This comment letter is part of the USC-Brookings Schaeffer Initiative for Health Policy, which is a partnership between Economic Studies at Brookings and the University of Southern California Schaeffer Center for Health Policy & Economics. The Initiative aims to inform the national health care debate with rigorous, evidence-based analysis leading to practical recommendations using the collaborative strengths of USC and Brookings. The original version of this comment was submitted to the Department of Health and Human Services on January 26, 2023.
Richard G. Frank, Keith Humphreys, and Haiden Huskamp submitted a comment letter in response to a recent proposed rule issued by the Substance Abuse and Mental Health Services Administration (SAMHSA) to solicit public comment on its proposal to modify its regulations regarding medications for the treatment of opioid use disorder (MOUD) such as methadone and buprenorphine.
Richard G. Frank
Director - Economic Studies, USC-Brookings Schaeffer Initiative for Health Policy
Senior Fellow - Economic Studies
Esther Ting Memorial Professor and Professor of Psychiatry - Stanford University
Haiden A. Huskamp
Henry J. Kaiser Professor of Health Policy - Department of Health Care Policy, Harvard Medical School
The authors note that the challenge for regulators is to find the “sweet spot” between an overly restrictive system that is hard for patients to access and an overly lax system that results in harms to patients and to the community. Broadly speaking, the U.S. has regulated opioid agonist MOUD strictly relative both to other countries and to what makes for an accessible treatment system.
They believe that the fundamental impulse behind the proposed rule to relax monitoring is the right one. However, they describe that the challenge now is to proceed cautiously and to continue evaluating whether the optimal point has been achieved or whether significant new harms emerge in the coming years due to regulatory relaxation.
Read the full comment letter here.
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Haiden Huskamp's contribution to this letter was funded in part by a grant to her institution from the National Institute on Drug Abuse, NIDA P30 DA035772. Other than the aforementioned, the authors did not receive financial support from any firm or person for this article or from any firm or person with a financial or political interest in this article. The authors are not currently an officer, director, or board member of any organization with a financial or political interest in this article.