FMRC OMAT/Suboxone program will operate as a sound and effective outpatient program specializing in office-based medication assisted and psychiatric care treatment programming for substance use recovery (opioid dependence treatment) in accordance with Federal licensure, statutory rules and regulations, SAMSHA Buprenorphine Clinical Practice Guidelines, DEA Office of Diversion, State of North Carolina DHHS, North Carolina State Opioid Treatment Authority (SOTA) as applicable, and in accordance with existing FMRC Outpatient Services Policies and Procedures.
FMRC is an outpatient or “periodic” service meaning that the service is provided on an episodic basis, either regularly or intermittently, through short, recurring visits for persons with mental health, intellectual developmental disability and/or substance abuse (MH/DD/SA) diagnoses by FMRC that already provides MH/DD/SA services. It is designed to offer the individual an opportunity to effect constructive changes in lifestyle by using buprenorphine or other medications approved for use in opioid treatment in conjunction with the provision of rehabilitation and medical services.
FMRC is founded upon and delivered in contemporary and state-of-the-art clinical orientations, including twelve-step facilitation through a holistic and substance use recovery-based construct. Our FMRC services engage in service delivery of "other medications approved for use in opioid treatment"; (medications approved by the Food and Drug Administration for the treatment of opiate dependence and approved for accepted medical uses under the North Carolina Controlled Substances Act, specifically buprenorphine with naloxone. Buprenorphine with naloxone, also referred to as “Suboxone” is used as an alternative to methadone for the maintenance treatment of opiate addiction. The drug is less rigidly controlled than methadone because it has a lower potential for abuse and is less dangerous in an overdose. Suboxone is approved for use in opioid treatment as a tool in the detoxification (non-detox-facility) and rehabilitation process of an opioid dependent individual.
The intention of adding naloxone to the Buprenorphine formulation (making it Suboxone) is to deter misuse. Suboxone is pharmacologically related to morphine and is a partial opioid agonist: It has the same effect on mu-opioid receptors in the brain as does heroin or other opiate drugs, but it has a ceiling affect whereby higher doses do not result in higher effects. Suboxone, when used correctly, reduces or eliminates withdrawal symptoms associated with opioid dependence but does not produce the euphoria and sedation caused by heroin or other opiates. This drug treats opiate addiction by preventing symptoms of withdrawal from heroin or other opiates and thereby reducing addiction behaviors. The use of these agents in medication-assisted treatment of opioid addiction is regulated by federal and state statute.
FMRC/Suboxone program will use the SAMHSA Buprenorphine Clinical Practice Guidelines (CSAT TIP 40 http://buprenorphine.samhsa.gov/) as a guide to clinical treatment, diagnostic formulations and implementation. It will further have the following practices in place:
- Staff education and training
- BackuOffice policies and procedures
- p coverage for the practice
- Assurance of the privacy and confidentiality of addiction treatment information
- Care coordination with other medical professionals. As a majority of the patients addicted to opioids commonly have coexisting medical and psychiatric conditions, it is expected that physician(s) will need to establish linkages with other medical and mental health specialists, particularly those specializing in the evaluation and treatment of common comorbid conditions (e.g., hepatitis B and C, HIV, tuberculosis, mood disorders, anxiety disorders, personality disorders, risk of suicide and homicide). Additional linkages should be established with any qualified colleagues, medical treatment facilities and addiction and psychiatric treatment programs who will accept new referrals for buprenorphine treatment
- Timely Physical examinations and/or laboratory evaluations (completed either onsite or offsite)
- An up‐to‐date listing of community referral resources shall be made available to all clients. These may include but not be limited to therapy groups, support groups, residential therapeutic communities, sober‐living options, internet and local specific self‐help groups, such as NA, AA, Al-Anon, and SAA.
- All reasonable attempts will be made for the physician(s) to have firsthand knowledge of the groups and programs in hopes to maximize in follow through with referrals
The following should be noted regarding our OMAT/Suboxone program:
- It is not subject to Opioid Treatment Program Federal or State Rules and Regulations as outlined in Title 21 and Title42 CFR (refer to applicable regulations and DATA 2000 Waiver) http://buprenorphine.samhsa.gov/fulllaw.html).
- It does not function or serve as a:
- Residential service (meaning service provided in a 24-hour living environment in a non-hospital setting where room, board, and supervision are an integral part of the care, treatment, habilitation or rehabilitation provided to the individual)
- Detoxification facility, pursuant NCGS 10A NCAC 27G SECTION .3100 – “NONHOSPITAL MEDICAL DETOXIFICATION FOR INDIVIDUALS WHO ARE SUBSTANCE ABUSERS”, nor SECTION .3200 –“SOCIAL SETTING DETOXIFICATION FOR SUBSTANCE ABUSE”, nor SECTION .3300 – “OUTPATIENT DETOXIFICATION FOR SUBSTANCE ABUSE”, and does not maintain facilities and operational scope for said purposes.
- For the purpose of detoxification, buprenorphine and other medications approved for use in opioid treatment shall be administered in decreasing doses for a period determined clinically appropriate by a qualified professional.
Director of Substance Use Services, qualified Medical Professional in collaboration with FMRC Corporate Team, will be responsible for ensuring/updating ongoing operations of FMRC. Final decision as to the admission of any client, and/or the outpatient treatment process and services clients receive, as well as clinical process and agency operations are made at the discretion of the Director of Substance Use Services.
Clinical and Diagnostic Flow:
Assessment and Treatment Planning (expected duration of 1 to 2 office visits)
- Based on urgency of client’s need, the evaluation could be either a Med Evaluation (E & M) or a CCA.
- Due to the nature of clients seeking or already receiving FMRC (Suboxone) services, attention will be towards determining if they meet level of care and eligibility for any enhanced services in accordance with Clinical Coverage Policy 8A. If so, a referral will be made to that specific service.
- For individuals with a history of being physiologically addicted to an opioid drug for at least one year and meeting DSM-5 Opioid Substance Use Disorder before admission to the FMRC Program, buprenorphine and other medications approved for use in opioid treatment may also be used in maintenance treatment, following and in addition to induction and treatment. In these cases, buprenorphine and other medications approved for use in opioid treatment may be administered in excess of 180 days in stable and clinically established dosage levels.
*"Evaluation" means an assessment service that provides for an appraisal of a client in order to determine the nature of the client's problem and his need for services. The services may include an assessment of the nature and extent of the client's problem through a systematic appraisal of any combination of mental, psychological, physical, behavioral, functional, social, economic, and intellectual resources, for the purposes of diagnosis and determination of the disability of the client, the client's level of eligibility, and the most appropriate plan, if any, for services. Each client transferring from another Suboxone provider will complete an intake packet and follow procedures above.
- Common behaviors and defense mechanisms of addicted patients will be anticipated. Medication, if on-site will be stored in a secure location, and the possibility of diversion will be minimized. Office items (e.g., prescription pads, syringes, needles) and staff possessions will be secured to minimize theft. Though via aforementioned adhered to buprenorphine clinical practice guidelines buprenorphine programming (medicinally) is a prescribing only modality and exercised as such at FMRC, pain management and rheumatology scopes of practice and services deployed and clinically delivered by physicians may warrant non-buprenorphine medications and medication management treatment mechanisms to be delivered and/or maintained on-site.
After the initial Assessment and Treatment Planning, the treatment is conducted in three (3) phases as described below.
Induction Phase: (expected frequency: one time per week for 2-4 weeks); duration per facility visit 45 minutes to 2+ hours, depending on induction medication titration clinical needs.
- The medically monitored startup of buprenorphine therapy. Buprenorphine for induction therapy is administered when an opioid-addicted individual has abstained from using opioids for 12–24 hours and is in the early stages of opioid withdrawal. If the patient is not in the early stages of withdrawal (i.e., if he or she has other opioids in the bloodstream), then the buprenorphine dose could precipitate acute withdrawal.
- Induction may be initiated as observed therapy in the physician’s office and s appropriate may be carried out using buprenorphine products, dependent upon the physician’s judgment.
Stabilization Phase: (expected frequency: 1 - 2 visits/week month 1; months 2 & 3 Q7-14 days, per compliance and clinical discretion; 8-12 weeks)
- The goal of the stabilization phase is to attempt to reach a daily maintenance dose within 1-2 weeks. It begins when a patient has discontinued or greatly reduced the use of his or her drug of abuse, no longer has cravings, and is experiencing few or no side effects. The buprenorphine dose may need to be adjusted during the stabilization phase. Because of the long half-life of buprenorphine it is sometimes possible to switch patients to alternate-day dosing once stabilization has been achieved.
Maintenance Phase: (expected frequency: 1-2 visits/month)
- Once stable, patients enter maintenance therapy. It is reached when the patient is doing well on a steady dose of buprenorphine/naloxone. It may be associated with gradual dose reductions (medical withdrawal) and eventual elimination of treatment, or there may be an indefinite continuance to avoid relapse of addiction. The length of time of the maintenance phase is individualized for each patient and may be indefinite. The alternative to going into (or continuing) a maintenance phase, once stabilization has been achieved, is medically supervised withdrawal. This takes the place of what was formerly called “detoxification.”
Dosage and Administration of Suboxone:
- Suboxone treatment is intended for use in adults and adolescents more than 16 years of age and is administered sublingually or IM as a single daily dose. The recommended target dose is in the range of 12 to 16 mg/day. The pill or film is placed underneath the tongue until it has fully dissolved and typically will be absorbed within 10-20 minutes.
OPIOID DEPENDENCE TREATMENT PROGRAMMING MODALITY
Services: Substance abuse disorder clinical treatment, and diagnostic formulations; ASAM Certified addiction medicinal treatment(s) [e.g., Suboxone, Acamprosate, naltrexone], psychotropic medications, individual and group counseling, family therapy, enhanced services, adjunct agency, natural/self-help support group modalities. Programming prescribing practices pertinent receipt of medication administration may be modified at any time pursuant clinical discretion for client population; compliance contingent.
Populations Served: Clients sourced externally/internally for medication-assisted substance abuse treatment; substance abuse disorder, as categorically outlined and specified in the APA DSM-V (or its successors). Ideal candidates for Opioid Addiction Therapy with Buprenorphine are individuals who have been objectively diagnosed with opioid addiction, are willing to follow safety precautions for treatment, can be expected to comply with the treatment, have no contraindications to buprenorphine therapy, and who agree to buprenorphine treatment after a review of treatment options.
Entrance / Medical Criteria:
- Diagnosis of opioid dependence F11.20 (DSM-5/ICD-10)
- Consumer has been informed of safe and effective treatment planning options and has chosen this method of treatment, and understands the potential risks and benefits, and is willing and able to follow the treatment plan.
- Not dependent on high doses of benzodiazepines or other central nervous system depressants including alcohol, without applicable ASAM dimension consideration of inpatient and/or outpatient detoxification prior admission.
- No co-occurring mental health conditions that may undermine the ability to participate in treatment.
- History of relapse and/or current co-morbidity and ASAM criteria do not indicate the need for a higher level of care.
- History of poor response to well-conducted episodes of buprenorphine treatment.
Discharge Restrictions: No client compliantly engaged in treatment and under normal and customary treatment program conditions shall be discharged from the program while physically dependent upon buprenorphine or other medications approved for use in opioid treatment, as prescribed/administered by Medical Director, unless the client is provided the opportunity for protracted detoxification from the drug or referral to appropriate provider(s). Reference FMRC Participation Agreement, Narcotics Contract(s), and/or Substance abuse Treatment Planning document(s) for more compliance information.
Dual Enrollment Prevention: The FMRC program will utilize CSRS (N.C. Controlled Substances Reporting System) for purposes of monitoring dual enrollment and/or outside sourcing of opioid/controlled substance procurement by its clients through obtained client consents, client registry/services tracker, and “waiting list management system”.
Waiting list management system is a component of capacity management, whereby systematic monitoring of treatment demand and current participation is maintained. The data required for the waiting list management component of a capacity management system shall include patient identifiers for each consumer seeking treatment, the date initial treatment was requested, and the date the consumer was removed from the waiting list.
Diversion Control Plan shall serve as a check and balance for dual enrollment prevention and shall include the following:
- Call-ins for client-stored prescription counts/checks
- Call-ins for drug testing, in addition to systematic testing commensurate facility visits
- Drug testing results that include a review of the levels of buprenorphine or other medications approved for the treatment of opioid addiction, and any other substances, illicit or licit, as determined necessary to ensure optimum delivery of program compliance and treatment outcome(s).
- Client attendance minimums
- Compliant networking and/or cooperation with local Law Enforcement and other community agencies.
Expected Outcomes of Medication-Assisted Treatment (MAT):
- Improve survival
- Increase retention in treatment
- Decrease illicit opiate use
- Decrease hepatitis and HIV seroconversion
- Decrease criminal activities
- Increase employment and pertinent biopsychosocialspiritual domain health
- Improve birth outcomes with perinatal addicts
- Ultimate goal is for patient recovery with full social, holistic, and autonomous function.
FMRC Staff Credentialing: General and Clinical Acumen:
All FMRC Clinicians and Physicians are guided by ASAM Standards of Care and Performance Measurement, as demonstrated and incorporated herein by reference:http://www.asam.org/practice-support/standards-and-guidelines, licensure boards, as well as comply with the current clinical coverage policy in effect relative credentialing and delivery of substance abuse services.
Physician Qualifications (MD or DO):
- Have a current registration number and unique identification number from the Drug Enforcement Agency (DEA) (this comes after the Secretary of Health and Human Services-specifically the Division of Pharmacologic Therapies (DPT) within the Center for Substance Abuse Treatment (CSAT) has been notified of intent to treat patients with this product who will in notify the DEA once qualified)
AND meet any one or more of the following criteria:
- Hold a subspecialty board certification in addiction psychiatry from the American Board of Medical Specialties.
- Hold an addiction certification from the American Society of Addiction Medicine (ASAM).
- Hold a subspecialty board certification in addiction medicine from the American Osteopathic Association (AOA).
- Has with respect to the treatment and management of patients who are opioid addicted, completed at least 8 hours of training (through classroom situations, seminars at professional society meetings, electronic communications, or otherwise) that is provided by ASAM, the American Academy of Addiction Psychiatry, the American Medical Association, AOA, the American Psychiatric Association, or any other organization that the Secretary of the U.S. Department of Health and Human Services (DHHS) determines is appropriate for purposes of this sub clause.
- Has participated as an investigator in one or more clinical trials leading to the approval of a narcotic drug in Schedule III, IV, or V for maintenance or detoxification treatment, as demonstrated by a statement submitted to the DHHS Secretary by the sponsor of such approved drug.
- Has such other training or experience as the State medical licensing board (of the State in which the physician will provide maintenance or detoxification treatment) considered to demonstrate the ability of the physician to treat and manage patients who are opioid addicted.
- Has such other training or experience as the DHHS Secretary considers as demonstrating the ability of the physician to treat and manage opioid‐dependent patients. Any criteria of the DHHS Secretary under this sub clause shall be established by regulation.
NOTE: Prescriber is responsible to adhere to the SAMHSA regulations for addiction treatment under the provisions of the Drug Addiction Treatment Act of 2000 (DATA 2000 and for complying with all associated state and federal opioid treatment and maintenance protocols as they relate to physician qualifications, privacy and confidentiality of the patient, dispensing and prescribing of buprenorphine products, record keeping and coordinating treatment with addiction and psychiatric treatment programs.
NOTE: Direct Care Staff are identified as “Clinicians”, “SU Services Director”, and/or “MD”, whereas further defined as individuals who provide active direct care, treatment, rehabilitation or habilitation services to clients.
Support Staff (administration and other) may be employed as providing "Support services", meaning services provided to enhance an individual's progress in his/her primary treatment/habilitation program.
Training: Proper training on the use of buprenorphine as a facet in substance use recovery programming will be the key to the successful introduction of this treatment paradigm, regardless of the clinical setting of buprenorphine treatment.
- Physicians treating opioid addiction shall establish a level of comfort and expertise with this form of care. For example, a physician might choose to refer a patient with addiction and depression, depending on the severity of depression, whether a psychologist or psychiatrist is available in the area, and whether the patient can afford specialized mental health care, among other factors.
- Expertise includes knowledge of applicable practice standards or guidelines, familiarity with the evidence supporting the recommended treatments, protocols for primary treatment or referral of patients with certain complicating conditions (e.g., severe depression), and knowledge of any applicable regulations or laws.
- Physicians must be knowledgeable about the most up‐to‐date treatments for opioid addiction, including pharmacotherapy, psychosocial interventions, self‐help and mutual‐help groups, and other appropriate treatments.
- Physicians must participate in addiction medicine training and professional activities and should learn from other professionals in addiction treatment. Basic and ongoing training in addiction treatment will greatly enhance a physician’s effectiveness in treating opioid addiction.
- Physicians must consider and plan for the full range of their patients’ needs before initiating treatment as each patient presents with different and usually complex needs. Candidates for buprenorphine treatment of opioid addiction should be assessed for a broad array of biopsychosocial needs in addition to opioid use and addiction, and should be treated and/or referred for help in meeting those needs.
- Physicians must participate in the DATA 2000‐qualifying 8‐hour training program on buprenorphine.
- SAMHSA maintains a list of upcoming DATA 2000‐qualifying buprenorphine training sessions on their website at: http://www.buprenorphine.samhsa.gov. These sessions include Web‐based courses accessible from the physician’s own computer. Detailed information about the DATA 2000 paradigm and the physician waiver process also can be found on the SAMHSA Buprenorphine Web site. Additionally, information can be obtained by contacting the SAMHSA Buprenorphine Information Center by phone at 866‐BUP‐CSAT (866‐287‐2728) or by e‐mail at firstname.lastname@example.org.
FMRC Program and Client rules:
Clients agree to abide by all rules, policies, and procedures of the FMRC Substance Use Services Outpatient Treatment Participation Agreement, incorporated by reference herein. Each client will be subject to random and/or scheduled mandatory biochemical assays (ex., oral, blood, urine). Clients agree to abstain from any/all non-prescribed/unauthorized/illicit psychoactive substances during entire course of treatment with FMRC OMAT Program. Clients testing positive for program prohibited substances are subject to medical and/or clinical review and treatment modification accordingly, up to and including program curtailment and/or termination.
FMRC OMAT/Suboxone program client treatment monitoring and compliance for purposes of continued eligibility and participation is determined by factors as:
- Absence of recent drug abuse, as evidenced by UDS and self-report.
- Clinic attendance, as determined medically/clinically necessary by attending MD and/or Director of Substance abuse Services;
- Absence of behavioral problems at the clinic
- Stability of the patient’s home environment and social relationships, as evidenced by ongoing periodic clinical psychosocial assessment
- Length of time in comprehensive maintenance treatment
- Assurance that prescribed medication can be safely stored and self-administered within the patient's home and possession
- Evidence the rehabilitative benefits patients derive from decreasing the frequency of clinic attendance outweighs the potential risks of clinical deterioration and/or controlled substance diversion
Random testing for alcohol and other drugs shall be conducted on each active opioid treatment client with frequency ranging from a minimum of once each month of continuous treatment after the initial 4-month programming to testing administered every office-based visit -- drug testing will include at least the following: opioids, methadone, cocaine, barbiturates, amphetamines, THC, benzodiazepines and alcohol. Alcohol testing results can be gathered either by urinalysis, breathalyzer or other alternate scientifically valid method approved for use in FMRC outpatient facilities.
Upon completion of initial four month opioid dependence medication-assisted treatment program, Medical Director will re-assess client’s biopsychosocial state via medical evaluation and make recommendations for continuance of program treatment in whole or in part, adjusting service schedule accordingly.
OMAT facility Policies and Procedures are purposed to create and operationalize clinically and ethically sound operational flow of clients through the OMAT/Suboxone Program.
OMAT Treatment Planning Model:
**Transferring Suboxone clients may experience a modified treatment plan, at the direction of Medical Director and/or Director, Substance Use Services. Administration will utilize Suboxone Program Client Services Tracker to update client’s received services with each treatment**
Administrative staff will:
- Make all reasonable efforts to ensure there are no two (2) OMAT therapeutic services scheduled on any one day for Medicaid clients, AND to schedule
- all Suboxone medication management appointments over 1-4 consecutive days during the week per Medical Director discretion, and
- OMAT individual counseling, CCAs, and group counseling adjacent physician visits during the week.
- Make reminder calls to all outpatient including OMAT clients the day before their appointment
- Clients with urgent/emergent needs that need an appointment for the following day must contact the FMRC office by 4 pm the day prior
- These non-regularly scheduled appointment needs will need to be approved by Medical Director or Director of Substance Use Services and be primarily dependent upon client ASAM/biomedical, compliance, and psychosocial need.
- Ensure that established intake packets include the OMAT Participation Agreement, MD’s Suboxone program agreement, MD’s Narcotics Contract, Substance Use Tx Planning documents for signature.
- Check-in and direct all OMAT clients to the appropriate area of the facility.
- Intake process and general procedures, including biochemical assays and vitals, are the same as existing/new outpatient/medication management clients.
- Prepare printed schedule for MD and client charts (encounter forms) with the following and provide them to MD prior to MD seeing clients:
- Client vitals (Trillium benefit plan unit number notated at top),
- E&M/Med Evaluation form
- Clinical Opiate Withdrawal Scale (COWS) screener
- Client treatment compliance sheet
- After client’s initial meeting with MD, ensure all Suboxone clients have scheduled appointment(s) for individual therapy, CCA, and/or group counseling
- Upload any and all client documentation returned to them by MD (including prescription copy) or Licensed Clinician, and follow clinical instructions on Encounter Forms, Medical Evaluations as applicable, and OMAT Participation Agreement.
- Generate billing tickets accordingly
- Ensure all Suboxone clients have executed a release of information aapplicables .
- On a regular basis check to see if clients are receiving any other services with FMRC or with other providers -- this is for the purposes of Trillium benefit plan tracking and applicable to Medicaid and IPRS clients only.
- Ensure that all OMAT clients get scheduled for a complete CCA for the 1st available appointment with a licensed therapist immediately following intake and preferably prior first physician visit for Program Director review and/or admission screening.
- All clients must receive a CCA within the first two weeks of their participation in OMAT.
- Copy every Suboxone prescription written for clients and:
- Scan it into EHR client chart
- Place the prescription copy in the prescription drop-box located in the administrative area
- Complete daily deposit reconciliation form/information, perform bank deposit accordingly; dual verification, bank deposit slip, scanned into Z-file.
- Maintain an updated FMRC’ OMAT client registry, in accordance with SAMHSA Buprenorphine Clinical Practice Guidelines
- Prior to client’s visit and before seeing the MD, notate on client encounter form the number of outpatient unmanaged units utilized (Medicaid clients)
- Notify Program and Medical Director and clients when clients reach their 20 units in order to apprise clients of awaiting TAR and/or necessity of converting to self-pay for continuation of Suboxone services.
- Submit TARs for all OMAT clients (with clinical documentation assistance from Program Director/back office) when Medicaid clients reach 20 units expended.
- Double check that clients have signed a short-term therapy treatment plan at induction, intake, or CCA, whichever service is provided first prior to uploading
- Will complete all necessary CCAs, psychotherapy modalities (individual and group)
- Will indicate on encounter and/or referral forms any referrals to other FMRC services and notify staff accordingly
- Will utilize COWS screening tool OMAT potential clients during CCA
- Will assess all OMAT clients for eligibility to Enhanced Mental Health Services and/or modified/higher level of care provider(s0 as appropriate and pursuant clinical coverage policy/guidelines in effect
NOTE: All OMAT clients will receive a biochemical assay by FMRC lab staff during every visit, following existing protocol for Medication Management/Urine Drug Screen policies and procedures. Refer to “OMAT Participation Agreement” and “FMRC OMAT Program” documents for additional contingency management. Biochemical assays will be billed as separate outpatient services and are not subject to designated area authority/catchment entities.
NOTE: Medicaid OMAT clients, per MCO benefit plan, have 24 unmanaged visits (units) towards OMAT programming, applicable to therapeutic components only.
- Individual and Group counseling accrue towards the 24 unmanaged visit benefit plan.
- The OMAT/Suboxone program is inherently a 35-unit model over 120 days
- TAR submitted at 20 units expended must contain: CCA, TX PLAN, & ASAM
- Clients unauthorized by the MCO for additional unmanaged benefit plan services will be responsible for ongoing services via self-pay, with such payment collected when services are rendered.
- FMRC OMAT currently accepts/enrolls for authorization Medicaid, most major medical insurance, and private-pay clients. Clinician/Physician paneling and credentialing may determine/select provider and/or service delivery.
Client Treatment Compliance Policies:
- Two (2) unexcused absences from OMAT program services (CCA, individual or group therapy, and/or medication management/POV) will result in modification to treatment planning, up to and including termination from OMAT.
- Unexcused absence is defined as “client no show without prior contact to administration and/or approval from Medical Director and/or Director of Substance Use Services”
- UDS/Biochemical Assays resulting positive for psychoactive substances without prior authorization/ outside MD approved prescribing practice, regardless of provider, will result in modification to treatment planning, up to and including termination from OMAT program, at discretion of Medical Director and/or Director of Substance Use Services
- Clients suspected of psychoactive substance diversion, as evidenced by such mechanisms as CSRS and law enforcement notification, will immediately be terminated from FMRC OMAT. Upon such knowledge or valid suspicion, outpatient staff will immediately notify Facility Director, Medical Director, and Director of Substance Use Services
- Clients will bring in signed 12-step meeting attendance cards to every OMAT service visit
- Refer to client OMAT Participation Agreement for additional client intolerances and facility rules
- Clients will on demand bring to the facility their medication packaging for prescription counts.
- Clients may be relegated to modified medication management practices (prescription receipt) pursuant level of compliance