Letter to Mr. Enomoto, Acting Administratot of the Substance Abuse and Mental Health Administration - Call to Implement CARA Provisions Expanding Access to Medication-Assisted Treatment

Letter

Dear Acting Administrator Enomoto,

Thank you for the attention the Substance Abuse and Mental Health Services Administration (SAMHSA) has dedicated to addressing the opioid misuse and overdose epidemic. Following the enactment of the Comprehensive Addiction and Recovery Act (CARA), we are writing to urge you to swiftly implement CARA's Section 303, Medication-Assisted Treatment for Recovery from Addiction. Thank you for your attention to this urgent matter.

As you know, along with Senators Whitehouse and Klobuchar, we worked closely with over 100 advocacy groups to coauthor and pass CARA into law. This bipartisan legislation includes important provisions related to prevention, treatment, recovery, and support for first responders. Specifically, Section 303 of CARA includes language that would allow nurse practitioners (NPs) and physician assistants (PAs) to prescribe medication-assisted treatment (MAT) for a period of 5 years. In the face of the nationwide opioid misuse and overdose epidemic, as many qualified providers as possible are required in order to treat patients who are struggling with an opioid use disorder. That is why we urge SAMHSA to prioritize expediting the release of regulations, including those related to educational requirements, necessary in order to effectively implement the provisions of CARA that allow NPs and PAs to prescribe MAT.

Specifically, in the absence of guidance from SAMHSA, we have heard from NPs and PAs that have questions related to the educational requirements under the law. For example, NPs and PAs are unsure if whether they take the current 8 hour course now, they will be able to count that toward the 24 hour requirement, so long as they have taken the course from one of the approved DATA 2000 organizations approved to provide this education. Additionally, we have heard concerns related to uncertainty regarding how proscriptive SAMHSA will be in certifying new courses based on the new curriculum requirements detailed in the law. The named organizations are eager to develop approved training courses for NPs and PAs, but require adequate direction from SAMHSA in order to proceed.

We also understand that a form permitting NPs and PAs to apply for a waiver will be released for public comment and respectfully request additional details pertaining to this form, including those related to the public comment period and the time until a final rule is issued.

Thank you again for your attention to this matter.

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