The Substance
Abuse and Mental Health Services Administration (SAMHSA)
U.S.
Department of Health and Human ServicesAttn: SAMHSA 4162-20
5600 Fishers Lane
Room 13N02B
Rockville, MD 20857
To Whom It
May Concern:
Since
its beginning methadone treatment has been demonstrated to be the most
effective treatment for narcotic addiction, resulting in the termination of
heroin use and of criminal behavior. In spite of this success, methadone
treatment is often disparaged as a “substitute drug” by those who ignore the
positive benefits that it has clearly brought to society. These attitudes
negatively impact on opiate treatment programs in a variety of ways, but it is
the methadone patients themselves who are particularly stigmatized and harmed.
With the introduction of buprenorphine it was hoped that the public would gain
a greater understanding of opiate addiction and treatment. However, this has
not occurred and rather than improving the situation buprenorphine patients
experience the same discrimination and stigma as patients receiving
methadone. The atmosphere will not
change as long as there is no organization or formal mechanism for patients
receiving Medication Assisted Treatment (MAT i.e. methadone and buprenorphine)
to voice their own needs and to form a strong unified public presence on their
own behalf. The National Alliance for Medication Assisted Recovery (NAMA
Recovery) is an organization of methadone and buprenorphine patients, healthcare
professionals, friends, and associates working together for greater public
understanding and acceptance of MAT. NAMA Recovery has 25 chapters across the United States and 15
international affiliate chapters from England to Denmark and India to
Australia, providing information, education and advocacy support to patients
receiving MAT. As the premier national advocacy
organization for MAT patients NAMA Recovery will actively respond to the issues
that affect the daily lives of MAT patients and work towards the day when they
can take pride in their accomplishments.
The NPRM for 42 CFR Part 2 recognizes that the regulation was enacted out of great concern about the potential abuse that disclosure of substance use information can create for persons in treatment and that the release of substance use information can cause individuals with substance use disorders to not seek needed treatment. When confidentiality is not maintained, the trust of the patients will be lost and many will not remain in treatment while those who do continue in treatment will have lost the trust in the clinic and the staff which is indispensable to successful patient treatment.
While NAMA-R recognizes that SAMHSA is attempting to create an
appropriate balance between preserving the confidentiality rights of substance
use disorder patients and the sharing of electronic health information we
believe that currently there are not enough technologic safe guards in
place. In addition the fines for any
violation of the NPRM like the current rule are very low and would be
meaningless to many institutions.
Health
information technology offers a greater opportunity to promote the health of
individuals and the health of community.
However, sacrificing the wellbeing of a person seeking help for a
substance use disorder in the name of convenience or administrative efficiency
is not a constructive way to achieve it for either the person or their
community when individuals avoid treatment for fear of retribution and discrimination.
NAMA-R recommends that changes in 42 CFR Part 2 be temporarily set
aside until the technology is available to protect persons with a substance use
disorder.
Thank you
for your consideration.
Sincerely,
Joycelyn
Woods, M.A., CMA
Executive DirectorDownload PDF
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