The trainings will be offered in two separate two-hour sessions for individuals and organizations working in Pennsylvania.

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