NCTR commends the Department for updating the regulations to be more consistent with the American society of Addiction Medicine's (ASAM) guidelines.  As you are aware ASAM is the internationally recognized leader in addiction medicine.  NCTR has been using ASAM guidelines for years and are quite familiar with them.  We reviewed both amendments; the changes to align with ASAM criteria and the enhanced behavioral health services.  Please find below our comments/questions/suggestions.

1. The Medication Assisted Opioid Treatment definition appears to replace the OTP definition and is not applicable to all Medication Assisted Treatment services (MAT) opiates and alcohol MAT.  Is this correct?
2. Medication assisted treatment definition includes alcohol and opioid use disorders.  Thus, medications such as buprenorphine, naltrexone, etc. can be used in licensed treatment programs without having the certification with DHS, DEA and the Board of Pharmacy.  Correct?
3. In the Enhanced behavior health amendments 12-VAC35-105-30 licenses - there is a licensed listed as "Opioid treatment/Medication assisted treatment".  However, this is eliminated in the ASAM amendment.  Is there a MAT license above and beyond a prescriber having the appropriate prescribing authority?
4. We would appreciate some clarification between OTP, OBAT, and MAT.  It appears that the regulations for the Opioid Treatment Programs is for non-residental programs that store, dispense and/or administers methadone.  If we do not use methadone and do not store or dispense other medications, what license do we need to assess, prescribe and monitor induction in a residential and/or OP setting (See #3 above)
5. 12VAC35-105-1520 - 3.7 co-occurring enhanced program: Is there a separate license for this distinction? We consider ourselves a co-occurring program, however we would not be able to have a psychiatrist assess a patient within 4 hours of admission.  This would be cost prohibitive.  Patients are evaluated by a licensed provider prior to admission to ensure the patient is stable enough for our 3.5/3.7 setting.  If a patients needed that quick of an assessment, we would refer to a hospital base program.  Would this mean we could no longer accept patients with co-occurring diagnoses?
6. 12VAC35-105-1570 B: Please add psychiatric NP to list of providers.
7. 12VAC35-105-1630 - 3.1 staff criteria under allied health professionals: Is it possible to add an onboarding period for new hires, such as: newly hired staff must meet all the allied health professional criteria including certification within a year of hire.
8. The definition of Credentialed addiction treatment professional:  Can CSAC working in a licensed treatment program and under the supervision of a licensed professional be included in the definition?
9. The license for residential treatment for women with children has been eliminated.  Does this mean we can no longer admit patients with their children?

Again, thank you for your efforts to bring the regulations in line with the ASAM guidelines.  If we can be of any assistance, do not hesitate to reach out.

Respectfully submitted

NCTR - Pattie Shneeman, LSATP 703-867-8410