Medication Assisted Treatment for Opioid Use Disorders (SAMHSA, RIN 0930-AA22)

May 25, 2016

Kana Enomoto, MA
Principal Deputy Administrator
Substance Abuse and Mental Health Services Administration
Department of Health and Human Services

Re: Medication Assisted Treatment for Opioid Use Disorders (SAMHSA, RIN 0930-AA22)

Dear Ms. Enomoto:

On behalf of the American Psychiatric Nurses Association (APNA), we are pleased to provide the following comments on the Substance Abuse and Mental Health Services’ (SAMHSA) proposed rule, Medication Assisted Treatment for Opioid Use Disorders. APNA is an organization of more than 10,000 members, committed to the practice of psychiatric mental health nursing, health and wellness promotion through identification of mental health and substance use issues, prevention of mental health problems and the care and treatment of persons with psychiatric  and substance use disorders. APNA is the only professional organization inclusive of psychiatric-mental health nurses at both the registered nurse (RN) and advanced practice (APRN) levels.

APNA applauds SAMHSA’s efforts to address opioid addiction, overuse, and needless deaths by reducing barriers to medication assisted treatment. We fully support the comments submitted by the American Nurses Association (enclosed), but we must emphasize that these regulatory changes, while offering some benefit, will fall short of what is needed to stem this national crisis. Meaningful expansion of access to buprenorphine can only be achieved with legislative changes that give advance practices nurses (NPs and CNSs) with already recognized prescriptive authority this same authorization to prescribe buprenorphine. A 2013 position released by APNA states that the American Psychiatric Nurses Association “fully supports the expansion of advanced practice registered nurses’ prescriptive authority to include the prescription of buprenorphine/naloxone (Suboxone) in the treatment of persons who are addicted to opiates.”

We respectfully urge SAMHSA to actively support legislative changes to provide advanced practice nurses authorization to prescribe buprenorphine. Thank you for the opportunity to comment. If you have any questions please contact me at ncroce@apna.org.

Be Safe,

Nicholas Croce
Nicholas Croce Jr., MS
Executive Director

The American Psychiatric Nurses Association is accredited with distinction as a provider of continuing nursing education by the American Nurses Credentialing Center's Commission on Accreditation.