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TNSAM Provides Feedback on New OBOT/OTP Rules

On December 15th, the Tennessee Society of Addiction Medicine (TNSAM) sent a letter to the Tennessee Department of Mental Health and Substance Abuse Services (TDMHSAS) highlighting several areas for revision from their recently proposed rules relating to office-based opioid treatment (OBOT) and opioid treatment programs (OTPs).
In the letter, TNSAM praised TDMHSAS for setting universal standards for providers in the state of Tennessee. However, TNSAM identified areas for improvement within the proposed rules. These recommendations revolved around enhancing provider flexibility to offer evidence-based care and enhance patient retention. For example, TNSAM urged TDMHSAS to reconsider their buprenorphine dosing standards, citing evidence for higher dose buprenorphine in the age of high potency synthetic opioids (HPSOs). Further, TNSAM urged TDMHSAS to reconsider strict dosing caps for methadone in OTPs. TNSAM noted that the dosage caps are only found in three states including Tennessee. TNSAM also urged for the final OTP take-home rules to be aligned with SAMHSA’s most recent guidance on the matter.