Monday, December 15, 2014

60 Minutes: Insurance Co.'s --A Formidable Barrier to Care

DHMH Should Consider Reviewing All Insurance Denials for Long-Term SUD Treatment

http://www.cbsnews.com/news/mental-illness-health-care-insurance-60-minutes

60 Minutes investigates how insurance companies review claims for long-term residential treatment for mental health disorders.  Connecticut's Sandy Hook Commission calls the insurance review process "a formidable barrier to care", and recommends that "a state agency review all denials".  

Thursday, December 11, 2014

Heroin Action Coalition Legislative / Policy Agenda: 2015
For more information contact: heroinactioncoalition@gmail.com or call 301-525-6183

1)  Awareness Campaign:  Even though advocates worked hard to pass two landmark pieces of legislation: 1) the Overdose Prevention Bill, allowing family members to obtain Naloxone (a drug that reverses overdose); and 2) the Good Samaritan Bill, which allows witnesses of an overdose to call for help without the fear of criminal prosecution, attempts to educate the public on these initiatives that save lives has been sorely lacking.  We need a public awareness campaign to end the stigma surrounding addiction and provide families and friends with these life-saving tools.  

2)  Treatment Capacity:  The state's treatment capacity does not come close to addressing the need --particularly in the area of adolescent and transition-age residential treatment and recovery services.  While advocates support medically assisted treatment (MAT) for those who want it, it should not be considered a substitute for long term residential treatment options which promote abstinence.  Maryland must find a way to maintain a full continuum of treatment options, rather than just those that are the least costly or most profitable.  Funding that was cut from the treatment budget in past years must be restored. 

3) Funding:  In order to close the treatment capacity / need gap, the state must be willing to look at creative funding options and to create public-private partnerships.  Opportunities for funding, similar to the legislation that diverted certain criminal fines to a Crime Victim’s Assistance Program, must be explored.  Similarly, fines from drug-related crimes could be diverted to treatment.

4)  Performance Measures:  Regarding the treatment we do have, there are absolutely no standardized performance measures, and oversight and accountability for treatment providers is nearly non-existent.  This means that our tax dollars are paying for programs, and tax payers have no idea whether they are succeeding at doing the job that they are being paid to do.

5)  Uniform Assessment Criteria:  Maryland has no uniform criteria for assessing the level of treatment an individual needs –even though DHMH claims to use ASAM criteria.  In reality, each individual treatment provider is able to operate under their own criteria, which is often based on the varied and random criteria of various insurance providers.  These multiple and inconsistent standards leave patients and family members caught in the middle --often forced to pay thousands of dollars in out-of-pocket expenses, due to the state's failure to mandate that a unified set of criteria be used throughout the state –by both those providing treatment and those paying for it.  

6)  Integrated Regulations:  Despite huge amounts of tax dollars spent on behavioral health integration over the last four years, there has been absolutely no effort to actually integrate treatment practices and systems --as evidenced by the lack of an integrated set of regulations governing mental health and SUD treatment providers. The discrepancies that exist between basic standards for mental health treatment (with 30 regulations) and SUD treatment (with 8 regulations) are so vast that it causes consumers to wonder what if anything, has actually been integrated.  We must have integrated treatment for co-occurring disorders, and this must be reflected in our Maryland regulations. 

7)  Oversight:  Currently, state leadership is weak. There is little direction or oversight for county health departments.  It is not uncommon for local health department officials to collaborate with for-profit treatment providers in developing local healthcare policies –even when consumers frequently and repeatedly provide evidence of fraud, corruption, abuse, and negligence within local treatment facilities.  A strong statewide leadership base must be established if Maryland is to develop a robust and competent treatment system based on evidence-based best-practices.  

8)  Rehabilitation Not Incarceration: Too many of our transition-age children are being jailed for a treatable mental health disorder which they neither understand nor know how to control.  Incarcerating our state's young adults for symptoms of their substance use disorder is not only costly, unproductive and wasteful --but inhumane and cruel, as well.  We must pass compassionate and rational laws which treat individuals for their mental health disorder, rather than punish them for it. 

9)  SBIRT in Schools:  Our state's schools have failed to play even a minimal role in prevention or awareness efforts, even though a recent statewide survey showed that nearly 25,000 Maryland high school students had used heroin or prescription opiates illegally.  A simple Screening, Brief Intervention and Referral to Treatment (SBIRT) protocol used by school nurses would go far to prevent problems in the early stages when efforts to treat have the highest rate of successful outcomes.  

10)  Family Peer Support:  Currently, there is no voice at the policy table for the families of individuals with a substance use disorder.  All other mental health disorders are represented by our state's mental health advocacy groups, including National Alliance on Mental Health (NAMI), Mental Health Association of Maryland (MHA), Maryland Coalition of Families (MCF), and On Our Own.  However, they have not represented our needs.  If policy that affects our children and our families is to be effective, it is imperative that we have an equal stake in shaping that policy. 

Sunday, December 7, 2014

Hogan to Declare State of Emergency Next Month

During a press conference in Frederick on Friday, Governor-Elect, Larry Hogan repeated his campaign promise to declare a state of emergency upon taking office.  Maryland will then be eligible for more federal funding and support for anti-drug measures.  He also plans to convene a summit of state and national experts on law enforcement, treatment and first-responders to focus on the problem.   Boyd Rutherford, Lieutenant Governor, will oversee the administration's effort to reduce heroin-related crime across Maryland.

Sunday, November 30, 2014

Let's Reconsider HIPAA!




Lawmakers Urged to Ease 

HIPAA Limits for Parents


It is a tragic, terrifying, heart- and gut-wrenching experience for a parent to watch helplessly as the child they've raised from infancy spirals out of control as a young adult, caught in the whirlpool of drug or alcohol addiction or mental illness.

It's an even greater tragedy to bury that adult child, knowing that healthcare information that might have enabled a parent to intervene had been kept from them due to provider interpretations of the chief federal healthcare privacy law.

At a hearing Friday before a House subcommittee, members of Congress heard testimony from three families on whether that law, the Health Insurance Portability and Accountability Act, was harming the people it was created to protect.

One of the parents was Gregg Wolfe, owner of a court reporting and litigation support company in Pennsylvania, who told how his 21-year-old son, Justin, a college student, died of a heroin overdose in December.

“Though doctors knew since May 2011, no one in our family was aware that Justin was using heroin,” according to Wolfe's testimony (PDF) before the subcommittee on investigations and oversight of the House Energy and Commerce Committee. Wolfe said HIPAA was “valuable,” but added there was a “dire need to change the HIPAA law regarding minors and legally emancipated adults who either have a mental disorder, disability or drug and/or alcohol addiction.”

Since the Patient Protection and Affordable Care Act allows parents to retain health insurance coverage for their children until age 26, Wolfe asked that “an exception be added to HIPAA.” Wolfe would give parents access to their adult offspring's medical records if the child has a mental disorder or addiction and maintains legal residence in their parents' homes or lives under the auspices of their parents' care and insurance coverage.

Also testifying, Leon Rodriguez, head of the Office for Civil Rights at HHS (PDF), the chief HIPAA enforcement agency, said that unless the patient objects, healthcare information may be disclosed to parents if the patient is “not present or is incapacitated.” If the patient objects, the rule “respects an individual's wishes to the extent practical and appropriate. (According to Wolfe, his son took pains to hide his addiction from his parents.)

“The ability to assure individuals that their personal health information will remain private is particularly critical in the area of mental health care, where concerns around the negative attitudes associated with mental illnesses may affect individuals' willingness to seek needed treatment,” Rodriguez said.

But Rodriguez also said the law authorizes providers “to alert appropriate persons” if a patient “poses a serious an imminent threat to himself or herself, or to another person,” including a parent or another person “who are reasonably able to prevent the serious and imminent threat,” provided the disclosure is “consistent with applicable law and standards of ethical conduct.”

Providers still need “lots more guidance,” in clear language and “in places where people can find it” about what's allowable under HIPAA, said witness Deven McGraw, a lawyer who heads the Health Privacy Project at the Center for Democracy and Technology, a Washington think tank.

Follow Joseph Conn on Twitter: @MHJConn

Thursday, November 20, 2014

Nearly 25,000 Maryland H.S. Students Have Used Opiates, Including Heroin

Below is the link to the data analysis for the Youth Risk Behaviorial Survey administered to a sampling of middle and high school students in spring 2013.  

Here is some data that may or may not surprise you:

22, 673 Maryland students, 15 or younger, used heroin one or more times during their life.  24, 968 Maryland students, 16 or 17, have used heroin. 

22,808 Maryland students, 15 or younger, have taken a prescription drug (such as OxyContin, Percocet, Vicodin, codeine, Adderall, Ritalin, or Xanax) without a doctor's prescription one or more times during their life.  25, 142 Maryland students, 16 or 17, have as well. 

22,755 Maryland students, 15 or younger, took a prescription drug without a doctor's prescription one or more times during the past 30 days.  25,112 Maryland students, 16 or 17 have as well. 

22,442 Maryland students, 15 or younger, have used a needle to inject an illegal drug into their body one or more times during their life.  24,809 students, 16 or 17, have also done so. 

22,458 Maryland students, 15 or younger, were offered, sold, or given an illegal drug by someone on school property during the past 12 months.  24, 814 Maryland students, 16 or 17, had the same experience. 

Monday, November 17, 2014

On Enabling


It's Lonely at the Bottom

It's easy to throw around terms like "tough love," "enabler," and "rock bottom." Living with those terms is another story.
In an effort to find an answer that leads to treatment for an addict there seems to be a lot of discussion about the tough love approach. Some of those stories include those families who have lost a child to overdose after following the tough love recommendation of a therapist—meaning they estranged themselves until the child reached “rock bottom” and was ready for treatment.

Some move to new homes, towns or even states in an effort to restart their lives, free from the turmoil of a family dealing with addiction. Eventually, for some, their loved one does hit the rockiest of bottoms—they overdose and die alone. I also know parents who followed the tough love advice with success, and recommend it as the only way to help their child and keep their sanity.

Twenty years ago I sat with my son’s therapist to discuss his substance abuse and relapse issues. She couldn’t tell me what my son’s drug of choice was, leaving me to come to my own conclusions which, in retrospect, were a bit naïve. I leaned across her mahogany desk where the timer was ticking away the minutes allotted for my session, looked up at her and asked, “What can I do?”

That was the first time I heard of the concept of tough love. She told me that when he hit rock bottom, he would be ready for a meaningful, long lasting treatment and recovery.

Rock bottom? I wondered what the heck she meant by rock bottom? She explained to me that rock bottom is the hoped for result of tough love—when you love your child enough to remove him from your home, no longer provide him with food or clothing, and basically disassociate yourself from his life until he becomes distraught enough to ask for help—or is jailed or near death. The therapist assured me that he would eventually come begging for my help, and then his recovery could begin.

She told me I had to stop enabling my son and practice tough love.

When he hits rock bottom then it is okay for me to provide him with food and clothing? When he hits rock bottom I can give myself permission to help him? I was confused and I was angry about what she was suggesting. While she talked, my mind wandered back in time to that tiny newborn child who clutched my finger with his little hand like he would never let go because he trusted me to be there for him when he was good, when he misbehaved and yes – when he fell into a place where only a mother’s love lives. And now this woman was telling me to abandon my child – to give up? To turn my back on my first born son? I thought “rock bottom” okay, I get it.

When my son was in the 8th grade he was depantsed in the boy’s locker room while the gym teacher looked on laughing, explaining later that boys will be boys. An hour later the principal called me to tell me they couldn’t find my son at school. I immediately drove to the school and my son was nowhere to be found. The rural school was about five miles from our home and it was raining. I drove slowly along the road looking for my son back and forth twice. Finally I saw what looked like some clothing in the ditch along the road. I stopped my car, got out and found him there soaked, laying in the mud, humiliated and sobbing. Rock bottom, Okay I think I’ve got it now - that was an example.

When my son was in the 12th grade he called me at work to tell me that he loved me and that he didn’t want to live anymore. He felt that God had deserted him and that neither God nor I could protect him from our volatile home situation. He had taken two bottles of pills. After a trip to the ER his stomach was pumped and he was admitted to the adolescent suicide psychiatric unit where he stayed for several months. Okay, I get it - I think he had reached rock bottom.

NO, I said to myself as I was driving back home alone after meeting with this tough love-loving therapist—I will NOT make a conscious decision to sit by and watch my son hit rock bottom before I offer him help. I will love him unconditionally until he feels like he is worth saving. I will love him when he steals from my bank account and hold him in my arms as he apologizes. I will replace the money he took from his brother’s birthday cards and hold his hand as he tells me how ashamed he is. I will sit and rock him as he sobs in my arms after another ruined family outing or holiday. We will sit at length and discuss behavior issues, anger issues, life issues and his self-loathing trying to make sense of it all. I will cry with him as he grieves a failed marriage. I will watch him suffer as he fights with his addiction and when he detoxes. I will cover him with blankets when he shakes uncontrollably and use cold packs to keep his fever down. I will spoon feed him vegetable broth when he can’t keep solid food down. I will buy emergency one way plane tickets. I will do it because I love him unconditionally. I don’t love him any more or less because he made a bad decision in the moment that changed his life forever. I will do it because he is worth saving.

My thoughts wandered back to my own experience with tough love when I was 19 and I remembered an argument with my mother and the ultimatum she gave me as I walked out the door. She said, “If you leave now, when you come back your clothes will be on the front porch.” Right! - I thought as I drove my car out of the driveway. But when I returned the doors were locked and all of my personal belongings were in boxes on the porch. Now that was tough love. The reason for the argument isn’t important here. My mother and I reconciled, and even sometimes laughed about my defiance. I never moved back home. But I will always remember the feelings on that night of hopelessness and feeling abandoned and unloved, not to mention homeless and alone.

So, yes, I was an enabler. I met my son every day where he was at in his life without judgment. I enabled my son to live at home as long as he wanted to. When he moved away I sent him tickets to come home when he needed to. When he called crying because he had relapsed and was embarrassed, I told him to never be ashamed of who he was.

And then when he hit rock bottom for the last time, I signed the papers to bring his body back home. I picked out clothing and made funeral arrangements and I designed a headstone for his grave—just like the mom who practiced tough love. So which is right? Who knows! Even the experts don’t agree.

I believe it is a combination of making a decision based on the availability of support, your own tolerance level, having tried everything that seems logical, being at a loss about what to do next and finding yourself willing to try anything.

I like this quote from The Water Giver—“Motherhood is about raising and celebrating the child you have, not the child you thought you’d have. . .and, if you are lucky, he might be the teacher who turns you into the person you’re supposed to be.”

Diannee Carden Glenn is based in North Carolina and Florida and has been campaigning for the last year for overdose prevention. She last wrote about the death of her son from a heroin overdose.

Sunday, November 9, 2014

Secretary Sharfstein's "Major Educational Campaign" is a Deliberate and Bogus Deception

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According to a report on WFMD Radio, "Drug and alcohol overdose deaths are on the increase in Maryland. The Department of Health and Mental Hygiene says so far in 2014, there have been 528 deaths from overdoses in the state, a 33% increase."  "Dr. Joshua Sharfstein, the Secretary of DHMH, says most of these deaths are due to heroin. The agency says there's been a 46% rise in heroin-related deaths, and seven-fold increase in fentanyl-related deaths."

"DHMH says it's working to get the message out on how to prevent overdose deaths. 'We have a major educational campaign where we're asking people to call 211 to get linked in to treatment to help people who are addicted to drugs. We're also providing education on what to do in case of an overdose, and we've trained thousands of people to use opiate overdose reversal drugs in order to save someone's life,' Dr. Sharfstein says."

Dr. Sharfstein:  Marylanders recently witnessed a "major educational campaign" when would-be legislators tried to get votes by swaying the hearts and minds of the state's voters through radio and television advertising.  Printing a stack of posters with useless and misleading information on them does NOT constitute a major educational campaign.  And we know YOU are smart enough to know that!  Can you really pat yourself on the back in front of the heartbroken Moms and Dads whose children may not make it through the night alive?  Do you have absolutely NO compassion, empathy, OR integrity?

Dr. Sharfstein:  Why would you ask "people to call 211" when those that call ARE NOT linked in to the treatment they need.  Random tests have been done by informed callers who have found that 211 operators DO NOT provide relevant or useful referrals.  Not only does this NOT "help people who are addicted to drugs", it wastes their valuable time and energy when they are in crisis.  It is a deplorable abomination that you would care so little and value human lives so little that you would waste state tax payer's dollars to devise a program that provided misinformation to people who are in crisis.  How can you boast about a program that DOES NOT WORK?!

Dr. Sharfstein:  Why would you be so bold as to pat yourself on the back for spending grant money that should have gone to train parents and family members --FIRST RESPONDERS, and instead went to train police and EMTs --emergency personnel who are called to the scene by those who are trying to keep the overdose victim alive until they get there.  Family members have had to get trained, find locations to hold trainings, and promote the trainings themselves in order to get life-saving Naloxone into the hands of other family members.

To blatantly mislead and misinform the public in the way you have done here is beyond cruel to the parents of kids who suffer with a very treatable mental health disorder --parents who have looked to DHMH for help and been ignored and rejected.

You add much salt to our wounds by stating publicly that you have helped us when you so clearly HAVE NOT!  

Thursday, November 6, 2014


Op-Ed: Anger a Necessity for Addiction Recovery Community

THE ANONYMOUS PEOPLE SCREENINGIn late September, more than 1,000 family members who have lost loved ones to drug overdoses rallied in Washington with an angry message: We’re Fed Up! with the epidemic of drug addiction in this country and the soaring number of overdose deaths.
Those family members have every right to be angry. They have every right to use their First Amendment rights to direct that anger toward the federal government and the current status quo.
I get it. I’m angry too; in fact, the Fed Up! rally made me angrier. It stood in stark contrast to the tenor and tone of the many other Recovery Month events I had the privilege to attend this past September.
It is apparently OK for those family members to angrily demand a better response from the federal government to the current health crisis. But when the addiction recovery community — more than 23 million Americans and their families — gathers to walk, speak and put a face on recovery there doesn’t seem to be much anger at the current state of affairs that is costing us more than 100 American lives every day.
Apparently, anger is a frightening emotion for many in the recovery community. Perhaps rightfully so when looking at it through individual personal recovery needs. Even the most famous recovery book in history, "Alcoholics Anonymous," named by the Library of Congress as one of the books that shaped America, suggests, “If we were to live, we had to be free of anger … [it] may be the dubious luxury for normal men, but for alcoholics these things are poison.”
But how else are we going to collectively move the needle on the current epidemic without using the prime emotion that has been at the forefront of all other advocacy movements in American history?
Floating balloons and celebrating that recovery is possible has been a great start in many communities. But when we look around at other marginalized health populations in history like the HIV/AIDs movement and the disability movement, they get a capital M on “Movement” in our cultural reflections onlybecause they got angry.
Is it not OK to express outrage over the blatant discrimination against many of us when we try to access health services, buy insurance, apply for a job or complete a housing rental application?
There’s a distinct difference between interpersonal fear-driven anger (that “The Big Book of Alcoholics Anonymous” warns against), and anger related to advocacy on behalf of your community using your citizenship. That kind of anger is actually the opposite of fear, because it takes great courage for marginalized individuals to organize and fight for their individual and collective civil and human rights.
People in recovery must get angry. We must take some lessons from the families who are fed up and join them in this emotion. For those of us who can take a stand, we owe it to those who cannot to channel this emotion into action.
As Stacia Murphy says in my documentary “The Anonymous People” about Marty Mann’s driving force (the first woman to ever achieve long-term recovery in Alcoholics Anonymous who chose to use her personal story publicly for social change), “Advocacy is about anger.” Our stories do have power!
Anger is the single missing component that will gel the entire addiction advocacy movement together. When recovery advocates embrace anger as its ally, we’ll create an overpowering force against public shame, stigmatization and discrimination.
Talking about mobilizing a constituency of consequence during the civil rights movement, Martin Luther King Jr. said, “We did not hesitate to call our movement an army. But it was a special army, with no supplies but its sincerity, no uniform but its determination, no arsenal except its faith, no currency but its conscience.”
Fifty years from now, will people look upon this new emergence of public recovery advocates with a capital “M” in their mind?  Time will tell.
Greg Williams, a person in long-term recovery for more than 12 years from addiction to alcohol and other drugs, is the filmmaker of the award-winning documentary "The Anonymous People." Williams received his master’s in addiction public policy and documentary film from New York University. 

Monday, November 3, 2014

Political Propaganda: ONDCP Praises MD's Efforts on Overdose

Below is a press release from Maryland's Department of Health & Mental Hygiene. Looks to me like the incumbents had to call in a favor from their friends at the White House in light of Larry Hogan's proactive promise to call a state of emergency as a result of the opiate epidemic's rising death toll.  
Mr. Botticelli did you intentionally join the Governor in his attempt to pull the wool over the eyes of the Maryland public or did he have you fooled, too? 
First of all, Mr. Botticelli, how could you assume that "Maryland is assigning the highest priority to addressing the overdose epidemic", when the Governor cut the treatment budget by 6.4 million dollars not even a year ago.  
Second, for Mr. O'Malley to make a thing a "goal" but take no action toward accomplishing that goal, is called "political spin" to policy makers, and... well.... "a bunch of bull" to many down home Marylanders.
Third, access to Naloxone does not "help people enter treatment."  In fact, after an overdose, the state does absolutely nothing to ensure that anyone gets into treatment.  There are no bed-to-bed transfers --or even referrals. After an overdose, the individual is simply sent back to their same environment without treatment or any intervention at all for that matter --still addicted.  
Fourth, Marylanders are wondering exactly what "broad set of strategies to address this crisis" you are referring to Mr. Sharfstein?  --And why on earth you waited so long (right before the election) to announce them, when our kids have been dying for the past four years --as we have told you repeatedly.  
Fifth, while Marylanders are very happy that "In March 2014, DHMH launched the Overdose Response Program," we are more than a little disappointed that it took volunteer parents a lot of unpaid time off work to find a legislator to force you to adopt that program via legislation.  We would find it a lot more palatable when you pat yourself on the back for something that your constituents forced upon you, if you and your staff were more inviting to your statewide network of family peer support advocates.  That way, we could initiate policy to save our own children's lives without always having to go through the legislature.   
Sixth, The reason why families spent their time initiating this bill was so families --THE REAL FIRST RESPONDERS, would have access to Naloxone. However, you gave grants to counties to pay EMT's and police officers to be equipped with Naloxone --while us family members STILL do not have the Naloxone that WE lobbied for and who provisions were made for in the Overdose Prevention "Naloxone" Bill.
Seventh, the state's "public information campaign" consists of some posters and a FaceBook page. Perhaps you should hire Anthony Brown's public information campaign Manager.  I am quite sure that he will tell you, Mr. O'Malley, that television is the way to go --albeit, more expensive.  But, if you guys can raise those kinds of funds to get re-elected, surely you can raise those kinds of funds to save the youth of your state --to save so many mothers the heartbreak of having to bury a child?  
At any rate, the families who care about your message ARE NOT BUYING IT --and the families who don't care ARE NOT READING IT.  So how about saving the political rhetoric for your cocktail parties, Mr. O'Malley.  We mothers of children with a substance use disorder DO NOT DESERVE IT!  
Lisa Lowe, Heroin Action Coalition                                                                 heroinactioncoalition@gmail.com
heroinactioncoalition.com

White House’s Office of National Drug Control Policy
Praises Maryland Efforts on Overdose
DHMH Expands Access to Reversal Drug
 Baltimore, MD (October 29, 2014) – The White House Office charged with leading the country’s fight to reduce drug use is praising the efforts of the Department of Health and Mental Hygiene (DHMH) to combat substance use and its consequences in Maryland. 
Michael Botticelli, the acting director of the U.S. Office of National Drug Control Policy (ONDCP), met with DHMH officials last week and reviewed the department’s strategies to combat substance abuse and overdose deaths in Maryland. In a Oct. 27, 2014, letter addressed to DHMH Secretary Joshua M. Sharfstein, Botticelli writes: “Maryland is assigning the highest priority to addressing the overdose epidemic affecting many states in our nation. There is much many other states can learn from your efforts.” 
“Overdose deaths are an epidemic affecting states across the country,” Gov. O’Malley said. “Combating this scourge and reducing overdose deaths by 20% by the end of 2015 is one of the 16 strategic goals of the O’Malley-Brown Administration.”  
This letter of support comes as DHMH announces the expansion of access to life-saving medication naloxone to Medicaid enrollees. Naxolone is used to reverse the effects of an overdose from opioid drugs like heroin. As a result of the change to the Medicaid pharmacy benefit, doctors can write prescriptions for the medication to enrollees without preauthorization. DHMH is reaching out to prescribing physicians and drug treatment programs with guidance on how to prescribe. 
“Greater access to naloxone will lead to more opportunities to save lives and help people enter treatment,” said Sharfstein. “We appreciate the support of ONDCP as we pursue a broad set of strategies to address this crisis.” 
Expanding naloxone access to Medicaid enrollees builds upon Maryland’s efforts to expand the overdose remedy statewide. In March 2014, DHMH launched the Overdose Response Program, which authorizes local entities to train and certify qualified individuals to recognize and respond to an opioid overdose by administering naloxone. DHMH has trained more than 3,200 individuals through this program. 
The State Police have committed to having all road patrol troopers trained and equipped with naloxone. The State requires every Emergency Medical Technician across the state to be trained in the administration of intranasal naloxone and every Public Safety transport unit to carry naloxone. It also builds upon the state’s public information campaign, “Be a Hero,” which emphasizes the importance of substance use treatment and provides facts about reversing a drug overdose. 

In June, Governor O'Malley issued an executive order establishing a statewide task force and initiating a broad range of efforts against overdose. Click here for more information on Maryland’s efforts on Overdose Prevention.   

Saturday, October 25, 2014

FOR IMMEDIATE RELEASE:
October 24, 2014

Contact:  Lisa Lowe
Heroin Action Coalition
301-525-6183



FAMILIES TALK ABOUT OPIATE ADDICTION:  MARYLAND'S HIDDEN EPIDEMIC

WEDNESDAY, OCTOBER 29TH,  12:00 p.m. to 2:00 p.m.
LAWYER'S MALL, ANNAPOLIS, MD


FAMILIES ARE HOPING THAT THE NEW ADMINISTRATION WILL ADDRESS MARYLAND'S BIGGEST HEALTH CRISIS

In the most recent gubernatorial debate between Lieutenant Governor, Anthony Brown, and Republican contender, Larry Hogan, Maryland's heroin epidemic was noted among the top issues facing the state.  Hogan admits that "we have a heroin epidemic here in Maryland. We have been called the heroin capital of the United States."  He claims that "Maryland is the only state on the East Coast that has not declared a state of emergency over this very serious problem."  He promises that within two days of taking office, he will "immediately call a state of emergency and call a summit to bring all of the various components together to sit around the table to find out how we attack this problem.  It is a major major issue!"

Anthony Brown promised to allocate $100,000,000 to "better drug treatment, education and outreach programs".  This funding will become available through savings created by the new marijuana decriminalization laws which will save the state millions when cases in which marijuana users are caught with small amounts of marijuana are no longer prosecuted.

Leaders of grassroots advocacy groups across the state agree that opiate addiction and overdose death have reached epidemic proportions and is Maryland's biggest problem.  Members are continuously frustrated by a lack of responsiveness and leadership on the part of Governor O'Malley in tackling the problem.

"If our kids were dying of any other epidemic, our state would be under quarantine," says Carin Callan-Miller, co-founder of Save Our Children and member of the statewide coalition of family-based grassroots advocacy groups --Heroin Action Coalition of Maryland.  "All you hear about in the media these days is Ebola.  We have mustered funding, doctors, troops, medicine and everything else to address this problem.  Yet, while 3,000 people died of Ebola in Africa, 30,000 Americans died from overdoses --And still the President, elected leaders, the press, local health departments, school officials, and every other community leader remains relatively silent on this issue!" 

Lisa Lowe, founder of Heroin Action Coalition agrees.  "This is the biggest public health crisis in my lifetime --parents are burying more kids than they were during the Vietnam War, but due to a long history of stigma and anonymity surrounding addiction, family members are extremely reluctant to talk about it.  If no one is talking about it, the media has no stories to write about it, and our elected officials do not have a constituency to hold them accountable for resolving the problem," says Lowe.  "By the same token, our Maryland Governor has been remiss in making this issue the state priority that it should have been during the past four years." 

"Maryland is way behind other states in providing a solution," says Callan-Miller.  "Families are going bankrupt, mortgaging their homes, cashing out life savings, and spending their retirement to save their kids --often sending them to out of state treatment programs that are just not available in our own state."  She says that she and her husband have mortgaged their home and spent their retirement on getting treatment for their son, who has struggled with a substance use disorder and has been repeatedly unable to get the help he needs in Maryland.  Lowe has spent so much time trying to get her son the treatment that would save his life --that she ended up losing her job and then her home. 

Ginger Rosela lost her son to an overdose a little over a year ago.  Since then, she has been an advocate for better prevention, treatment and recovery programs in Calvert County and has also joined the statewide Coalition of family advocates.  She started a FaceBook page dedicated to her son Jake, and has been instrumental in heightening awareness and helping families to get their loved ones into treatment in Southern Maryland.  She recently held an event in Calvert County in which more than 50 people attended and received training in overdose prevention and free Naloxone kits --the opiate overdose reversal drug that only recently became available to parents with the passage of legislation.  According to Rosela, family members are doing the work that they expected their state and county health departments to do.  "In order to get Naloxone into the hands of family members, we had to find a local legislator willing to introduce a bill, then we had to take off work to educate our legislators."  "Now, in order to get the Naloxone to the families who need it, we must find doctors willing to prescribe it, get trained in teaching other family members to use it, find locations to hold the trainings, promote the events, and raise money to purchase the kits --all at our own expense," explains Rosela.  "There are many advocates who are working full time without pay to save lives," says Rosela.  "Even though it is too late to save my own son, I cannot bear to hear about the next death or the next funeral or the next heartbroken Mom or Dad.  So I am fighting to save their kid." 

Families are frustrated that more has not been done to resolve the problem.  "Last year, families spent a lot of time educating elected leaders on the merits of the Good Samaritan Bill and were successful in getting it passed into law," points out Rosela.  The Good Samaritan Bill provides limited immunity from arrest or prosecution for minor drug law violations for people who call for medical help when they are witnessing an overdose.  Rosela is disappointed that there has not been a statewide campaign to educate citizens about the new law.  "This law has the potential to save lives," maintains Rosela, "except that no one has heard about it."

"We do not have an organization that supports families with an individual struggling with a substance use disorder," Lowe points out.  "We have no budget, no paid staff, and we are all doing this work around our other jobs," she admits.  "There are other advocacy organizations that save the Bay, save animals, or advocate for fair mental health policy --all with million dollar annual budgets --but we are trying to save kids with absolutely no budget."

Lowe argues that a lack of performance measures for treatment programs are at the root of the problem. "Despite millions being poured into Maryland's addiction treatment programs, Maryland continues to wrestle with an out-of-control heroin epidemic.  We do not know what works because we have no standards for defining successful outcomes and no real performance measures for comparing various programs or determining which ones are even effective.  How do we know where to spend tax payer dollars if we don't know what has worked and what hasn't," questions Lowe.  "We need to begin to look at ways to compare all of the programs in our state's continuum of care, so that we can fund what works.  We need to look at what other state's are doing that has achieved measurable results."

"This is definitely an area where we would like to see improvement in the new administration," says Lowe.  "While the Governor may define successful recovery as the ability to hold a job while an individual maintains a dependency on high doses of methadone --a relatively low cost option for the state, many family peer support advocates argue that methadone maintenance is simply another form of addiction, albeit a legal form.  Many families are in support of long term residential treatment, arguing that even though it may be more costly in the short term, the savings in terms of health and quality of life is worth it in the long run.  Families need to be invited to weigh in on the policy that effects our lives and impacts our families," urges Lowe.  

"We need to look at ways of defining success that everyone agrees with," emphasizes Lowe.   "Then we need to figure out which treatment providers have the highest rates of success with regard to meeting these benchmarks.  We need to look at ALL programs along the continuum of care --those that are publicly funded as well as privately funded. Then we need to tie rates of success to county and state funding.  Only then can our elected leaders be sure that our tax dollars are doing what our citizens want them to do --and that is to solve the problem of addiction and overdose death."   Lowe stresses that "our elected officials have a responsibility to spend tax payer dollars wisely --to achieve the best bang for the buck.  Transparent and measurable outcomes are the only way that Maryland constituents have to hold their elected and appointed leaders accountable for spending their money on what is in their best interest." 

Rosela agrees, "the responsibility for implementing effective policy and programs for addiction treatment in the State of Maryland falls squarely at the door of the Governor.  This is a critical campaign issue which has not been fully addressed by either gubernatorial candidate."  With an 88% increase in the overdose rate from 2011 to 2013, and DHMH first quarter stats for this year showing a 33% increase in overdose deaths compared to the same time last year, voters want to know how the candidates will address this issue.

Family advocates are guardedly hopeful that the new administration will bring a fresh perspective and new ideas to tackle the problem.  "But in the long run," notes Callan-Miller, "we will need the new administration to allocate the necessary funding to create necessary programs, rather than cut the treatment budget --as Governor O'Malley did during the past year."

Tuesday, October 21, 2014

MD GOVERNOR'S RACE

Hogan says Heroin is #1 Problem in Parts of the State!
He Would Declare a State of Emergency!!

It seems as if this election, more than any other I can remember, is not about party lines --but about status quo vs. change. Check it out if you missed it:


In response to a question about Maryland's Hidden Epidemic --Opiate Addiction, here are some quotes from the contenders:

Anthony Brown says:  "In June, we sat down with local communities..."  

Heroin Action Coalition says:  Really? --Where were the family support groups? I don't know who you "sat down with" in "local communities", but it certainly wasn't with the families of those most affected and those most able to offer insights into what works and what doesn't.  

Anthony Brown says:  "We stepped up Maryland police..."  

Heroin Action Coalition says:  Have you missed hearing every law enforcement spokesperson, from Gil Kerlikowski, former DEA drug czar, to the officer on the corner beat say, 'we cannot arrest or enforce our way out of this problem'?  Maryland police have "stepped up" to the plate long ago, Mr. Brown.  It is the bottom of the ninth and the entire state is waiting for DHMH and the County Health Departments to stop sleeping in the dugout.

Anthony Brown says:  "Naloxone --We did that."  

Heroin Action Coalition says:  You are joking, right?  Families initiated the legislation that allowed Naloxone to be available to the family members of those addicted to opiates.   Families lobbied to get the bill passed.  And now, families are promoting and hosting the Naloxone trainings at their own expense.  What exactly did you do, Mr. Brown?

Larry Hogan says:  

"One of the biggest crime related issues in Maryland is the growing heroin epidemic."

"...been all around the state"..."was shocked to hear how bad the problem was." ..."the number one issue in Hagerstown is heroin" ..."sixty percent of St. Mary's problems are caused by heroin" ..."in Caroline County, the number one issue is heroin".  ..."Sixty to seventy percent of people in the Frederick County jail are gang related and heroin related."  

"We have a heroin epidemic here in Maryland.  We have been called the heroin capital of the United States."

"Maryland is the only state on the East Coast that has not declared a state of emergency over this very serious problem."

"On January 4th, two days after taking office, I will immediately call a state of emergency and call a summit to bring all of the various components together to sit around the table to find out how we attack this problem.  It is a major major issue!"


Thursday, October 16, 2014

IS DHMH SELLING OUT?

Where are Integrated Regulations to Guide Maryland's New Behavioral Health 'Services and Systems'?

According to the Maryland Department of Health and Mental Hygiene's website, there are "ongoing efforts to integrate the State’s mental health and substance use disorder services and systems". In order for these "services and systems" to become integrated, the regulations --which guide the activities of those regulated by the Department (DHMH), must also be integrated --otherwise, they have no real reason to change what they currently do and adopt the state's new system of integrated care.  Family advocates have no expectation that treatment providers will make changes to existing programs simply on a voluntary basis.

Even though DHMH plans to contract with a national accreditation organization --either the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) or the Commission on Accreditation of Rehabilitation Facilities (CARF), to provide "new" standards for treatment providers and to ensure that treatment facilities comply with these standards, the consumers who will potentially utilize these services want to ensure that SUD treatment standards are comparable to mental health treatment standards.  Consumers of SUD treatment services have not yet been given the opportunity to review the new accreditation standards, and therefore, cannot logically be expected to comment on something which they have not yet seen.

Currently, there are eight regulations for the delivery of substance abuse treatment services compared to thirty for the delivery of mental health treatment services.  If Substance Use Disorder (SUD) is now recognized as the neurologically-based mental health disorder that science has proven it to be, then individuals struggling with SUD should get the same protections and receive the same quality of care that Maryland currently provides to individuals struggling with all other mental health disorders.  Unfortunately, this is currently not the case.

Marylanders have been waiting for true integration, and hence, comparable and equitable regulations, for years.  Now that DHMH is reviewing and changing these regulations, consumers of SUD services and their families are expecting that SUD service providers will be held to the same high standards that have guided mental health service providers for decades.

With the epidemic rate of overdose death in the state, and the Governor's promise to lower overdose death by 20% in the next year --delivering anything less to consumers of SUD services will not be acceptable.  It is time for SUD patients and their families to receive their fair share of protections and standards.


CURRENT REGULATIONS

Below are just a few regulations governing mental health treatment, which are currently NOT applied equally to substance use disorder treatment.  Consumers of the newly integrated "services and systems" need to know how the "new" regulations will be applied to ensure that they receive the same high quality care that consumers of mental health services already have.

INVOLUNTARY ADMISSION:  10.21.01 outlines involuntary admission to an inpatient treatment facility if the individual has a mental illness that "substantially impairs the mental or emotional functioning of the individual so as to make care or treatment necessary or advisable for the welfare of the individual or for the safety of the person or property of another".  It currently excludes a diagnosis of substance use disorder.  RESULT: Parents are able to petition the courts to have their child admitted to a hospital against their will if they are cutting themselves, but not if they are shooting heroin --even though the death rate is much higher for overdoses than suicides.  

CONSUMER PARTICIPATION IN TREATMENT POLICY:  10.21.02 mandates that treatment programs must include community and consumer participation in establishing policies and procedures and for reviewing and evaluating these policies.  There is no equal standard for SUD treatment.  RESULT: Consumer input shapes treatment policy at mental health facilities, but not at substance abuse facilities.

GROUP HOUSING:  10.21.04 outlines regulations for "Group Homes for Adults with Mental Illness" but excludes individuals with a substance use disorder.  In the SUD "Continuum of Care" we have "Sober Living Homes" for Adults with a Mental Illness (SUD), which are regulated by housing laws --not DHMH.  RESULT: Currently, there is nothing to prevent our children from being referred by a residential treatment provider into substandard housing, run by a violent unstable drug-using sexual predator, where they share a bedroom with three other drinking or drugging men or women, and where they are required to pay hundreds of nonrefundable dollars prior to moving in. Even when the housing environment is not as overtly harmful as this example, many sober living environments inadvertently undermine the recovery of these individuals --diagnosed with a chronic, severely debilitating, and often fatal mental health disorder, when they fail to provide essential links to the support services that these individuals desperately need to regain their mental health.

FAMILY INVOLVEMENT:  10.21.05 charges staff to "assist individuals in aftercare planning...as soon as possible after acceptance, in collaboration with the individual" and "community-based service providers", "family members", "others who have a personal interest in the individual"... (with proper consent).  No equivalent regulation for substance use treatment providers exists.  RESULT: In many SUD treatment facilities, family members are typically disallowed or strongly discouraged from participating in aftercare planning.  "Proper consent" is neither explained nor sought by facility staff.  "Community-based service providers" are rarely, if ever, permitted to have contact with the individual while in treatment, much less in planning for discharge. The individual recovering from a severely debilitating mental health issue (SUD) is often coerced into making important life-altering decisions without the benefit of those whom they rely on for insight and wisdom.

NOTICE TO NEXT-OF-KIN:  10.21.05 also ensures that notification of discharge or release must be provided to next-of-kin (with proper consent).  No equivalent regulation for substance use treatment exists.  RESULT: In SUD treatment, young adults are routinely kicked out of treatment without a phone, money or transporation, for infractions that are unrelated to either their own health and safety or the health and safety of others.  Under current practices, there is no way for a parent to find out whether their child has left treatment other than to call police and report them missing.  Presumably, the provider is required to tell police that the individual has left treatment (as opposed to dying or being kidnapped).  Then, the police can let the next-of-kin know that their family member was last seen alive by the facility staff, but is no longer at the facility.

ADOLESCENT PROGRAMS:  10.21.06 outlines regulations for Regional Institutes for Children and Adolescents (RICAs) for adolescents with "a long-term and severe mental disorder" with "treatment needs that cannot be met through community-based programs" and where residential treatment can be "expected to improve the individual's condition or prevent further regression so that the individual can return to the community" --except adolescents with a substance use disorder.  RESULT: Many parents are so desperate for help for a child with a substance use disorder, that they rely on individuals without any licensing or training to handcuff their sleeping kids in the middle of the night, drag them out of their beds, and transport them across the country to unregulated facilities in rural states where withholding of food, sleep deprivation, or isolation without clothing are among the negative reinforcements used as a means of control.  These horrific tortures are implemented under the guise of "therapy".

Similarly, 10.21.07 outlines regulations for Therapeutic Group Homes (TGHs), which also exclude kids with a substance use disorder.

FAMILY SUPPORT ORGANIZATION:  10.21.10.07 allows a Psychiatric Residential Treatment Facility (PRTF) to bill Medicaid for a) caregiver (parents) peer-to-peer support; b) youth peer-to-peer support (through 26 years old); and c) family and youth training.  A FAMILY SUPPORT ORGANIZATION may provide these services to PRTFs and get paid for them if: 1) they are non-profit; 2) their board and staff are caregivers with lived experience.  No equivalent regulation for SUD treatment exists.  RESULT: Family Support Organizations providing these same services for SUD to caregivers and transition-age youth are NOT paid and their services are rarely even acknowledged by SUD Residential Treatment Facilities.

EXPRESSIVE AND EXPERIENTIAL THERAPIES:  10.21.10.09 allows a PRTF to bill Medicaid for "Expressive and Experiential Behavioral Services", including art; dance/movement; horse-back riding; horticulture; music; drama; etc.  Presumably, if PRTFs are able to get reimbursed for these services, they are more motivated to provide these services. RESULT: Since these waivers do not apply to SUD providers, SUD facilities are not motivated to provide these therapies to their patients.

CRISIS AND STABILIZATION SERVICES:  10.21.10.10 allows a PRTF to bill Medicaid for Crisis and Stabilization Services, therefore providing them with an incentive to provide these services.  No equivalent regulation for SUD providers exists.  RESULT: Unless an individual suffering with SUD is "in crisis" to the point where they are unconscious and in need of emergency medical services, caregivers are fully responsible for providing crisis and stabilization services.  It is not uncommon for caregivers to set alarms throughout the night so they can frequently check on a loved one who is "in crisis" and "in need of stabilization" to ensure that they continue breathing.

GRIEVANCE SYSTEM:  10.21.14 outlines a very detailed resident grievance process with four stages, including mandatory meetings, time parameters for responses, written responses from treatment directors, remedy and appeal guidelines, reviews by Resident's Rights and Central Review Committees, reporting requirements, etc. in order to provide a "fair, efficient, and complete remedy for allegations of rights violations".  RESULT: As there is no similar regulation for SUD treatment providers, patients whose rights have been violated may feel lucky to have a "complaint box" where violations are reviewed by a low level staff prior to being filed in the waste basket.

SIGNED RELEASES FOR HIPAA COMPLIANCE:  10.21.17.04 mandates that a "Community Mental Health Program" must ensure that an individual "receives information, verbally and in writing, regarding making an Advance Directive for Mental Health Services" --a document designed to give authority to a representative whom the patient trusts to make decisions concerning his or her treatment.  The Mental Health community recognizes that a patient's ability to make rational decisions may be compromised by their debilitating disorder, and they may need assistance from someone whom they trust and respect to assist them in making life and death decisions.  No equivalent regulation for substance use treatment providers exists.  RESULT: Many SUD facilities do not provide any information to admitted clients regarding HIPAA releases to allow a similarly trusted advocate or family member to assist them in making treatment decisions.  In fact, without a signed release, staff at treatment facilities commonly tell family members --husbands, wives, parents, children that they "cannot confirm or deny" that their loved one is in treatment --even when the family member dropped them off and signed an agreement to pay for treatment an hour before.  This archaic practice not only fails to recognize the vitally important role of the family in supporting their loved one's treatment and recovery, but actually undermines primary ties and normal healthy relationships between parent and child or husband and wife.

COMMUNITY ADVISORY COMMITTEES:  10.21.17.05 stipulates that a "Community Mental Health Program" must have an Advisory Committee comprised of individuals currently or previously served by a mental health program, family members of those served, or members of a mental health advocacy organization.  Mental Health programs provide better quality services with a higher rate of successful outcomes when they have the benefit of feedback from those with "lived experience" and first-hand insights into the treatment experience.  No equivalent regulation for SUD treatment providers exists.  RESULT: SUD programs fail to seek input or feedback from family members and fail to recognize existing substance abuse advocacy organizations, hence they fail to benefit from the lived experience or first-hand insights of their clients, and their programs are weaker and less effective because of it.

LOCAL RESOLUTION OF CONFLICTS:  10.21.17.06 outlines collaboration between a "Community Mental Health Program" and a County Core Service Agency.  It addresses "protocol for resolution of conflict between the program and an individual served", thereby providing local oversight for programs within a local community.  There is no equivalent for SUD treatment providers.  RESULT: Currently, there is no person, agency, or office that resolves conflicts between a SUD program and the individual served.  Individuals with a valid and documented grievance against a SUD provider have absolutely no avenue for complaint or resolution.

CULTURAL SENSITIVITY:  10.21.17.07 ensures that information and services are provided in a "culturally sensitive manner" and at a "suitable reading comprehension level".  No equivalent regulation exists for SUD treatment providers.  RESULT: Patients are likely to become anxious and intimidated when they find themselves in treatment situations which alienate them, either due to cultural differences, language comprehension issues, learning deficits, physical impairments or any other barrier which would cause them to feel threatened or isolated by the treatment environment.

NOTICE PRIOR TO DISCHARGE:  10.21.17.10 stipulates that "except in the case of imminent danger" notice of the discontinuation of treatment services must be given.  This gives the patient time to find another facility or to appeal the decision.  RESULT:  Since SUD providers have no equivalent regulation, they are at liberty to discharge any patient without warning, based on the whims of the staff in charge at the time.  Premature discharge is common and occurs regularly at many SUD treatment facilities.

LINKS TO SUPPORT SERVICES:  10.21.21.05 specifies that a "rehabilitation assessment" will be conducted for each patient in order to assess their need for housing and employment, mobility and transportation, social relationships and leisure activities, education and vocational training, etc.  Links to these types of "Rehabilitation and Support Services" are provided in order to support the patient's recovery.  No equivalent regulation for SUD treatment providers exists.  RESULT: Without this focus on the 'whole person', many SUD providers simply offer addiction education without addressing any other significant areas of their patient's lives.  It is as if they can simply educate them out of their addiction without spending time or effort rebuilding lost lives and replacing old patterns with new habits.  Service providers don't seem to understand that a patient who has engaged in negative and defeating habits for many years, with no experience or memory of how to access links to successful recovery, will somehow miraculously make these connections.  Thus, an individual new to recovery with only 28 days of residential treatment is returned to homelessness and joblessness with absolutely no awareness of how to live a "normal" life, and without the assistance or training necessary for accomplishing it.

HOUSING ASSISTANCE:  10.21.21.09 directs the "Community Mental Health Program" Director to attempt to develop financial resources to assist an individual temporarily to maintain housing within the community.  No equivalent regulation for SUD treatment exists.  RESULT:  Patients with a SUD are commonly discharged to homeless shelters.  Programs, like Access To Recovery, that were effective in ensuring that patients released from a detox facility had a minimum of funding to cover one month of rent in a step down level of care have been cut, regardless of how promising or effective the program's outcomes were.

GROUP HOUSING STANDARDS:  10.21.22 requires all areas of a Residential Rehab to be "safe and clean and free from clutter and have furnishings, supplies and utensils comparable to those found in residences of nondisabled residences" --requires "hot and cold running water and adequate light, heat and ventilation".  Ensures that a resident has "access to food"; "an adequate supply of soap, towels, and toilet tissue"; "access to transportation" and to a telephone; and a "bed with a clean mattress, pillow, and linens".  It stipulates that no more than two people will share a room and that there will be at least one bathroom for every four residents.  No equivalent regulation for SUD treatment facilities exists.  RESULT: SUD patients who need an ASAM 3.1 level of care are commonly discharged to housing which is currently governed by housing laws.  As such, this very vulnerable population has been readily preyed upon by landlords --often motivated by greed, and eager to make money off of individuals trying to get back on their feet, perhaps after years of battling an often fatal and severely debilitating neurological disorder.


"NEW"  REGULATIONS  (PROPOSED  BY  THE  "NEW" BEHAVIORAL  HEALTH  ADMINISTRATION)

Below are the "new" regulations proposed by the "new" Behavioral Health Administration, governing the "new" integrated treatment "services and systems".  Consumers are concerned that the "new" regulations are simply a rewritten version of the "old" regulations.  We are concerned that the vast gap between SUD treatment services and mental health services will not be bridged and the needs of consumers and families of SUD treatment services will continue to be ignored by service providers, government agencies and elected leaders.  This is simply an intolerable and unacceptable option.

We were promised integration!  Our tax dollars paid for integration!  We deserve integration!  And we will not rest until we have integration!

10.21.11.05.A(3)(c) "provides, at a minimum, individual, group, and family therapy..." under licensing regulations for MENTAL HEALTH TREATMENT without having an equivalent provision under SUBSTANCE USE DISORDER TREATMENT.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

10.21.11.05.A(5)(a) "provides community-based comprehensive rehabilitation services and supports, including, but not limited to: (i) community living skills; (ii) activities of daily living; (iii) family and peer support," under licensing regulations for MENTAL HEALTH TREATMENT without an equivalent provision for SUBSTANCE USE DISORDER TREATMENT.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

10.21.11.05.A(5)(a) provides similar "services and supports designed to promote resiliency and facilitate the development or restoration of a minor's age appropriate skills...(i) self-care skills; (ii) social, peer, family, and teacher interactions; and (iii) semi-independent living skills," for MENTAL HEALTH patients without the equivalent for SUBSTANCE USE DISORDER patients.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

10.21.11.05.A(5)(f) "promotes the individual's ability to engage and participate in appropriate community activities" for individuals receiving MENTAL HEALTH TREATMENT but not for those receiving SUBSTANCE USE DISORDER TREATMENT.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

10.21.11.05.A(10) provides for a "Supported Employment Program" for MENTAL HEALTH patients without an any equivalent provision for SUD patients.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

.05.A.(1) Mental health has licensing regs for "group homes for adults with mental illness", which exclude persons with substance use disorders.  Individuals suffering with a substance use disorder are stuck with unregulated sober living homes --currently used as step-down programs in the continuum of care when detox facilities refer unsuspecting clients into them.  While individuals recovering from any other mental health crisis get to live in homes with light, heat and hot water; with appropriate furnishings; with access to food; with soap, towels and toilet tissue; with access to telephone and transportation; with curtains and a clean mattress and pillow and bedding --our unsuspecting, barely adult, children are referred by treatment providers into unregulated sober living homes with absolutely no oversight --or even the promise that the residents are remotely drug-free.  Many sober living houses are enormously harmful to the recovery of individuals, particularly transition age adults who may have very little experience living independently.  When treatment providers are allowed to discharge clients to unlicensed and unregulated "sober-living homes" under the guise of "continuum of care", very vulnerable and fragile individuals are placed at enormous risk.  SUD advocates do not have a problem with housing laws pertaining to housing --but when providers refer clients who meet ASAM criteria for a level 3.1 facility into a HOUSE --governed by housing laws --and pretend that this is our contiuum of care --it is nothing less than a breach of public trust.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

.05.A.(2)  makes a provision for mobile treatment services for individuals needing mental health services, but not for those needing SUD services.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

.05.A.(9)  makes a provision for respite care services in mental health treatment but not in substance use disorder treatment.  Consumers of SUD services will benefit equally when this licensing provision is applied to SUD treatment.

Section C:  The fact that a third section of COMAR 10.21.11 exists --Section C: Integrated Behavioral Health Programs, seems to suggest that facilities that are regulated under Section A: Mental Health Programs and under Section B: Substance Use Disorder Programs WILL NOT BE REQUIRED TO INTEGRATE MENTAL HEALTH AND SUD TREATMENT SERVICES.  Consumers were lead to believe that this was the point of Behavioral Health Integration in the first place.  Isn't this what is promised to consumers on the DHMH website --inherent in the statement "ongoing efforts to integrate the State’s mental health and substance use disorder services and systems"? With the overdose death rate at epidemic levels, can we afford anything less?


ASAM  CRITERIA

The American Society of Addiction Medicine (ASAM) developed criteria for "placement, continued stay and transfer/discharge of patients with addiction and co-occurring conditions".  While DHMH requires treatment providers operating in Maryland to follow these guidelines when determining the appropriate level of care for patients --they DO NOT require insurance companies doing business in the state to recognize these same guidelines.  As a result, Maryland has a disjointed and inconsistent treatment system because some providers follow ASAM criteria for determining level of care, while others do not.  Those that do, either charge families for whatever portion of their treatment program is not paid by insurance or provide services for which they are not paid.  Other programs discard ASAM criteria altogether, allowing insurance companies or a client's ability to pay, to determine their level of care.

Consumers of services are wondering if Maryland's Behavioral Health administrators are in denial when they fail to acknowlege this blatant and flagrant inconsistency.  Agency administrators repeatedly insist that Maryland treatment providers are required to follow ASAM criteria, when it is painfully obvious to anyone who has used the state's treatment system that placement, length of stay, and transfer/discharge plans are more often based on an individual's ability to pay and the availability of beds (often limited to a single county) than on ASAM criteria when determining 'level of care'.  Consumers can certainly vouch for the fact that SUD treatment providers use ASAM criteria inconsistently at best.

Consumers expect and deserve basic honesty from appointed agency representatives.  Regardless of whether DHMH chooses to resolve the fact that our Maryland treatment system is NOT guided by ASAM criteria, they should, at the very least, be honest about that fact.  Trying to convince consumers that placement, length of stay, or transfer/discharge is based on a standardized medical criteria when they have consistently experienced otherwise is like trying to convince someone it is safe to cross a wooden bridge when it is on fire.  If our elected and appointed leaders do not care enough to fix the problem, at least they should not cover up their lack of care with misrepresentations and falsehoods.