Monday, September 28, 2009


The Substance Abuse and Mental Health Services Administration (SAMHSA) requested comments on the proposed rule ammendment regarding the Federal OTPs dispensing requirements for buprenorphine and combination products. My comments are outlined below.

“Opioid Drugs in Maintenance and Detoxification Treatment of Opiate Addiction; Buprenorphine and Buprenorphine Combination; Approved Opioid Treatment Medications Use”

Current regulations demand of all patients receiving buprenorphine in OTPs (Outpatient Treatment Program) daily attendance for several months followed by rigidly defined criteria for less frequent visits thereafter. In marked contrast, patients receiving buprenorphine outside an OTP setting can receive at the first physician visit a prescription to be filled at any pharmacy for a month’s supply of the medication. The proposed rule-making change eliminates this arbitrary and unwarranted disparity by providing that precisely the same flexibility will apply to OTPs as has governed “waivered” physicians for several years; it is to be welcomed!

The proposed regulatory change, however, is exceedingly narrow in scope, focusing exclusively on the administration, dispensing and prescribing of buprenorphine. In stressing that buprenorphine providers and patients in OTPs shall be obliged to “adhere to all other Federal treatment standards established for methadone” the proposed rule-making notice calls attention to these “other standards,” and they demand comment. To say they are extraordinary would be an understatement; they would appear to be unique in American medicine.

For complete comments click here .


At 3:20 AM, Anonymous Anonymous said...

Dr Newman
I applaud your concern for the community and the courage to stand up to a state of oppression for so many people who need a voice like yours.
I have been so discouraged by the poor care and discrimitory practices of many clinics and even private practices my son has been to. I have never felt so humiliated going to Dr's who should be understanding and sympathetic. I have observed clinics that are cold and uncaring and vague information that is given to patients and their caregivers.
I've seen snyde looks and comments and unfair treatment to others depending on their insurance or appearance. I've waited in clinics where patients were told to wait for hours. I saw cases like my son, where they just gave us a help line and no meds after being there for 8 hrs. I am going to a 2nd addiction specialist, and I won't stop untill I get the respect and quality treatment that we should expect from professional Dr's and the Clinics they work at. Heroin addiction could happen to anyone- even their sons in any community and any income
bracket. The government needs to stop all
discriminatory practice along with the caregivers who look down on Meth and Herion addicts who are seeking treatment.
My son is a Heroin addict in a very nice, highly disired, suburban neighborhood. He is staying clean but is very discouraged by our medical community and the government regulations. Drugs and now Herioin are rampant at our highschools, but no one is admitting to the elephant in the room, or the poor heath services and discriminating practices that are among the clinics and private practices.
Thank You Dr


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