OPPA submits comments on SMBO draft rules on OBOT
On Mar. 7, the Ohio Psychiatric Physicians Association submitted a letter, to the State Medical Board of Ohio related to draft rules on office based outpatient treatment (OBOT) of opioid addiction, 4731-33.
"As representatives of the psychiatric field, the OPPA is concerned with aspects of 4731-33-01 F. While we support the expectation that physicians providing OBOT seek collaboration with behavioral health care providers, we are troubled by the Board’s decision to mandate the required components of treatment, and in particular to require at least one of five particular behavioral interventions. We believe that the appropriate behavioral interventions are best determined by the behavioral health provider or collaborating team of providers."
Further,the OPPA has significant concerns with 4731-33-03 I.1-2. The wording used would make it impossible for a physician to prescribe mono-buprenorphine without risking his or her medical license except in the very limited and specific cases defined in 4731-33-03 I.2. We believe that these cases do not represent the breadth of situations encountered by physicians in practice and that limiting a physicians’ right to prescribe this medication is unnecessary and potentially harmful to patients. Several obvious examples, such as in cases of breastfeeding women or patients with allergy to naloxone, are immediately obvious, but even if these were added to the list provided in section 4731-33-03 I.2, we do not believe this would suffice.