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OTP

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The American Association for the Treatment of Opioid Dependence (AATOD) is hosting a free webinar from 12:30 pm – 2:00 pm Wednesday, September 24, on states’ and treatment providers’ response to the Substance Abuse and Mental Health Administration’s updated regulations governing opioid treatment programs (OTP). The updated regulations, in place since October 2024, are intended to increase accessibility to and flexibility within OTPs, including methadone treatment for opioid use disorder.

Registration for the webinar is required.

The webinar builds on the July 2025 presentation that provided guidance to OTPs on the updated regulations. Presenters will share how states and treatment providers are complying with the regulations and how patients have benefited through increased access, retention, and treatment flexibility.

The discussion will serve as a prelude to AATOD’s policy discussions at the upcoming national conference in Philadelphia, October 4 – 8, 2025.

The webinar will also be available on-demand via the AATOD website. Certificates of Attendance will be provided upon request. For questions, email AATOD.

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Close-up of Hands holding pens and making notes at the conference

The Substance Abuse and Mental Health Services Administration (SAMHSA) is hosting an in-person workshop “Implementing the Revised 42 CFR Part 8 Regulations in Opioid Treatment Programs,” from 8:00 am – 5:00 pm on Tuesday, August 12 at the Penn Harris Hotel in Camp Hill, PA. Register online by Friday, August 8.

This full-day, in-person workshop will review the revised federal regulations for opioid treatment programs (OTP) and provide practical guidance for implementation. Topics will include:

  • Overview of the 42 CFR Part 8 updates;
  • FDA-approved medications for opioid use disorder (MOUD);
  • Practitioner discretion in care delivery; and
  • Screening, admission, and assessment protocols.

Who should attend: Clinical, counseling, and administrative OTP staff

Continuing education: Eligible participants will receive a certificate for 8 CME/CEU credits (practitioners, nurses, social workers, and other healthcare providers).

If you have any questions, please send them electronically.

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Photo by CHUTTERSNAP on Unsplash

The 2025 American Association for the Treatment of Opioid Dependence (AATOD) Conference will be held October 4 – 8 in Philadelphia at the Philadelphia Marriott Downtown. The 2025 conference theme is “The Evolving Field of Opioid Treatment.”

AATOD is seeking opioid treatment program (OTP) providers, OTP patients, and friends of the field to serve as volunteers for the conference. Benefits of volunteering include discounted full conference rates or free individual days. More information about volunteering can be found on the AATOD Conference website.

The aim of the AATOD conference is to educate and promote acceptance and integration of medication-assisted treatment options by patients, families, clinicians, the medical system, judicial systems, government, policymakers, social service administrations, and the general public. Presenters will disseminate innovative, evidence-based initiatives and treatment techniques to better serve patients and providers, improve program development and administration, promote integration across the continuum of care, and enhance patient outcomes to assist communities in developing an effective response to this crisis.

The Pennsylvania Association for the Treatment of Opioid Dependence (PATOD), the state chapter of AATOD, is a member of RCPA. Those interested in volunteering or with questions can email Pam Gehlmann, Regional Director for Pinnacle Treatment Centers, who is serving as Host Committee Chair.

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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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The Center for Medicare and Medicaid Services (CMS) has released the Physician Fee Schedule CY 2025 Final Rule. You can view CMS’ press release, fact sheet, and final rule page in the Federal Register for more information. There were critical areas addressed in this year’s Physician Fee Schedule (PFS), including:

  • The extension of some telehealth flexibilities permitted under CMS’ authority absent Congressional action;
  • Updated payment for social determinants of health risk assessments as a part of Opioid Use Disorder intake activities furnished at Opioid Treatment Programs (OTP);
  • The establishment of a new add-on code to account for coordinated care, referral services, and peer supports at OTPs;
  • Payment for safety planning intervention and post-discharge follow-up;
  • The establishment of six G codes that mirror current interprofessional consultation Common Procedural Terminology codes used by practitioners who are eligible to bill E/M visits; and
  • Recognition of responses to CMS’ request for information on Certified Community Behavioral Health Clinics.

For the OPPS Final Rule, please see links to CMS’ press release, fact sheet, and final rule page in the Federal Register. Some highlights from this final rule include:

  • The maintenance of the Partial Hospitalization Program and Intensive Outpatient Program rate structures;
  • Narrowing the definition of “custody” in Medicare’s payment exclusion rule to mitigate barriers to Medicare access by individuals who have recently been released from incarceration or are on parole, probation, or home detention; and
  • Changes to Medicaid regulation, allowing states implementing the Medicaid clinic services benefit to cover clinic services outside the “four walls” of behavioral health clinics.

If you have any further questions regarding these final rulings or the application of the “four walls” impacts on Pennsylvania, please contact RCPA COO and Mental Health Director Jim Sharp.

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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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Last Thursday (October 3, 2024), the Pennsylvania Department of State’s Board of Medicine submitted to the Independent Regulatory Review Commission (IRRC) a final-omitted regulation that would allow an initial physical examination required for prescribing, administering, and dispensing controlled substances to be conducted via telehealth under certain circumstances under 49 Pa. Code § 16.92. A final-omitted regulation does not require a public comment period and is in essence an expedited process for proposing a regulation change. IRRC will hold a public meeting on November 21 to approve or disapprove the regulation.

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.

In its Regulatory Analysis Form, the Department of State’s Board of Medicine wrote:

“This final-omitted rulemaking amends the Board’s regulations at § 16.92 by allowing the initial physical examination required for prescribing, administering, and dispensing controlled substances to be conducted by means of telehealth for those patients being admitted into an Opioid Treatment Program (OTP) for treatment of opioid use disorder with either buprenorphine or methadone, provided that the health care provider determines that an adequate evaluation of the patient can be accomplished via telehealth and a full in-person physical examination is completed within 14 days after admission to the OTP. This standard is the same physical examination standard utilized as a result of the Bureau of Professional and Occupational Affairs regulatory waiver issued during the COVID-19 epidemic, which proved to be safe and effective during and after the COVID-19 epidemic. This final-omitted regulation also conforms the Board’s regulations to the Federal opioid use disorder treatment standards as the Board does not wish to unnecessarily maintain a more stringent standard than required by Federal law for OTPs given the continued opioid crisis in this Commonwealth.”

In February 2024, the U.S. Department of Health and Human Services’ Substance Abuse and Mental Health Services Administration (SAMHSA) published a final rule amending the federal regulations for the certification of OTPs in 42 CFR Part 8. The changes to the federal rules were used temporarily to improve access to treatment during the COVID-19 federal public health emergency. SAMHSA has now made those changes permanent, and DDAP intends to implement the updated federal rules and reduce barriers to treatment, as described in its latest Licensing Alert 07-2024. This final-omitted regulation is part of the commonwealth’s process for aligning with the final rule on 42 CFR Part 8.

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Photo by Markus Winkler on Unsplash

The Department of Drug and Alcohol Programs (DDAP) has issued Licensing Alert 02-2024, effective immediately, to inform opioid treatment programs (OTP) about the recent final rule issued by the Substance Abuse and Mental Health Services Administration (SAMHSA) on February 2, 2024, concerning medications for the treatment of opioid use disorder (OUD). RCPA issued an alert to its members on February 1 announcing the final rule.

This rule modifies and updates regulations pertaining to OTP accreditation, certification, and standards for the treatment of OUD. The most crucial aspects of SAMHSA’s final rule include the permanent adoption of COVID-19 era flexibilities, allowing patients to receive more take-home doses of methadone, which is proven to enhance treatment retention and reduce illicit opioid use. The update also permits the initiation of methadone and buprenorphine treatment via telehealth through OTPs and removes stringent admission criteria, thereby improving access to care for individuals in need.

DDAP is currently reviewing the final rule, set to take effect on April 2, 2024, with a compliance deadline of October 2, 2024, and plans to issue a follow-up Licensing Alert soon. For further information, contact the Bureau of Program Licensure.

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