Archive for AATOD

AATOD Letter to SAMHSA Regarding SMA-167

June 5, 2015

Summer King
Reports Clearance Officer
I Choke Cherry Road
Room 2 – 1057
Rockville, MD 20857

Re: Federal Register Notice Vol.
80, No.65 Notification Form
(SMA – 167)
Dear Ms. King,

I am writing in response to the Department’s notification with SAMHSA conceming data collection activities for DATA 2000 reporting. I am specifically referencing the notification form (SMA-167) that SAMHSA uses with regard to provider notification as part of the Drug Abuse Treatment Act of 2000 and its subsequent amendments.

The Department’s primary question is whether the proposed collection of information, obtained through the above referenced notification form, is necessary for the proper performance and functions of the Substance Abuse and Mental Health Services Administration. The obvious answer from our Association’s point of view is yes. Our Association represents approximately 1,000 Opioid Treatment Programs (OTPs) throughout the U.S., which are all certified through SAMHSA.

We think it is important when any DATA 2000 practitioner wishes to increase the number of patients being treated as part of their practice from 30 to 100 patients to provide sufficient information to SAMHSA to guide SAMHSA’s decision making.

We believe that it is fair to state that SAMHSA does not currently collect adequate information about the care being provided within DATA 2000 practices. Illustratively, no one has any idea of how many patients are treated through DATA 2000 practices at any given point in time. No one has any centralized data on what kinds of services are offered to patients, including counseling and other clinical support services, beyond the prescribing of Schedule III opioids to treat opioid addiction. No one has any idea if DATA 2000 practices are conducting toxicology testing to guide therapeutic decision making. No one has any centralized data collection with regard to DATA 2000 practices checking PDMP databases either prior to admitting the patient and throughout the patient’s care.

These are not academic questions. Accurate lesponses will provide SAMHSA with an understanding if the existing DATA 2000 practices are following SAMHSA’s Best Practices recommendations in treating opioid addiction (TIP 40), in addition to the recently released National Practice Guidelines from the American Society of Addiction Medicine.

In our judgment, SAMHSA should collect such information on a routine basis from DATA 2000 practices. This kind of information could easily be captured as such practices are transitioning from a 30 patient capacity to a 100 patient capacity.
In order to avoid significant burden to DATA 2000 practitioners who are filing such forms, the form could simply add a few basic elements that answer the following important patient care questions:

  • How many patients are currently in treatment and how many patients do
    you intend to care for?
  • What kinds of clinical support services do you provide to your patients
    directly? Through case management referral?
  • Do you check PDMP databases before the patient is treated and
    throughout the patient’s care?
  • On average, how long does the patient remain in continuous treatment in
    your practice?
  • What is your patient drop out rate?
  • Do you conduct toxicology tests during the course of the patient’s care?
    If so, what is the frequency of toxicology collection and what drugs are
    being tested?
  • What percentage of patients have discontinued the use of illicit drugs?

These are some basic questions that should be added to the form, in addition to the currently collected information including the state medical license number, DEA registration number, address of primary location, telephone, fax, and email addresses to gain an understanding of the type of care being provided in DATA 2000 practices.

From our Association’s point of view, adding such elements to the form will provide SAMHSA with some of the basic information that it should have as part of its decision making to certify such DATA 2000 practices and provide increased opportunities to treat patients in their practices. Further, it will allow SAMHSA to understand whether these practices follow best practice guidelines, as contained in SAMHSA’s Clinical Guidelines for the Use of Buprenorphine in the Treatment of Opioid Addiction (TIP 40), as referenced above, and the recently released and comprehensive National Practice Guideline for the Use of Medications in the Treatment of Addiction Involving Opioid Use (American
Society of Addiction Medicine).

Thank you for taking these comments into account.

Sincerely yours,
Mark W. Parrino

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Opioid Treatment Program Survey

The American Association for the Treatment of Opioid Dependence, Inc. (AATOD) is conducting an evaluation of hepatitis and Opioid Treatment Programs (OTPs). Each OTP in the country is encouraged to complete this brief survey in order to acquire up-to-date information about hepatitis and OTPs.

The survey is web-based, user-friendly and can be completed within 15-20 minutes or less. If you have an OTP with multiple locations, please note that the survey should be completed for each location. Your responses are analyzed by a third party and will be kept confidential.

To begin the survey, please CLICK HERE or cut and paste this link into your web browser:

We appreciate your willingness to participate and value your feedback. Thank you if you already completed the survey. However, please forward this survey invitation to any other OTP within the United States.

If you have any questions, please email

Thank you!

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2015 AATOD Conference in Atlanta, GA

2015 AATOD Conference

>> Click to download the full conference PDF


Letter from the Conference Chair

Dear Friends and Colleagues,

On behalf of the American Association for the Treatment of Opioid Dependence, Inc.
(AATOD), it is my pleasure to invite you to the 2015 AATOD Conference being held
March 28–April 1, 2015 at the Hyatt Regency in Atlanta, Georgia. The 2015 Conference
is sponsored by the Georgia Department of Behavioral Health and Developmental
Disabilities along with the Opioid Treatment Providers of Georgia.

AATOD has a history of providing an outstanding conference which continuously
strives to provide conference attendees with new and exciting avenues for learning and
growth, 2015 will be no different. In fact, for this conference we will have a first ever
Documentary Screening. The documentary The Fix: The Feeling is Mutual is one way
to accomplish this. What a unique opportunity to be both enlightened and trained! The
conference will be filled with an abundance of other opportunities to socialize with
those in the Medication Assisted Treatment (MAT) field and to gain knowledge about
opioid overdose prevention, research within MAT, current ideas, and issues through Hot
Topic Round Table Discussions, and a variety of other treatment related concerns. One
of the most important issues that will be addressed at this conference will be the health
crisis America faces as it relates to opioid dependence.

The conference theme is “Addressing a Public Health Crisis: Opioid
Dependence” and the event comes at a unique time in American history. In their
2014 National Drug Control policy, President Obama, and the Office of Drug Control
Policy (ONDCP) proclaimed that the United States is in an Opioid Epidemic. In
addition, ONDCP has officially stated “we are significantly bolstering support for
Medication Assisted Opioid Treatment.” It is important for us to take the opportunity
of MAT becoming more recognized and accepted as a valid and essential piece of the
recovery puzzle. We have a responsibility to those we treat to remain proficient in our
knowledge of treating this disease. Our plenary speakers have been chosen to assist
us in reaching this goal. To name a few, we expect CDC Director, Dr. Thomas Frieden,
SAMHSA Administrator, Pamela Hyde, and ONDCP Director, Michael Botticelli as
featured speakers.

The largest gathering of the MAT community will be at the 2015 AATOD Conference.
AATOD and its membership are the authority on MAT. Although these modalities of
treatment have been available since the 60s, with growing support there is a renewed
interest in MAT. This conference has been designed to meet the needs of everyone
from novice personnel to seasoned MAT providers, with offerings of the Clinicians
Course, Workshops, Hot Topic Round Tables, Patient Advocate Training, and vendors
for products and services that will benefit clinic business. This conference is intended
for anyone who has an interest or concern about the opioid epidemic we are facing.
It is our hope that this event is a catalyst for change in this public health crisis. Your
participation is vital to the success of the conference.
Please join us for the 2015 AATOD Conference in Atlanta.

Jonathan P. Connell, MA
2015 AATOD Conference Chair

>> Click to download the full conference PDF

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AATOD Letter to Secretary Burwell

Please see letter below sent to the Honorable Sylvia Mathews Burwell, Secretary of the
U.S. Department of Health and Human Services from Mark  W. Parrino, AATOD President.

Burwell_Letter 8-13-14 | Alcoholism and Drug Abuse Weekly August 11 2014


Dear Secretary Burwell,

I am writing you pursuant to correspondence that you had received, dated June
26,2014 from five US Senators. They were discussing their concerns about
untreated opioid addiction in the United States, and indicated that the
Department might have the ability to raise the patient cap for DATA 2000
practices without Congressional authorization.

I understand that the Department will be considering a number of policymaking
initiatives in order to respond to the current public health crisis of untreated
opioid addiction in our country, including the use of buprenorphine products in
certified DATA 2000 practices and Opioid Treatment Programs (OTPs). At the
present time, we have conducted a survey among the nation’s State Opioid
Treatment Authorities and AATOD member programs, concluding that
buprenorphine is an underutilized medication in the OTPs based on the lack of
reimbursement through third party payers.


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Federal Policy Guidance Document released by CMS on July 11, 2014

The Centers for Medicare & Medicaid Services (CMS) released an informational bulletin with respect to services available under the Medicaid program to individuals with a substance use disorder (SUD).

You will find the reference on page 2 of this Federal Policy Guidance Document to be of interest, “Medication Assisted Treatment is the use of FDA approved medications in combination with evidence based behavioral therapies to provide a whole patient approach to treating SUDs.”

The Informational Bulletin can be accessed on HERE.

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Jackson Lewis Newsletter For AATOD Members – July 23, 2014

Welcome to our eighth newsletter for AATOD members, where we highlight recent developments in employment law that should be of particular interest to your membership. Links are provided to our website, blogs, and other sources for more detailed information, or, you may contact the attorneys listed below directly. For specific employment law questions, you may speak to one of our attorneys through the Risk Management Hotline we have created for AATOD by calling 1-866-220-0946. To access the articles discussed below, press Control Click on the link.

New York Becomes 23rd State To Enact Medical Marijuana Law
The Governor of New York signed on July 7 New York’s Compassionate Care Act, which will permit limited use of medical marijuana by individuals suffering from covered medical conditions, making New York the 23rd state to legalize the use of medical marijuana.
EEOC Issues Controversial Pregnancy Discrimination Guidelines
In a controversial move, the EEOC has issued Enforcement Guidance on Pregnancy Discrimination and Related Issues, along with a “Q&A” document about the guidance and a Fact Sheet for Small Businesses.
Inflexible Leave Policy is Fair, Lawful and Protects Disabled Employees, Says Tenth Circuit
The EEOC has sued numerous employers, alleging that their “inflexible leave policies” were unlawful because they did not take into account the possibility of the employer’s providing additional leave as a reasonable accommodation. Those employers have agreed to pay, literally, millions of dollars to settle those cases. But now, the U.S. Court of Appeals for the Tenth Circuit has not only rejected the idea that inflexible leave policies are inherently discriminatory, but has gone even further and has recognized that such policies “can serve to protect…the rights of the disabled” by ensuring fair and uniform treatment.
New Minnesota Medical Cannabis Law Protects Employees From Discrimination For Medical Marijuana Use
Minnesota’s new Medical Cannabis Act, signed into law on May 29, 2014, differs from many other state medical marijuana laws in that it narrows the kind of medical cannabis permitted. It also offers considerable protections to applicants and employees in the workplace.
Yes, A Person Can be Criminally Prosecuted for Violating HIPAA
As reported by, a former hospital employee is facing criminal charges brought by federal prosecutors in Texas for alleged violations of the privacy and security requirements under the Health Insurance Portability and Accountability Act (HIPAA).
A Court Affirms Workers’ Compensation Determination Requiring Employer to Reimburse Employee for Costs of Medical Marijuana
A New Mexico intermediate appellate court has affirmed a workers’ compensation judge’s determination that an employer and its workers’ compensation carrier are required to reimburse an employee for costs associated with the purchase of medical marijuana.
EEOC Letter Finds GINA and ADA Issues in Fit-For-Duty Medical Examination Form
A local government entity’s request for employee family medical history as part of an annual fitness-for-duty medical exam “clearly violates Title II of GINA,” according to an informal discussion letter from the EEOC Office of Legal Counsel.


Follow our Drug and Alcohol Testing Blog
The Jackson Lewis Drug and Alcohol Testing Law Advisor will help you keep up with the latest developments in workplace drug and alcohol testing laws, and will provide insight on related issues, including drug testing technologies, trends in drug and alcohol abuse, and avoiding discrimination when employees have substance abuse problems.


About Jackson Lewis P.C.
Founded in 1958, Jackson Lewis, dedicated to representing management exclusively in workplace law, is one of the fastest growing workplace law firms in the U.S., with over 770 attorneys practicing in 55 locations nationwide and Puerto Rico.

For more information, please contact:
Paul J. Siegel, (631) 247-4605
Kathryn J. Russo, (631) 247-4606

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AATOD Letter to Attorney General Eric Holder

Mark W. Parrino, President of the American Association for the Treatment of Opioid Dependence, Inc. (AATOD) shared a link to an important letter to Attorney General Eric Holder, dated April 10, 2014, which was signed by sixteen US Senators. The Senators are urging the Attorney General to work with all of the branches in the Department of Justice to utilize the federally approved medications to treat opioid addiction “in combination with counseling”. “Specifically, the Department should initiate a multi-state program utilizing anti-addiction medications to support successful reentry into society of opioid addicted offenders from various correctional settings.” He asks us to join him in supporting this approach and clearly the sixteen Senators understand the benefit of providing access to Medication Assisted Treatment for opioid addiction in the Criminal Justice setting.

Additional Resources:


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ATOD’s Response to Proposed Rule on Disposal of Controlled Substances

“We particularly appreciate the sensitivity of providing such guidance to the county at a time of increasing prescription opioid abuse and addiction.  These proposed regulations expand the entities to which ultimate users may transfer unused, unwanted or expired controlled substances for the purpose of disposal as w ell as the methods by which such controlled substances  mayb e collected.”

Click Here to read the entire letter on on AATOD’s response to

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