AFFP feels that the steps to up the number of patients under care for opioid use disorders can be overburdening to the physicians. The new proposals are being championed by the Substance Abuse and Mental Health Services Administration, SAMHSA and will need the physicians to track patients progressively after they have received medical associated treatment (MAT) due to opioid disorder. But M.D. Robert Wergin, AFFP’s Board Chair, wrote a letter to the Acting Administrator Kana Enomoto expressing reservations that administrative tasks may increase.

What the proposed rules entail

The new rules proposed by SAMHSA highlights specific requirements that practitioners will have to adhere to. The physicians will be required to keep an exhaustive documentation of the opioid use disorders patients’ progress. Some of the things to be documented include:

Buprenorphine patients’ average monthly caseload
What is the percentage of active buprenorphine users?
How many patients have finished a treatment?
What is the percentage of patients who opted to drop buprenorphine?

The key issue of concern is that the rules only increase the documentation that physicians will be performing without improving patient care. AFFP suggested that the needed information can be sourced from sources like prescription drug monitoring program databases. Since physicians need the prescription history of their patients, AFFP asked SAMHSA to see to it that the information is available in an online system and is easy to use.

Wergin Letter to SAMHSA

In his letter to SAMHSA, Wergin urged the federal body to carefully into the matter whether claims data meets some of the requirements of a report. He said that SAMHSA should use claims data not to create burdens but collect the vital information.
Wergin listed other options that can be used for data collection instead of having to burden the busy practices. It is important to shield off more tasks considering now that physicians treat as many as 275 patients requiring MAT, which is a rise from the previous 100 patients.

Wergin went on to explain that the reporting requirements will not bring any improvements to patient care but instead will add undue burden of reporting the progress of 275 patients. He insisted that the need to report the status of not only the current patients under treatment but also those who have gone through in the past one year was unwarranted.

Primary care practices do not have the privilege to get updates about the status of a patient who received a referral. They are also not notified in case there is a discontinuation in the behavioral health consults. Wergin suggested that to make the process less burdensome, the primary care providers can report the number of patients who got treatment in a year and those who are still active in the treatment.

He said that AFFP acknowledges that the disposition of patients who are out of treatment should be tracked but mentioned it is not possible for a physician to have the disposition of all the patients.