billions from deceptions that “Suboxone Film was safer, less divertible, and less abusable”

From Bloomberg:

Indivior misled doctors and government health programs into believing that the drug, Suboxone Film, was safer and less likely to be abused than rivals, the Justice Department said in a statement Tuesday.

. . .

Federal prosecutors in the Western District of Virginia said Indivior’s deceptions had contributed to an epidemic that has killed thousands of people.

“Indivior obtained billions of dollars in revenue from Suboxone Film prescriptions by deceiving health-care providers and health-care benefit programs into believing that Suboxone Film was safer, less divertible, and less abusable than other opioid-addiction treatment drugs,” said the prosecutors.

Interestingly, SAMHSA has recently issued proposed recovery housing guidelines. (They are seeking feedback. Please send yours, whatever it is.) SAMHSA has previously published materials that stated the Fair Housing Act and Americans with Disabilities Act require transitional housing programs to allow legally prescribed medications.

In the past, concern about diversion of medications like buprenorphine was treated as an imagined problem (it’s not), or that it’s only diverted for instrumental use to avoid withdrawal in the context of barriers to access.

These guidelines speak to the issue of diversion in a new manner:

According the NSDUH (2017) the intentional misuse of buprenorphine increased over 30%, making it the fastest growing abused prescription opioid in the country. There are still other prescription opioids that are intentionally misused or abused more than buprenorphine, but this drug has witnessed the largest percentage uptick in popularity. In July 2018, SAMHSA conducted a technical expert panel on the inclusion of MAT into the recovery model of care. Our expert panelists described the diversion of mood-altering (partial and full agonist) MAT drugs as the act of diverting an appropriate prescribed medication from the intended recipient to another recipient. Also equally problematic is the intentional abuse of these medications such as mixing with other drugs or alcohol and/or injecting medications for the sole purpose of achieving intoxication. Since the abuse of mood-altering substances can have detrimental effects on other people’s sobriety living in close quarters such as a recovery house, our experts recommended several courses of action listed below to help ensure client safety.

  • Medication counts with staff and client
  • Increase drug testing (if suspected of diversion)
  • Communication between stakeholders, providers & staff (releases of information)
  • Distribution of lock boxes
  • Maintain proper documentation
  • Monitor specific residents
  • Open discussion of medications (e.g., group topic, potential triggers, etc.)

They also still appear to require the inclusion of any FDA approved medication. (That specifier, “FDA approved medication” does not appear to be limited to medications for SUDs.)

“Substance-free does not prohibit prescribed medications taken as directed by a licensed physician, such as Medication Assisted Treatment, and other FDA approved medications.”

For purposes of this document, SAMHSA’s official definition will serve as the benchmark from which to ascribe best practices and suggested minimum standards. The utilization of this definition is because it encompasses the basic tenets as set forth in the statute and it stipulates the inclusion of medication assisted treatment and other FDA approved pharmacological interventions.

It’s worth noting that legally prescribed medication played a key role in raising the opioid problem to the crisis level and sustaining it.

It’s also worth noting that legally prescribed, FDA approved medications can include opioids, benzos, muscle relaxers, and many other frequently misused drugs.

Implementation of these expectations are likely to result in very troubled programs, in an already troubled industry, and result in more stigma and NIMBY pushback that makes it harder for conscientious and recovery-oriented providers to establish programs.

The question isn’t whether maintenance patients should have access to long term recovery support, like sober housing. They absolutely should. The question that’s never discussed is, who should take responsibility for providing these patients with access to this kind of support? When you look at existing housing programs, they are generally started by people in recovery who want to help others succeed on their pathway or by treatment providers that committed their time and resources to extending recovery support for their patients.

Maintenance patients do not have adequate access to recovery housing. One way to explain this gap is that housing providers are discriminating. Another way to explain this is that maintenance treatment providers have failed to deliver this kind of recovery support. Of course, there are other possible explanations, and it might be a combination of explanations.

Another question is this, if large portions of recovery housing residents have misused maintenance medications, is it wrong to want an environment that does not allow those misused medications? If that’s a legitimate want, is it wrong to provide that? (And, under the FHA argument, what about benzos, gabapentin, stimulants, etc.?)

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