Opioid Crisis Response: Key Opportunities and Challenges for Hospitals and Health Systems

On October 24, 2018, President Trump signed H.R. 6 into law. More formally known as the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act, H.R. 6 is a follow-up to the last bipartisan opioid crisis-focused legislation, the 2016 Comprehensive Addiction and Recovery Act (CARA).

Like CARA, the SUPPORT Act takes sweeping aim at the opioid crisis, focusing on numerous aspects of opioid prevention, treatment, and recovery, including expansion of opioid use disorder (OUD) treatment access and capacity in residential and inpatient care, medication assisted treatment (MAT), and via telehealth and improving medical education and training resources for health care providers to better address addiction, pain, and the opioid crisis.

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The takeaways for hospitals and health systems from H.R. 6 include both important specific requirements and strategic trends in addressing opioid related activities.

Hospitals and health systems should pay particular attention to new regulatory and reimbursement requirements, as well as the evolution in best practices reflected in the SUPPORT Act.

Expanding Focus on Social Determinants Relevant to OUDs

Expanding Focus on Social Determinants Relevant to OUDs 

H.R. 6 highlights an investment into and focus on other critical social determinants relevant to OUDs.

  • Section 7183, the CAREER Act, is intended to improve resources and wraparound support services for individuals in recovery from a SUD in the transition from treatment programs to independent living and reintegration into the workforce.
  • Section 7031, the Ensuring Access to Quality Sober Living Act, requires HHS to develop best practices for operating recovery housing (shared living environments free from alcohol and illegal drug use and centered on peer support and connection to services that promote recovery from substance-use disorders).

The ability to focus on social determinants appears to be an essential piece of supporting the initial decision to seek treatment and preventing relapse. At the same time, traditional reimbursement mechanisms do not provide funds to meet these needs.

Traditional reimbursement mechanisms do not provide funds to meet these needs.

Hospitals and health systems should consider opportunities to identify resources offering housing and transitional support for patients in treatment and recovery from OUDs and to provide information and as seamless a transition as possible.

Perhaps the biggest opportunity for all health care organizations is to improve training to prevent opioid dependency.

  • Section 7101 of H.R. 6 expands medical education and training resources for health care providers to better address addiction, pain, and the opioid crisis.
  • Section 6092, the Combating Opioid Abuse for Care in Hospitals (COACH) Act, requires CMS to publish guidance for hospitals on pain management and OUD prevention strategies for Medicare beneficiaries.

Additional lessons for hospitals are likely to be forthcoming.

  • Section 6104 prohibits hospital patient pain surveys (unless the questions address the risks of opioid use and the availability of non-opioid alternatives).
  • In their place, the Treatment, Education, and Community Help (TEACH) to Combat Addiction Act, Section 7101, requires SAMHSA to designate Regional Centers of Excellence in SUD Education to improve pain management and SUD education by developing evidence-based curricula for health care professional schools.
  • Section 7121 also requires SAMHSA to award grants to establish or operate at least ten comprehensive opioid recovery centers across the country to conduct outreach and provide a full continuum of treatment and recovery services, including job-placement assistance.

Training also extends to Medicare beneficiaries:

  • Section 6021 requires CMS to provide Medicare beneficiaries with educational resources regarding opioid use and pain management, as well as descriptions of covered alternative (non-opioid) pain management treatments.

Some hospitals have focused specific training efforts on naloxone administration, enabling greater numbers of patient family members and loved ones, as well as first responders, to act quickly in response to overdoses.

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H.R. 6 is extensive. It highlights legal changes not only related to evolving compliance requirements but also to best practices in reducing opioid risks and improving outcomes in treatment of opioid and other substance use disorders.

It really does take a village.

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References:

Pub. L. No. 115-271 (2018).

Pub. L. No. 114-198.

Dep’t of Health and Human Servs., Office for Civil Rights, How HIPAA Allows Doctors to Respond to the Opioid Crisis, https://www.hhs.gov/ sites/default/files/hipaa-opioid-crisis.pdf. 

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