TAKE ACTION! Tell HHS to Expand Access to Specialty Addiction Treatment!

SUBMIT YOUR COMMENT TO THE FEDERAL REGISTER HERE. DO NOT COMMENT BELOW - IT WILL NOT BE READ BY HHS. Comments are due by 5:00 pm ET on May 31. 

Your voice is needed! HHS's recently released proposed rule on Medication Assisted Treatment for Opioid Use Disorders proposes to raise the buprenorphine patient limit for qualified physicians from 100 to 200 patients. While the proposal is a step in the right direction, it misses several important opportunities to expand access to care.

Most importantly, as written, the proposed rule does NOT include physicians who are board certified in addiction medicine by the American Board of Addiction Medicine (ABAM) among those eligible for the higher patient limit.

Please use the draft language below to tell HHS that ABAM-certified physicians should be eligible for the higher patient limit based on their extensive and rigorous education and training in addiction medicine. Please consider personalizing your comments to include information about your training, your practice and your patients to highlight why ABAM-certified physicians should be considered eligible for the higher patient limit.

ASAM's full and final comment letter is available HERE. It addresses additional aspects of the proposed rule, such as the criteria for qualified practice settings, new formulations, and reporting requirements. Please feel free to use ASAM's comment letter as a template for your own submission.

SUBMIT YOUR COMMENT TO THE FEDERAL REGISTER HERE. DO NOT COMMENT BELOW - IT WILL NOT BE READ BY HHS. Comments are due by 5:00 pm ET on May 31.

DRAFT LANGUAGE

I recommend in the strongest terms possible that the opportunity to qualify for a higher patient limit be broadened to include those addiction specialists with ABAM certification by striking the term “subspecialty” from §8.610(b)(1). This change would align the eligibility requirement with the concept of “board certification” as defined in §8.2, which includes board certification in addiction medicine from ABAM. As written, the eligibility requirement is unclear; “subspecialty board certification” is not defined anywhere in the proposed rule but implies that only physicians with subspecialty board certification in addiction psychiatry from the American Board of Psychiatry and Neurology (ABPN) or subspecialty board certification in addiction medicine from the American Osteopathic Association (AOA) would qualify for the higher patient limit based on their medical education and training. If that is indeed the case, the proposed rule is forfeiting a valuable opportunity to expand access to high-quality addiction treatment.

There are currently 3,644 U.S. physicians certified by ABAM, but only 1,088 physicians with an addiction psychiatry subspecialty certification from ABPN, and 7 physicians with a subspecialty board certification in addiction medicine from AOA. As currently written, the proposed rule appears to categorically exclude the vast majority of the addiction specialist physician workforce from the opportunity to treat additional patients. These are physicians who have demonstrated advanced expertise in addiction medicine through a rigorous board examination and have dedicated their medical careers to treating patients with the disease of addiction. Excluding these physicians would surely and severely limit the impact of the proposed rule and perpetuate the current addiction treatment gap.

While addiction medicine was recently recognized as a multi-specialty subspecialty by the American Board of Medical Specialties (ABMS) under the American Board of Preventive Medicine (ABPM), it will still be several years before any physician will be able to claim “subspecialty” board certification in addiction medicine under ABPM, and many ABAM-certified physicians will never be eligible for subspecialty board certification under ABPM:

• ABPM has yet to announce when it will offer the first ABMS-level addiction medicine exam for subspecialty certification. It will be no sooner than 2017. If no exam is offered in 2017, it will not be until 2019 that some current ABAM diplomates and other physicians who have completed an addiction medicine fellowship could claim ABMS certification. 
• Physicians who passed the 2015 ABAM exam will not be required to recertify under ABPM to claim ABMS board subspecialty certification. However, only 392 of the 539 who passed the exam will be eligible for the ABMS-level certificate and it is unknown when it will be awarded to them (although it’s been indicated that it will not be until the first cohort of successful ABMS examinees are awarded their certificates).
• Current ABAM-certified physicians with a primary ABMS board certification who are younger than 65 on July 1, 2016 will have until at least until 2022 to sit for the ABMS addiction medicine exam. (Physicians with a primary ABMS board certification who are 65 or older on July 1, 2016 will not be required to take the ABMS exam and will receive a time-unlimited certificate from ABAM when the transition period ends.)
• Current ABAM-certified physicians without a primary ABMS board certification (940 total physicians including 328 osteopathic physicians) are ineligible for ABMS subspecialty certification in addiction medicine. These physicians will also receive a time-unlimited certificate from ABAM when the transition period ends.

Given that it will be at least one year until any physician can claim “subspecialty” board certification in allopathic addiction medicine, and that it may be five years or more until the majority of the ABAM-certified addiction specialists are able to complete the ABMS exam and claim “subspecialty” board certification, and that a large fraction of the addiction specialist workforce will never be able to claim “subspecialty” board certification, I urge SAMHSA to remove the requirement that physicians hold “subspecialty board certification” in §8.610(b)(1) and clarify that all physicians with a “board certification” in addiction medicine or addiction psychiatry as defined in §8.2 be eligible to apply for the higher patient limit.