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Authors Posts by Jason Snyder

Jason Snyder

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In its July 15 public meeting, the Independent Regulatory Review Commission (IRRC) disapproved the Department of Drug and Alcohol Programs’ recovery house regulations for licensure in a 4-1 vote. Earlier in the week, the Office of Attorney General and House and Senate committees approved the regulations.

DDAP intends to revise the regulations to respond to IRRC’s concerns and resubmit the regulatory package as soon as possible. The latest draft of the regulations are available on IRRC’s website.

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Photo by National Cancer Institute on Unsplash

The Substance Abuse and Mental Health Services Administration’s (SAMHSA’s) new guide reviews ways that telehealth modalities can be used to provide treatment for serious mental illness and substance use disorders among adults, distills the research into recommendations for practice, and provides examples of how these recommendations can be implemented. The guide is available here.

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The Pennsylvania Department of Drug and Alcohol Programs (DDAP) is reminding drug and alcohol treatment facilities of the availability of the Electronic Reporting System (ERS). This new system makes it easier for providers submitting unusual incident reports to DDAP licensing staff for review. This brochure provides additional information. Providers experiencing technical issues can email DDAP.

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This ASAM Alignment Memorandum establishes a procedure for drug and alcohol treatment providers to request from the Department of Drug and Alcohol Programs (DDAP) additional time beyond July 1, 2021 in reaching substantial alignment with service delivery conditions under The ASAM Criteria, 2013.

Questions regarding this memorandum can be directed to DDAP, ASAM Transition, or Jason Snyder, Director, Drug & Alcohol Division.

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Vital Strategies will host a live webinar from 1:30 pm–3:00 pm Wednesday, June 30, featuring Pennsylvania officials and other stakeholders who will discuss overdose-related trends being seen across the Commonwealth as well as new interventions and opportunities to access bulk, no-cost naloxone for overdose prevention initiatives in your community.

Register here. More information is available here.

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RCPA is working with the legislature, which is working with the governor’s office, to finalize an application process that would allow for an extension from the Department of Drug and Alcohol Programs (DDAP)/the Department of Human Services (DHS) in substantially aligning with the American Society of Addiction Medicine (ASAM), including the PA-specific requirements. The extensions would be approved for up to six months to December 31, 2021.

We will continue to keep you updated on this process. Email Jason Snyder, Director, Drug & Alcohol Division, with questions.

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On June 14, 2021, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) resubmitted to the Independent Regulatory Review Commission (IRRC) its Final-Omitted Regulations on Standards for Drug and Alcohol Recovery House Licensure. As of yesterday afternoon, they are publicly available on IRRC’s website.

The submitted regulatory package includes:

  • the updated regulations (p. 49–78);
  • a regulatory analysis (p. 1–11);
  • a preamble that includes public comments and DDAP response to comments (p. 13–48);
  • a sample recovery house licensing application (p. 79–80);
  • a sample recovery house licensing checklist (p. 81–88);
  • additional DDAP forms (p. 89–101); and
  • a description of forms that must be provided by the recovery house (p. 102–112).

DDAP expects that the new regulations will be in effect by July 2021 and will require compliance with the new regulations by January 2022. More information on drug and alcohol recovery house licensing is available on DDAP’s website.

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As you may know, the Pennsylvania Department of Drug and Alcohol Programs (DDAP) has issued three temporary regulatory suspensions under authority granted by the Governor’s declaration of a disaster emergency due to the coronavirus pandemic. Based on flexibilities granted by the Substance Abuse and Mental Health Services Administration (SAMHSA), DDAP’s goal with these suspensions was to respond to the extraordinary circumstances of the last year by allowing entities regulated by DDAP to continue operating throughout the uncertainty of the pandemic.

On June 10, 2021, the General Assembly passed House Resolution 106, which terminated the Disaster Declaration in whole, effective immediately. However, Governor Wolf signed Act 21 of 2021 on June 11, 2021 to ensure regulatory and statutory suspensions enacted under the Disaster Declaration would continue. Act 21 extends all of the regulatory and statutory suspensions authorized under the Disaster Declaration until September 30, 2021. More information on Act 21 is outlined in this press release from the Governor.

In the table below, you will find the three regulations in which DDAP suspended utilizing the Disaster Declaration. DDAP would like to reiterate that these suspended regulations will continue to be in place until September 30, 2021.

 

Statute/Regulation Statute/Regulation Purpose Waiver benefit/explanation
28 Pa. Code § 715.16(e)

 

 Prohibits narcotic treatment programs (NTPs — methadone clinics) from permitting a patient to receive more than a 2-week take-home supply of medication. In response to COVID-19, SAMHSA is allowing up to 28 days of take-home medications for patients on stable dosages, if the physician deems appropriate.

 
28 Pa. Code § 715.9(a)(4) Requires NTPs to make a face-to-face determination before admission to treatment, for those clients who will receive buprenorphine treatment. In response to COVID-19, SAMHSA is allowing initial evaluations for a patient who will be treated with buprenorphine to be completed via telehealth.
28 Pa. Code § 715.6(d) Requires NTPs to have narcotic treatment physician services onsite. In response to COVID-19, SAMHSA is allowing initial evaluations for a patient who will be treated with buprenorphine to be completed via telehealth.

 

In the coming weeks, DDAP will continue to work with SAMHSA and solicit feedback on the best way to move forward with these suspended regulations to ensure that the drug and alcohol treatment field is able to provide necessary services to patients in the safest, most effective way possible.

Thank you all for your continued work to help better the lives of Pennsylvanians with substance use disorder. If you have any further questions, please do not hesitate to reach out to the Bureau of Program Licensure, Division of Licensing Inspection at (717) 783-8675 or via email.

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