A federal agency is taking steps to enable physicians to care for more patients with opioid use disorders, but the AAFP is concerned that new reporting requirements in a proposed rule could be overly burdensome.
The proposed rule(www.gpo.gov) from the Substance Abuse and Mental Health Services Administration (SAMHSA), published in the July 8 Federal Register, would require physicians to track the progress of patients who receive medication-assisted treatment (MAT) for opioid use disorders.
In an Aug. 5 letter(2 page PDF) to Acting Administrator Kana Enomoto, M.A., AAFP Board Chair Robert Wergin, M.D., of Milford, Neb., outlined the Academy's general support for expanding MAT but also expressed reservations about increasing administrative tasks.
The proposed rule lists specific, detailed reporting requirements that practices would be expected to follow. Wergin pointed out other methods that are available to collect the data without creating more tasks for busy practices. Avoiding unnecessary work is especially important now that physicians can treat as many as 275 patients with MAT, up from the previous cap of 100 patients, a change that the AAFP supported.(3 page PDF)
"The AAFP strongly urges SAMHSA to examine whether claims data could be used as a source for meeting some of the reporting requirements," Wergin wrote. "Claims data for patients using insurance should be piloted by SAMHSA as a way to collect the necessary information without imposing additional reporting burdens on MAT prescribers before these reporting requirements are implemented."
The proposed rule calls on physicians to document the progress of patients who receive treatment for opioid use disorders in exhaustive detail including
- the average monthly caseload of patients who receive buprenorphine,
- the percentage of active buprenorphine patients who receive behavioral health services,
- the number of patients who complete treatment and
- the number of patients who choose to discontinue use of buprenorphine.
A major concern is that requiring such heavy documentation from physicians only adds to their administrative duties without improving patient care. The AAFP suggested that instead, the information could come from sources such as prescription drug monitoring program databases. And because physicians need information about their patients' prescription history, the AAFP is pressing SAMHSA to ensure that online systems are easy to use.
"We also heard significant concerns that these reporting requirements would do nothing to improve patient care and pose an undue burden to report the status of 275 patients and all the patients currently not in treatment but who had been in treatment in the past year," Wergin wrote.
Primary care practices often are not notified of a patient's status once the patient receives a referral, nor do they get updates if behavioral health consults are discontinued. Wergin wrote that it would be less burdensome to instead report the total number of patients treated in a year and the number who are in active treatment and counseling.
"While the AAFP acknowledges the need to track the disposition of patients no longer in treatment, it is not always possible for a physician to know the disposition of every patient who has dropped out of treatment," he wrote.
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