Opioid treatment programs (OTPs) must submit a plethora of information on their services to the Substance Abuse and Mental Health Services Administration (SAMHSA). Office-based outpatient treatment (OBOT) providers who prescribe buprenorphine must submit exactly nothing, it appears.
On May 20, we asked SAMHSA, “How is office-based treatment with buprenorphine working, since the patient cap was increased from 100 to 275 in July of 2016? How many patients are getting treatment? What kind of treatment are they getting? Are doctors reporting anything?”
On May 23, SAMHSA responded: “The only MAT data we have would be from N-SSATS, and that doesn’t include private practitioners.” (N-SSATS is the National Survey of Substance Abuse Treatment Services.)
SAMHSA then provided this statement: “SAMHSA promotes access to medication-assisted treatment for opioid use disorder through training of providers (e.g., physicians, nurse practitioners, and physician assistants). For example, the 4,151 buprenorphine prescribers who have increased their patient limit from 100 to 275 represent the potential to treat up to 726,425 additional people with opioid use disorder. Starting with the 2019 National Survey on Drug Use and Health [NSDUH], SAMHSA is planning to include questions on the use of medication-assisted treatment among Americans for the treatment of opioid and alcohol use disorders.”
The Actual Number, Please; Not the Potential Number
We explained that we were asking about the actual number of patients being treated, not the “potential” number. “There is no mechanism for that,” was SAMHSA’s response. That’s why they’re going to use NSDUH, which self-reports—not from everyone, but from a selected sample. They extrapolate the information from the sample.
Either SAMHSA is getting reports from doctors and not telling anyone about it, or is not getting reports from doctors.
So, SAMHSA requires the waiver that allows providers to prescribe buprenorphine for treating opioid use disorder; SAMHSA allows doctors to prescribe to no more than 275 patients; and then SAMHSA collects no data from doctors on what they are actually doing: how many patients are being treated, whether they are going over the cap [the maximum they can prescribe to], whether they are referring patients for counseling, or testing urine for traces of drug use, or anything else.
It was only after we sent SAMHSA a link to their own reporting form (https://www.surveygizmo.com/s3/3854276/Mandatory-275-Waiver-Report/) that we got this response: “The purpose of those reports is to verify that people are either being provided with or referred to counseling. At this time, our Policy Lab is working to further analyze the incoming data and determine how it can be used.”
“SAMHSA would have been better positioned if they would have gone through with their last Federal Register notice, which would have collected data from the physician practices that wanted to treat over 100 patients,” said Mark Parrino, MPH, president of the American Association for the Treatment of Opioid Dependence (AATOD). “SAMHSA lost its opportunity to have any insight on what is happening in these practice settings.”
Kelly J. Clark, MD, president of the American Society of Addiction Medicine (ASAM), noted that significantly more physicians have requested a waiver to treat up to 275 patients than the Department of Health and Human Services (HHS) had anticipated. The final rule estimated that 1,150 physicians would request the waiver in the first year, and a total of 1,950 by the end of five years. As of May 22, there are 4,151 physicians with waivers to prescribe to up to 275 patients, as SAMHSA stated. “This is a significant increase in physician prescribing capacity,” said Dr. Clark.
The Required Data . . . Aren’t Available
Dr. Clark said that physicians with waivers to prescribe to up to 275 patients are required to report their average number of patients, by month, as well as other statistics. But these data are not, as SAMHSA said, available.
Clark added that mid-level practitioners are now prescribing buprenorphine as well as physicians.
As of May 18, a total of 11,491 nurse practitioners (NPs) and physician assistants (PAs) have registered for the free 24-hour training that ASAM offers, in collaboration with AANP and AAPA. Already, over half of those who have registered have completed the training, she said. ASAM is compiling the results of surveys of the NPs and PAs. “We want to learn more about their experience with the training, patient care and other educational needs.”