1.   What is the major change that will affect patients?

A major change is the new takehome schedules. Patients must be in compliance.

First Quarter in Treatment patients are eligible for one takehome a week
Second Quarter two takehomes per week
Third Quarter three takehomes per week
Fourth Quarter six takehomes per week, i.e. once a week pickup
Year One in Treatment 14 day takehomes/twice a month pickup
Year Two and on 31 day takehomes/once a month pickup

Patients taking LAAM will have the same takehome schedule.

2.   Do the new regulations allow programs to dispense pills?

Yes, the restriction to dispense only liquid medications has been eliminated. Patients will be allowed to have medication in solid (pill) form. So patients with 31 day takehomes should just receive one bottle of pills, per month.

3.   What if my Program does not want to implement these new takehome schedules and other provisions of the new Federal Regulations?

Unfortunately, although these are Federal Regulations, individual states and programs can still have their own, more stringent, regulations. But, the new regs clearly state that OTPs that do not substantially comform with the Federal Opioid Treatment statndards will risk losing SAMHSA certification. If a program is not SAMHSA certified, it does not operate. If your state has stricter regulations, contact your State Methadone Authority, and lobby for adoption of the Federal Regulations in your state.

4.   Does CSAT have to be notified if patients on doses higher than 100mgs get takehomes?

No, this reporting requirement has been eliminated. Any patient with a dose over 100mgs can have takehomes. There is no mention of 100 mgs. mentioned in the Federal Regulations.

If you are restricting your dose to under 100mgs in order to keep your takehomes, this is no longer necessary. Go to your program and get your dose raised, if necessary. If your program has a dose cap policy in effect after May 18, 2001, please contact Watchdog at staff@atwatchdog.org and report this to us. The proper officials will be notified about the violation.

5.   Are there any changes in the U/A requirements?

No, the same federal requirement of eight random u/a’s per year remains. But, if your program uses observed” u/a’s, this will no longer be allowed under the new accreditation guidelines. The guidelines are very clear that program wide observed u/a’s are not necessary. And the Fed Regs do not require testing for marijuana.

6.   Do the regs make any provisions for patient grievances?

The SAMHSA/CSAT Accreditation Guidelines, as well as the accreditation standards developed from them, include provisions for accepting and acting upon patient grievances. For the first time, patients will have access to a formal grievance procedure, through CARF and JCAHO, the accrediting agencies; and through CSAT, which will be implementing an 800 number soon for patients to call, all across the country.

7.   Do the new regs address fees that programs charge?

No, there is no mention of fees. And, there have been reports of programs around the country raising their fees to cover “accreditation”. This is an area that needs to be watched, carefully. Contact your ARM chapter if your program is raising fees to cover accreditation.

8.   Do the new regs allow any doctor to prescribe methadone to treat opiate addiction?

No. Current regulations enforced by the DEA do not permit DEA registered doctors to prescribe narcotic drugs, including methadone and LAAM, for the treatment of opiate addiction. But any doctor with a narcotics license can prescribe methadone for pain. This has not changed. If your private physician is interested in becoming an Office Based Opioid Treatment (OBOT) provider, and treating your opiate addiction, there are resources available. Contact ARM at www.arm-advocates.org, or your local ARM chapter, listed below. Also, Robert Lubran at CSAT can assist physicians who want to become OBOT providers. Mr. Lubran can be reached at 301-443-7745 or rlubran@samhsa.gov. CSAT is very interested in assisting physicians with OBOT.

For more information on methadone maintenance treatment go to: The CSAT MMT Advocacy site.

Chris Kelly
DC-ARM