MISAM Presses for Changes in the Regulation of MAT

On September 1^st, the Michigan Society of Addiction Medicine (MISAM) sent a letter to Director Hawks of the Michigan Department of Licensing and Regulatory Affairs (LARA) to highlight concerns about the department’s regulation of medication for addiction treatment (MAT). Specifically, MISAM identified state rules requiring mandatory scheduled drug-testing and imposing numerical limits on the prescription of buprenorphine and naltrexone as harmful for addiction specialist physicians (ASPs) and patients in Michigan.

In the letter, MISAM expressed support for a regulatory framework that facilitates the safe practice of MAT while also safeguarding against improper behavior. However, MISAM’s letter argued that LARA’s current posture on drug-testing conflicts with medical best practice, as outlined by the American Society of Addiction (ASAM) Medicine’s National Practice Guidelines and Drug-Testing Guidelines. Contrasting LARA’s drug-testing rule, this guidance states that “decisions about the type and frequency of testing should be made by the ordering physician.” As a result, LARA’s mandatory drug-testing rules diminish the discretionary authority of ASPs to craft their own individualized treatment plan based on patient needs. Additionally, MISAM also argued that LARA rules which impose limits on the number of patients that ASPs are allowed to treat with buprenorphine and naltrexone are out of alignment with the federal standard set by the Substance Abuse and Mental Health Service Administration’s (SAMHSA) guidance. By going beyond the federal standard, LARA’s regulation of buprenorphine and naltrexone sets artificially high requirements that ultimately restrict patient access to these lifesaving treatments.