The new Methadone Federal Regulation Proposal states that when the new Regs take effect, all MMT clinics will have to be accredited. JCAHO has been kind enough to compile a list of questions and answers patients might have about clinic accreditation. We hope this helps MMT patients understand a little bit more about clinic accreditation and how our treatment will be affected. Please post any comments or questions you have to the Watchdog Forum.

1.     What is accreditation and how does it differ from regulations?

Accreditation is a system of using state of the art standards to evaluate the effectiveness, quality and safety of an organization delivering care. Accreditation bodies are usually private non-profit agencies. Standards and processes used by accrediting agencies are reviewed and, if necessary, revised on an ongoing basis, seldom less often than annually. This means that accrediting bodies have the capability of responding to changes in the field rather quickly. The goal of accreditation is to enable an organization (program) to constantly improve the quality of the services that it provides through a process that employs professionals who are knowledgeable about opioid addiction treatment.. Using this process, these health care professionals visit a methadone clinic to evaluate it under the relevant accreditation standards. Accredited organizations must also be in compliance with applicable federal, state, and local laws and regulations. In the event that an accreditation standard differs from a regulation, the regulation will prevail.

Regulations are governmental rules establishing minimum standards, based on existing laws. Regulations can be enacted by federal, state, and/or local government. They insure safety and establish a "floor", below which licensed organizations cannot fall. Sometimes regulations and/or the laws upon which they are based can be influenced by several factors, including but not limited to funding and politics. Regulations usually do not change rapidly. However, regulations are necessary to protect the public and insure that organizations providing services adhere to all applicable laws.

2.     Will accreditation force programs to close? If so, are accrediting agencies responsible for insuring that patients continue to receive treatment if their program closes.?

Accreditation evaluates programs, based on the standards of the accrediting body. All accrediting bodies have several possible "accreditation outcomes", e.g. Accreditation, Accreditation with recommendations, one-year accreditation (CARF), conditional accreditation, three-month abeyance (CARF), non-accreditation, etc. The less desirable outcomes can be appealed by the program to the accrediting body. In the proposed change of federal regulations governing narcotic treatment, the Substance Abuse and Mental Health Services Administration (SAMHSA) intends to allow existing programs to operate without becoming accredited for a reasonable period of time after the regulation changes. This is being done so that programs may easily manage the transition to the new accreditation system. It is also possible that SAMHSA may grant exceptions under the proposed rule. This could result in SAMHSA allowing a treatment program to exist without it having been accredited. This would only happen in extreme cases involving unusual circumstances. The majority of programs participating in the pilot study have become accredited and those that have not have appeared to need just a little more time to make the changes that are required.

Accreditation, therefore, does not close programs. Programs choose to operate (or not) in an effective manner, focusing on quality and the patients that they serve. Given the continued need for treatment, the field will probably continue to expand. However, accrediting agencies are not treatment programs and, therefore, do not place patients or open new programs if a program closes. The accrediting bodies will, however, quickly review new treatment programs so that services can resume in a timely manner.

In the unlikely circumstance that a program has to closed because it cannot obtain or retain state approval or SAMHSA approval, it is very likely that the state government and the federal government would become involved in seeking treatment alternatives for the patients affected. This might involve finding another treatment provider to move in to operate a facility or arranging for patients to be transferred to a neighboring program. This has been done in the past in a number of states in which programs have closed, before the new accreditation system was even proposed.

3.    Will program policies change if the program becomes accredited (fees, dosing, hours, take-home)?

Some program policies will change as part of the accreditation process and some will change as a result of the change in federal regulations. The focus of accreditation is quality services to the patients. Programs are encouraged to treat patients with dignity, preserve patient rights, inform patients of program policies, review policies on an ongoing basis, and evaluate their own program performance in an effort to continuously improve delivery of care. Therefore, in an atmosphere of continuous improvement, it is hoped that policy changes will occur whenever data collected suggests that a change is in order.

4.     Can patients speak with surveyors?

Yes. Accrediting bodies have mechanisms in place to receive consumer input as part of the accreditation process. In fact, accrediting bodies want to hear from patients and community members and have set up mechanisms so that these important individuals can be heard during an accreditation survey.

5.     How do patients complain to an accrediting body and how fast are the complaints resolved?

Patients can complain to an accrediting body, on site, as part of the survey process; by writing to the accrediting body; or by calling the accrediting body. Keep in mind that accrediting organizations do not accredit just methadone programs, and therefore, are responsible for accrediting thousands of organizations. Complaints are logged in and compared with other complaints from similar programs or the same program. Complaints are also evaluated as to type of complaint. This means that complaints that reflect a flaw in policy or overall service delivery are treated differently than complaints that only pertain to a specific individual. If necessary, an accrediting body may visit an accredited program based on the number and/or type of complaints that it has received. Patients should continue to use their program's grievance procedures, state agencies and advocate organizations to resolve conflicts of an urgent nature.

6.     Clinics not only differ from state to state—they also are different within a state. Will accreditation make them all "look alike" (same policies).

No. Accreditation's goal is not for all treatment programs to "look alike". Programs need to develop their mission and policies to fulfill that mission based on the population served, applicable laws, regional realities, size of program, funding realities and other considerations. Just like all patients should not have same treatment plan, programs should not have the same policies. However, all programs accredited by the same accrediting organization are surveyed using the same standards. In this way, there is a uniform way to evaluate program effectiveness.

7.     Will accreditation make a difference in my rights as a patient?

Patients have a lot of rights, including but not limited to: the right to be treated with dignity, to be informed about their medication and involved in plans for treatment; to reasonable policies regarding fees; to know their dose and be able to review their records, under supervision; and to conflict resolution. Accrediting bodies have many standards directly and indirectly related to the rights of patients. Accreditation will insure that programs deliver treatment in the context of preserving patient's rights.

8.     What does it take to be a surveyor?

Surveyors are professionals in their areas of expertise. For example, surveyors visiting behavioral healthcare programs, such as methadone treatment programs, are doctors, nurses, psychologists, social workers, and mental health and addictions professionals. Most have a masters's degree or above and have worked in various types of organizations, including methadone programs, community mental health centers, criminal justice settings, hospitals and adolescent treatment centers. They have experience in patient care and administration. They are also specifically trained to apply the standards to the type of program being surveyed. They are reviewed annually by their supervisors and treatment programs are encouraged to give feedback to the accrediting body, after the survey, regarding their satisfaction with the surveyor and the survey process. The accrediting bodies encourage surveyors to keep up with the latest treatment issues through continuous education, sponsored by the accrediting body and/or other agencies and schools.

9.     Which accrediting body is the best?

This question does not have an easy answer. If the rules are changed to require methadone treatment programs to become accredited, the federal government must approve the accrediting bodies before they may begin to accredit methadone clinics. Part of the approval process involves federal approval of the methadone-specific standards used by the accrediting body, to ensure that they reflect the best-known practices in treatment. Accrediting bodies have different characteristics and, therefore, programs should choose the accrediting body that best fits the characteristics of the program being surveyed. These program characteristics include size, organization (are they part of a larger agency or do they stand alone); location (urban or rural); patient population served; community characteristics and expectations; funding; number of sites; and current accreditation status, among others.

10.     Will accrediting bodies be available to help with local controversies, such as in communities suffering from the NIMBY (Not-In-My-Back-Yard) syndrome?

Accrediting bodies are willing to send experts (surveyors or central office staff) to speak to community groups, provider associations and other groups about accreditation and how it enhances the delivery of care. Often, these speaking engagements are initiated at the request of the community organization due to something controversial. It is not the role of the accrediting body to convince a community to accept a specific type of treatment. In other words, the accrediting body will not recommend that a community open a methadone treatment program but it will discuss how effective an accredited methadone treatment program can be in addressing some of the fears that some communities have.