During the COVID-19 pandemic, it is critical to remember that we are still in the midst of an overdose crisis. While many regulators have argued that methadone and buprenorphine policies must be deliberately restrictive due to the risk of overdose, adverse medication effects, and medication diversion, the COVID-19 crisis has forced many regulating bodies to re-evaluate these policies in order to comply with the urgent need for communities to practice social distancing and sheltering-in-place.

Multiple government agencies including SAMHSA, the DEA, Medicare, and Medicaid have recently announced policy changes to allow for more flexible prescribing and dispensing. While these changes are a step forward, clinics have been either reluctant or resistant to fully implement them to the extent allowable under law. In light of the evolving pandemic and the needs of the community, we must not allow fears of overmedication and diversion to outweigh the health risks caused by patients being forced daily to congregate in large groups, or being driven to an adulterated illicit drug supply.

Close person-to-person contact and group assembly are currently actions deemed hazardous to public health. Unfortunately, “sheltering in place” is unrealistic for many people who use drugs. People who use opioids are either forced to continue to engage with the illicit drug market or must comply with prohibitive and insurmountable requirements to receive medications for Opioid Use Disorder (OUD). Many opioid users are at an increased risk of COVID-19 infection due to being immunocompromised and/or having comorbid health conditions.

In order to reduce the risk of COVID-19 infection, involuntary withdrawal, and drug poisoning, the Urban Survivors Union and the undersigned organizations strongly recommend the following measures be taken immediately:

1) The only acceptable standard for discharge of patients from OUD treatment during the COVID-19 outbreak shall be violent behavior that would endanger their own health and safety or that of other patients or staff.

2) Administrative detox shall be fully suspended during the pandemic and patients shall be provided the opportunity to request dose increases as needed, given that the illicit drug market will continue to experience fluctuations and patients need access to these life-saving medications. Patient doses shall not be reduced during the transition to take-home care unless they request adjustments to their doses, or documented medical emergencies require it and patients cannot consent due to medical crises, as may be the case with severe respiratory distress resulting from COVID-19 infection.

3) Referrals for COVID-19 testing shall be made available at all opioid treatment programs (OTPs), as well as syringe service programs. Staff shall receive training to recognize the symptoms of COVID-19 and be familiarized with protocols to refer patients for further testing. Harm reduction providers can also play an essential role in “flattening the curve” of transmission by identifying cases, making medical attention available to those who test positive, and teaching life-saving harm reduction skills to help people stay safe during this crisis. Plain language and evidence-based public health materials about COVID-19 prevention, symptom identification, and treatment should be available in locally prominent languages at all locations for participants and their communities.

4) During the COVID-19 national emergency, healthcare professionals–including doctors, nurse practitioners, physician assistants, and pharmacists–shall not be required to complete the previously- mandated training and waiver to prescribe these medications, thereby making MAT available in all settings. Prescribers shall not have limitations on the number of patients that they can treat. Naloxone and other overdose prevention tools (i.e. fentanyl test strips) shall be prescribed or made available with all dispensed medications in compliance with state law.

5) Opioid treatment programs (OTPs), prescribing clinicians, and pharmacies shall actively work to expand access to methadone treatment through the medical maintenance/office-based and pharmacy-delivery methods currently allowed by federal exception/waiver. The existing OTP regulations for the dispensing of MAT shall be temporarily adjusted to require all pharmacies to dispense these medications. This will reduce the risks of transmission associated with daily clinic attendance and person-to-person contact. In accordance with SAMHSA recommendations, lockbox requirements for take-home dispensing shall be suspended. Standard dispensing protocols for other opioid medications are deemed sufficient, since child- and tamper-proof bottles are already in use for methadone and buprenorphine. (Per SAMHSA’s TIP 43, Chapter 5: “Some programs require patients to bring a locked container to the OTP when they pick up their take-home medication to hold
it while in transit. This policy should be considered carefully because most such containers are large and visible, which might serve more to advertise that a patient is carrying medication than to promote safety.”)

6) Take-home exception privileges shall be expanded to the maximum extent possible, limited only by available supply and operations for delivery. Any bottle checks that clinics wish to conduct shall be conducted by tele-medicine. Take-home schedules shall be authorized for individuals in all medical settings, including pharmacies and mobile vans. In light of new SAMHSA guidelines, clinics shall allow 14 to 28 days of take-home privileges to as many patients as possible. Patients testing positive for benzodiazepine or alcohol use shall be allowed the take-home privileges outlined in SAMHSA guidelines, but may be additionally required to check in via telemedicine for the purpose of decreasing the risk of adverse reactions, including overdose. Access to take-home doses is critical to keep patients engaged and retained in treatment.

7) Telehealth and service by phone shall replace any and all in-person requirements and appointments as the primary means of service provision until social distancing guidelines change. Toxicology requirements shall be suspended for the duration of telehealth-based services. Telemedicine services shall include waivered platforms, such as telephone intakes and video
conferencing, as some patients may have different access needs.

8) The regulatory in-person requirements for methadone inductions shall be lifted in order to be consistent with the new policy changes for buprenorphine inductions. Clinic-based in-person appointments shall conform to social distancing requirements and OSHA guidelines for the management of the COVID-19 pandemic.

9) DEA restrictions on mobile medication units shall be revised to accommodate delivery of medications to individuals who are sequestered in their homes, are quarantined, or live in rural communities that are 15 miles or more from the nearest opioid treatment program.

10) State and federal Medicaid dollars shall be expanded to cover all costs for take-home medications not otherwise covered by insurance for patients experiencing financial hardship due to COVID-19. In states that did not expand Medicaid, the state shall be the payor of last resort. In the interest of saving lives and adhering to existing public health protocol for management of COVID-19 transmission, it is necessary to make significant revisions to existing regulatory standards.

This is a critical time to take decisive action for the protection of patients, providers, their families, and the community. As our healthcare system reaches full capacity and becomes overburdened by COVID-19-related emergencies, as seen in Italy and Spain, providers on the front lines will be forced to make life and death choices. These recommendations outline a plan of primary prevention that will minimize the burden on our healthcare system and save lives during this national emergency.

We, the undersigned, are a coalition of direct service providers, community advocates, public health officials, medical professionals, human rights groups, people in recovery, treatment professionals, members of impacted communities, and many others. We ask SAMHSA, the DEA, and all other federal, state, and local regulatory bodies and health authorities to adopt these recommendations fully and immediately in light of the COVID-19 pandemic.

Organizations

Urban Survivors Union
Louise Vincent, MPH
Executive Director
National Harm Reduction Coalition
Monique Tula
Executive Director
The National Alliance for Medication-Assisted
Recovery
Zachary Talbott, MSW
President
Joycelyn S. Woods, MA
Executive Director
Faces and Voices of Recovery
Patty McCarthy, M.S.
Chief Executive Officer
National Viral Hepatitis Roundtable
Lauren Canary, MPH
Director
Law Enforcement Action Partnership
Major Neill Franklin (Ret.)
Executive Director
The Levenson Foundation
Benjamin A. Levenson
Chairman
Foundation for Recovery
Dona M. Dmitrovic, MHS
Executive Director
National Council for Behavioral Health
Chuck Ingoglia
President and CEO

Drug Policy Alliance
Kassandra Frederique
Managing Director, Policy Advocacy &
Campaigns
International Certification & Reciprocity
Consortium
Crystal Smalldon, CCAC, CIAC, RSSW
President
Behavioral Health Association of Providers
Pete Nielsen, MA, LAADC
CEO

Center on Addiction / Partnership for Drug-
Free Kids

Frederick Muench, Ph.D.
President
National Advocates for Pregnant Women
Lynn M. Paltrow, J.D.
Founder and Executive Director
Recovery Advocacy Project
Ryan Hampton
Organizing Director
Open Society Foundations
Sarah Evans
Unit Manager, Public Health Program
Kasia Malinowska-Sempruch
Director, Global Drug Policy Program
305 Psychotherapy Group
Mark Houston, LCSW
Owner and Psychotherapist
Addiction Professionals of North Carolina
Sarah Potter, MPA
Executive Director
AIDS United
Drew Gibson, MSW
Policy Manager for HIV & Drug User Health
Alcohol & Drug Abuse Certification Board of
Georgia
Amanda Finley
Executive Director
Alliance for Positive Health
Diana Aguglia
Regional Director
The BALM Training Institute for Family
Recovery Services/Family Recovery Resources
Beverly A Buncher, MA, CBFRLC, PCC
Chief Executive Officer
Bay Area Workers Support
Maxine Holloway, MPH
Co-Founder
Benevolence Farm
Kristen Powers
Interim Executive Director
Better Life in Recovery/Springfield Recovery
Community Center
David Stoecker, LCSW
Executive Director
BioMed Behavioral Healthcare, Inc
Brian A McCarroll DO. MS. ABAM
CEO, President

Brave Technology Coop
Gordon Casey
Chief Executive Officer
Broken No More
Tamara Olt, M.D.
Executive Director
CADA of Northwest Louisiana
Bill Rose, LAC, CCS, CCGC
Executive Director
C4 Recovery Foundation, Inc.
Ricard Ohrstrom, Chairman
Jack O’Donnell, CEO
Center for Optimal Living
Andrew Tatarsky, Ph.D.
Executive Director
Center for Popular Democracy/ Opioid
Network
Jennifer Flynn Walker
Senior Director of Advocacy and Mobilization
Central Texas Harm Reduction
Richard Bradshaw
Community Outreach Leader
CheckUpandChoices.com
Reid K Hester, Ph.D.
Director, Research Division
Chicago Drug Users Union
Peter Moinichen, CADC, CODP, MAATP
Co-Founder
Chicago Recovery Alliance
Brandie Wilson
Executive Director
Choices Recovery Trainings
Ginger Ross, CRSW, NCPRSS
Owner/Trainer
Church of Safe Injection
Kari Morissette
Director
Circle for Justice Innovations
Aleah Bacqui Vaughn
Executive Director
City of Revere – Substance Use Disorder
Initiatives Office
Julia Newhall, BSW, CPS
Director
Coastal Holistic Care
Jessi Ross
Founder
Connecticut Certification Board
Jeff Quamme, MSW
Executive Director
DanceSafe
Mitchell Gomez
Executive Director
Desiree Alliance
Cristine Sardina, BWS, MSJ
Director
društvo AREAL
Janko Belin
President
ekiM For Change
Diannee Carden Glenn
Director

Exponents, Inc.
Joseph Turner, J.D.
President and CEO
Faith In Public Life
Blyth Barnow, MDiv
Harm Reduction Faith Manager
Families for Sensible Drug Policy
Carol Katz-Beyer
President
Florida Opiate Coalition- Block by Block
Bonny Batchelor
Director
Foundation for Recovery
Dona M. Dmitrovic, MHS
Executive Director
Full Circle Recovery Center, LLC
Stephanie Almeida, CDAC
Founder
Georgia Overdose Prevention
Laurie Fuggitt, RN and Robin Elliott, RN
Co-Founder
GoodWorks: North Alabama Harm Reduction
Morgan Farrington
Founder
The Grand Rapids Red Project
Stephen Alsum
Executive Director
Grayken Center for Addiction, Boston Medical
Center
Michael Botticelli, MEd
Executive Director
Greater Hartford Harm Reduction Coalition Inc.
Mark A. Jenkins
Executive Director
Guilford County Solution to the Opioid
Problem
Chase Holleman, LCSW, LCAS
Program Director
Harm Reduction Action Center
Lisa Raville
Executive Director
Harm Reduction Ohio
Dennis Cauchon
President
Harm Reduction Therapy Center
Jeannie Little, LCSW
Executive Director
Health in Justice Action Lab
Leo Beletsky, JD MPH
Director
Health Professionals in Recovery
William C. Kinkle, RN, EMT-P, CRS
Co-Owner
Health Services Center, Inc.
Melissa Parker
Prevention Projects Director
Healthy Streets / Health Innovations
Mary Wheeler
Program Manager

HIPS
Tamika Spellman
Policy and Advocacy Associate
HIV/HCV Resource Center
Laura Byrne, MA
Executive Director
Hope Recovery Resources
Beth Fisher Sanders, LCSW, LCAS, MAC, CCS,
MATS
Chief Executive Officer
HRH413
Albert Park, MSW
Co-Founder
International Network of People Who Use
Drugs
Judy Chang
Executive Director
Illinois Association of Behavioral Health
Sara Howe, MDA
Executive Director
Inclusion Recovery
Dan Ronken, LPC, LAC
Founder
Indiana Recovery Alliance
Kass Botts
Executive Director
Innovative Health Systems
Ross Fishman, Ph.D.
President
Instituto RIA
Zara Snapp
Co-Founder

Organizations

www.ncurbansurvivorunion.org 9
Iowa Harm Reduction Coalition
Sarah Ziegenhorn
Executive Director
Katal Center for Health, Equity, and Justice
Gabriel Sayegh, MPH
Co-Executive Director
The Lemire Group LLC
Dean Lemire
Owner
Lifespan Counseling
Dene Berman, Ph.D., MPH, ABPP, MAC
Director
Lysistrata Mutual Care and Collective Fund
Cora Colt
Co-Founder and Treasurer
MEDPEARL LLC
Deanna Dunn, PharmD
Owner/Pharmacist
The Middle East and North African Network
of/for People who use Drugs
Hasan Taraif
Executive Director
Minnesota Recovery Connection
Wendy Jones
Executive Director
Movement for Family Power
Lisa Sangoi and Erin Coud
Co-Founders and Co-Directors
NCADD- NJ
Heather Ogden, CPRS, CRSP, CADC Intern
Advocacy Coordinator

New England Users Union
Jess Tilley
Executive Director
New Jersey Harm Reduction Coalition
Jenna Mellor
Executive Director
A New PATH, Parents for Addiction Treatment
& Healing
Gretchen Burns Bergman
Executive Director
New View Addiction Recovery Educational
Center
Jennifer A. Burns, MA
Executive Director
New York Center for Living
Audrey Freshman, Ph.D., LCSW, CASAC
Executive Director/Chief Clinical Officer
New York State Harm Reduction Association
Joseph Turner, J.D.
Co-Chairperson
North American Syringe Exchange Network/
Tacoma Needle Exchange
Paul A. LaKosky, Ph.D.
Executive Director
North Carolina Harm Reduction
Shelisa Howard-Martinez
Executive Director
North Carolina Survivors Union
Louise Vincent, MPH
Executive Director

Organizations

www.ncurbansurvivorunion.org 10
Northern Berkshire EMS
Stephen Murray, BBA, NRP
Paramedic Supervisor
ONESTOP Harm Reduction Center, North Shore
Health Project
Mary Doneski, MA
Program Manager
PeerNUPS/Athens/Greece
Christos Anastasiou
Coordinator
Pennsylvania Alliance of Recovery Residences
Fred Way, MA
Executive Director
Pennsylvania Harm Reduction Coalition
Devin Reaves, MSW
Executive Director
People’s Action
Sondra Youdelman
Campaigns Director
The People’s Harm Reduction Alliance
Shilo Jama
Executive Director
The Perfectly Flawed Foundation
Luke Tomsha
Executive Director
Philadelphia Drug Users Union
David Tomlinson, BA
Founder
Project Point Pittsburgh
Alice Bell, LCSW
Overdose Prevention Project Coordinator

Protect Families First
Annajane Yolken
Executive Director
Provenance Counseling
Lisa S Musarra, MSW, LCSW, LCADC, ICADV
Owner
The Reach Project, Inc and Reach Medical, PLLC
Justine Waldman, MD, FACEP
Chief Executive Officer
Reframe Health and Justice
Sasanka Jinadasa
Partner
Rights & Democracy NH, Rights & Democracy
VT, Rights & Democracy Institute
Kate Logan, MA/ABD
Director of Programming & Policy
R Street Institute
Carrie Wade, Ph.D., MPH
Director of Harm Reduction Policy
Chelsea Boyd, MS
Research Associate Harm Reduction Policy
San Francisco AIDS Foundation
Laura Thomas, MPH, MPP
Director of Harm Reduction Policy
The Seven Challenges LLC
Robert Schwebel, Ph.D.
Author and Program Developer
Sex Worker Advocacy Coaltion
Tamika Spellman
Lead Organizer
Sex Workers Outreach Project Behind Bars
Jill McCracken, Ph.D.
Co-Director

Organizations

www.ncurbansurvivorunion.org 11
Sex Workers Organizing Project- USA
Christa Daring
Executive Director
The Southern Tier AIDS Program
John Barry, LMSW
Executive Director
Students for Sensible Drug Policy
Betty Aldrich
Executive Director
Students For Sensible Drug Policy Africa
Ewelle Sylvester Williams, SW
Vice Chairman
Substance Use, Policy, Education and Recovery
PAC
Haley McKee
Co-Chair
Suncoast Harm Reduction Project
Julia Negron, CAS
Founder and Lead Organizer
Tennessee Recovery Alliance
Sara Alese
Executive Director
Texas Drug User Health Alliance
Mark Kinzly
Executive Director
Texas Harm Reduction Alliance
Joy Rucker
Executive Director
Texas Harm Reduction Conference
Emily Gray
Co-Founder

Texas Overdose Naloxone Initiative
Mark Kinzly
Executive Director
Truth Pharm
Alexis Pleus
Executive Director
Ukrainian Network of People who Use Drugs
Anton Basenko, ME
Chair of the Board
University of Missouri, St. Louis
Missouri Institute of Mental Health
Claire Wood, Ph.D.
Rachel Winograd, Ph.D.
Addiction Science Faculty
Urban Survivors Union, Greensboro Chapter
Derek McCray Miller
Member
Dr. Vando Medical Services
Leonardo Vando, MD
Chief Executive Officer
Vantage Clinical Consulting LLC
Jamelia Hand, MHS, CADC, CODP
Chief Executive Officer
Vermonters for Criminal Justice Reform
Thomas Dalton, J.D., MA, LADC
Executive Director
VICTA
Lisa Peterson, LMHC, LCDP, LCDS, MAC
Chief Operating Officer

Organizations

www.ncurbansurvivorunion.org 12

Voices of Community Activists and Leaders-
New York

Jeremy Saunders
Executive Director
Whose Corner is it Anyway
Caty Simon
Founding Co-Organizer
Women With A Vision
Christine Breland Lobre, MHS, MPH, LPC
Program Director
Zanzibar Network of People Who Use Drugs
Kassim Nyuni
Executive Director