The following letter was drafted by a group of clinical providers working to promote policy changes that have the potential to improve capacity to treat hepatitis C in Opioid Treatment Programs in New York State. Based on early feedback on the draft letter, we plan to revise our approach in order to most effectively advocate for increased resources to address viral hepatitis care in opioid treatment programs throughout New York State. We will contact each person who has input their name below prior to taking any further action.
We are currently requesting your review and comment on the recommendations documented in this draft letter below.
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- Comments can also be submitted to Andrew Talal, MD, MPH, NYS Hepatitis C Telehealth Workgroup Chair via Marc Badura email@example.com.
- There is a proposed Amendment to OASAS General Service Standards for Substance Use Disorder – Part 822 regulations (https://oasas.ny.gov/system/files/documents/2020/05/822-proposed.pdf) to allow for more flexibility in treatment/recovery planning and removes barriers to care. This amendment is open for public comment until 7/26/20, comments can be submitted to firstname.lastname@example.org.
July 1, 2020
Re: Steps to rapid expansion of Hepatitis C Treatment in Opioid Treatment Programs
OASAS and Medicaid Leadership,
A group of providers who work in the drug user health and hepatitis C (HCV) field are writing to advocate for increased resources to permit HCV treatment in opioid treatment programs (OTPs) across New York State (NYS). We believe that enhancing reimbursement for HCV treatment, revising regulation to permit co-administration of direct acting antivirals (DAAs) and medications used to treat opioid use disorder, and ensuring permanent approval of telemedicine regulations enacted in response to COVID-19 are crucial steps to promote rapid expansion of HCV treatment in OTPs. Advocacy from OASAS and restructuring of OTP reimbursement policies would have immediate and long-lasting effects on the efforts to eliminate HCV from NYS.
Despite the widespread availability of effective DAAs, high OTP patient interest in HCV treatment, and an extensive evidence base of the effectiveness of HCV treatment in OTPs, HCV treatment within OTPs has been slow to expand in NYS. We believe that this is due in large part to structural barriers related to financial viability as opposed to a lack of effective treatment options. Drs. Andrew Talal and Lawrence Brown have been successfully treating hepatitis C at START Treatment & Recovery Centers via telemedicine for many years. Our clinics are models of how both on-site and telemedicine HCV treatment services can address our patients’ HCV treatment needs.
Enhanced reimbursement of HCV treatment in OTPs would incentivize OTPs to develop and to sustain HCV treatment programs. Based upon our experiences, we have a few suggestions as outlined below:
1) Revision of APGs: Under current APG billing rates, the potential reimbursement for an initial HCV evaluation is four times lower than providing medication management evaluations during the same amount of time.
2) Enhanced reimbursement for HCV services could be achieved via a weighted APG service for infectious diseases. The weighted APG could provide equitable reimbursement on par with HCV treatment reimbursement in GI and primary care clinics. Under bundled rate billing, additional reimbursement for HCV care could be achieved via reimbursement of a discrete HCV treatment service in addition to the bundled payment, or an enhanced bundled rate for those clinics providing HCV treatment to patients. Reimbursing for hepatitis A and B vaccination administration is also essential. In addition, lifting of the 5% cap on medical services in OTPs is needed to significantly expand HCV treatment.
3) Expanding and maintaining telemedicine capacity in OTPs, regardless of urban or rural location, is another crucial step in expanding HCV treatment. Telemedicine addresses the skilled workforce shortage present in many OTPs and provides patients access to needed specialty care. Without the ability to quickly implement HCV treatment via telemedicine, the OTP system would need many years to develop an onsite workforce capable of treating hepatitis C on a large scale. In some OTPs, providing on-site HCV treatment may be an impossibility. Similarly, given the ease of HCV treatment administration, permitting co-administration of DAAs and MOUD should be permitted. Reimbursement for DAA administration would be another path toward incentivizing HCV treatment within OTPs.
4) Promoting HCV treatment in Part 822 regulations: Explicitly including HCV treatment in the OASAS 822 regulations would ensure that programs can rapidly address their patients’ needs for HCV education and treatment. OTPs are responsive to regulatory changes. Hepatitis testing, treatment and patient education could be included as a program requirement under article 822.7(f) or 822.8 (c)1(i). Pairing regulatory requirements with enhanced reimbursement would have the greatest and most immediate impact on the adoption of HCV treatment programs in OTPs.
OTPs are ideally situated to provide hepatitis C treatment to the most at-risk patients and can go a long way to promoting the Gov. Cuomo’s goal of being the first state in the nation to eliminate HCV. Treating HCV in people who inject drugs reduces 10-year mortality and liver-related comorbidities by 30% as well as curtailing incident infections.
With OASAS’s support, NYS can make great strides in reducing HCV infections and improving the lives of our patients. By incentivizing HCV treatment with enhanced reimbursement and expanding telemedicine services, OTPs can be an integral part of the Governor’s plan to eliminate HCV infection.
Andrew Talal, MD, MPH
Professor of Medicine
Jacobs School of Medicine and Biomedical Sciences, University of Buffalo
Lawrence Brown, MD
Chief Executive Officer
START Treatment & Recovery Centers
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