Thursday, December 29, 2011

Tennessee Proposes New Regulations Harmful to Patients, Quality Treatment and Best Practice

National Alliance for Medication Assisted Recovery
Press Release

Contact Persons:
Joycelyn Woods, Executive Director,
Roxanne Baker, President,
Phone/Fax: 212-595-NAMA

On December 19, 2011 the state of Tennessee is proposing new regulations for methadone. A hearing is scheduled for January 5, 2012 (State will accept written comments until January 19th).

Here are some of the proposed regulations:

The screening process: Patient must have two documented unsuccessful attempts at detoxification or drug-free treatment within a 24-hour period. (Page 14)

Dose: Doses greater than 100 milligrams of methadone requires written notification to the SOTA, greater than 120 milligrams need SOTA approval prior to administration and greater than 140 milligrams shall include a peak and trough test. (Page 21)

Take Home Medication: Patients on a monthly with 1 positive drug screen will be put on a weekly schedule for two weeks or more. (Page 24)
Administrative Discharge for Drug Use: A fourth positive drug test in 6 months will result in immediate discharge or ASW. (Page 26)

Central Registry: A propsed Central Registry with no comment on how confidentiality will be maintained or even where it will be stored. (Page 29)

It must also be noted that many new proposals in the new regulation are good treatment, however they appear cumbersome resulting in excessive paper work so counselors do not have quality time to see patients. There must be a better way to do it such as the federal government whose regulations are very basic while the treatment requirements are in the accreditation guidelines. This also allows the federal the make changes when necessary without approval from Congress. Like the first federal regulations the Tennessee proposed regulations are written with good intent but the result is likely not to be what was intended.

Tennessee Needs Our Help

Patients and residents of Tennessee that are family please follow the instructions in the attached Announcement. A copy of the legislators in the state Senate and Assembly is included. You should also send a copy to the Secretary of State and TN SOTA whose addresses are below.

Out of State Patients the Hearings scheduled for January 5, 2012 needs to have patients write their feelings and why some of these regulations hamper recovery rather than support it. You can send a letter to the following:


Tre Hargett
State Capitol
Nashville, TN 37243-1102
Phone: (615) 741-2819


Kurt Hippel, Esq.
Tennessee Department of Mental Health
Office of Licensure and Review
4255th Ave. North, 3rd Floor
Cordell Hill Building
Nashville, TN 37243

Jason Carter
Cordell Hull Bldg. 5th Floor
425 5th Ave. North
Nashville, TN 37243
Phone: (615) 532-6736
Fax: (615) 741-6602

Download Announcement
Download TN Senate Members
Download TN Assembly Members
Download Proposed TN Regulations

Download Press Release (PDF)

Revised: January 6, 2012

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