Over the last few weeks, there has been an expansive and dramatic shift to the provision of Substance Use Disorder services onto digital platforms as we move into the COVID-19 pandemic crisis. Recovery community and treatment organizations would be well served to develop these services in a manner that supports safe, effective and individualized care. We must be transparent and respect the rights of the persons served with Virtual Recovery Support Services (VRSS), assuring that services are only provided in ways that support them and their recovery. These ten assurances are intended to assure the people we serve dedication to high quality effective and transparent care that is focused on their individualized recovery process.
Assurance 1: VRSS service providers must assure that care provided is of high quality – Recovery Community Organizations and substance use treatment providers should work with funders, insurers and the government to ensure VRSS platforms support effective and appropriate access to high quality care. Marginalized communities who lack access to high tech remote access care must be ensured equitable access to services.
Assurance 2: All VRSS digital information holders must assure persons served that they will do no harm – Sharing digital health data should always have the purpose of supporting recovery and not be used to discriminate against people with substance use disorders (SUDs). Persons with SUDs have unique risks of discrimination and prosecution that are not protected under HIPAA. Informed consent in culturally competent ways for persons served is crucial. Funding sources need to only use information that they have in ways that both adhere to applicable laws and support recovery without risks of discrimination or legal sanctions. RCO and SUD treatment providers must to take their responsibility to protect this information very seriously.
Assurance 3: People seeking help for an SUD should be assured that they will not be forced to use VRSS – The people we serve should have the final say in what types of care they receive, particularly regarding the use of VRSS as there may be pressure to use them under the premise that they cost less or are more convenient for the provider.
Assurance 4: The people served must be assured that they retain control over their own information and decide on what happens to their own highly sensitive information – Persons served should always have the final decision on whether their information is shared, and retain the right to know how providers use and share their highly personal and sensitive information.
Assurance 5: RCOs and SUD Treatment providers must assure transparency about how services are funded, avoid data mining and other revenue streams potentially in conflict with the interests of the person served. – Persons served need to know that the care they are getting is the only focus of care and that their data is not a revenue stream for the care provider or any entity involved in the care process.
Assurance 6: Digital health information gathered by the RCOs and SUD Treatment providers must be accurate – Care providers need to be able to assure persons served that they adhere to high standards of data quality and integrity. Validation methods need to be auditable and transparent to the persons served.
Assurance 7: Digital health information should be vigorously protected in verifiable ways- Those entities entrusted with digital health information must follow the privacy and security rule as a minimum standard and adapt to state-of-the-art security standards as they evolve. Persons served should know that high standards are being met in their VRSS care.
Assurance 8: Security violations should be reported promptly – If security lapses occur, proper reporting and accountability processes are followed. Entities that suffer security breaches must let persons served know of the event and what is being done to fix it. RCOs and SUD Treatment providers should inform persons served within 10 business days of detection of any breach, potential consequences and mitigation efforts.
Assurance 9: VRSS should always facilitate connection – RCOs and treatment organizations using VRSS need to assure persons served that care is focused on their needs and not designed for the convenience or ancillary purpose of the service providers or funder.
Assurance 10. Persons served must be actively engaged in how this technology evolves – “Nothing about us without us” is fundamental to the recovery community. It is vital that the recovery community be actively engaged in the development, implementation and use of VRSS now and into the future.
William Stauffer April 5, 2020