On Thursday, President Trump announced that he will declare America’s opioid epidemic a national public health emergency. This designation came at the behest of the President’s Commission on Combating Drug Addiction and the Opioid Crisis’ draft interim report released in August. The opioid epidemic is now the first public health emergency since the H1N1 influenza outbreaks of 2009. The designation aims to enhance access to opioid treatment by easing federal regulations and offering states federal funding flexibility to promote telemedicine. While the official text has yet to be released, expected provisions include:
- Telemedicine Waivers. The designation allows for patients living in isolated areas who are experiencing opioid use disorder (OUD) to be prescribed non-methadone Medications-Assisted Treatment (MAT) without an initial in-person visit as is generally required by law. Today’s announcement did not provide additional specificity on the criteria that will be used to assess the geographic areas that will qualify for the telemedicine waiver.
- Funding Flexibility. The federal government will allow states to shift existing federal grant funds to target interventions toward people living with OUD. The announcement did not offer specific parameters for the funding streams that are eligible for this flexibility.
- Human Capital. The Department of Health and Human Services (HHS) will expedite its hiring processes for positions that will help states combat the epidemic. The number of staff and the nature of how they will be deployed is unclear. The Department of Labor (DOL) will offer Dislocated Worker Grants to people living with OUD, those who have faced barriers to employment due to a past OUD diagnosis, and others who have been dislocated or unemployed because of the epidemic.
Of note, the declaration will expire in 90 days but can be easily renewed.
So What Now?
Thursday’s announcement has the potential to enhance access to much-needed OUD treatment and prevention services. While the declaration offers new resources, potential risks are interwoven within each opportunity. Here are a few salient considerations to maximize provisions under this declaration:
- Braiding and Blending Funding Streams and Resources. The federal government has released a myriad of new funding opportunities and legislation aimed to address the epidemic over the past year. These include the 21st Century Cures Act, Comprehensive Addictions Recovery Act (CARA), and Strategic Prevention for Prescription Drug Misuse grants out of the Substance Abuse and Mental Health Services Administration (SAMHSA). The new resources that are available as a result of the declaration must compel a thoughtful examination of how to integrate these new tools into existing efforts. State governments are particularly well-positioned to curate disparate funding streams into a cohesive implementation strategy that can yield the most effective and efficient outcomes. The economization and coordination of today’s opioid epidemic funding streams should also be held in balance with the uncertain nature of the sustainability of this revenue, and its impact on future staffing, operations, and financial and technological infrastructure.
- Potential Flashpoints as MAT in Telemedicine Meet the Realities of the State Opioid Regulatory Environments. While the today’s declaration may waive the initial in-person visit requirement for people living with OUD in specific geographic areas, treatment stakeholders must still navigate state opioid policies. For example, some states require women of child-bearing age to be given a pregnancy test prior to be prescribing an opiate or opioid of any kind – including those contained in some MATs. Coordinating ancillary services such as a pregnancy test via telemedicine poses challenges. Inherent in this example is the fact that many states have separate regulatory frameworks that guide the prescription of opioids and opiates, and MAT. Prescription drugs like buprenorphine could be subject to both sets of regulation. Additionally, provider organizations may have facility-specific limitations on MAT prescribing. A holistic review of all the regulatory possibilities is needed to soundly implement the telemedicine flexibility from the declaration.
- Don’t Forget about the ‘A’ and ‘T’ in “MAT”. Similar to the ancillary treatment components noted above, healthcare stakeholders who take advantage of telemedicine must also consider how they will quickly scale-up the mental health counseling and psychosocial supports that are proven to decrease the likelihood of relapse. These services are critical to the MAT model and hold clinical, operational, staffing, financial and technological implications for operationalizing the full-spectrum of MAT services via telemedicine.
- Treatment Enhancement Should Not Come at the Expense of Sound Prevention Strategies. Today, four out of five new heroin users turned to the drug after consuming prescription opioids. Curbing the nonmedical use of opioids is essential to addressing the epidemic. Stakeholders must continue to promote the use of prescription drug monitoring programs (PDMP), and consider opportunities to leverage opioid alternatives to manage chronic pain.
On the Horizon
The opioid epidemic may be the defining public health imperative of a generation, and HMA remains committed to supporting our clients throughout their efforts to create positive change.
As stakeholders throughout the country work to mitigate the impact of the opioid epidemic on the public, consideration must be paid to possible future secondary and tertiary public health concerns, including the disruption of the opioid use-to-injection drug use-to HIV/AIDS pipeline. There is still much to learn from the outbreak in Scott County, IN in 2015.
We would love to hear from you. What do you think are the next under-reported impact of the epidemic? What do you think is needed right now in the opioid space?
This blog was written by HMA Senior Consultant Xavior Robinson.