Response 892690761

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Draft Terms of Reference One

1. Describe and compare essential elements of models of service delivery for opioid dependence treatment (ODT) in Australia (and internationally) including best practice guidelines and current models that support access to ODT medicines through both pharmacy and non-pharmacy settings

ToR-1
The Network of Alcohol and other Drugs Agencies (NADA) is the peak organisation for non government alcohol and other drugs services in NSW. We advocate for, strengthen and support the sector. NADA’s decisions and actions are informed by the experiences, knowledge and concerns of its 100 organisational members that provide a broad range of alcohol and other drugs services including health promotion, harm reduction, early intervention, treatment and continuing care programs.

NADA welcomes the opportunity to comment on the Draft TOR for the proposed post-market ODTP review.

NADA supports the examination of models of service delivery for ODTP, particularly to develop a more consistent approach across jurisdictions, regions, pharmacy and non-pharmacy settings.

We recommend that:
• This should take into consideration the complexity of the lives of people on the ODTP, including the essential health and psychosocial supports required for them to participate fully and meaningfully in their lives and communities. This may include access to affordable and appropriate housing and access to employment and job training providers if requested.

• Multidisciplinary ODTP teams should be examined through a cost-benefit lens including the benefits of easy access to liver clinics, mental health services and case management models.

• The service delivery models examined take into account:
o changes in funding, treatment and support options for opiate dependent people over the last 60 years since Methadone was first introduced.
o the barriers to access in rural and regional areas.
o the aging population and the limitations and complexities that ageing can present for those on ODTP, for example, comorbidities, disability and physical access, decreased income, transport.
o the learnings gleaned from the ODTP response to Covid-19 and the likelihood and implications of future pandemics – including consumer access to Naloxone.
o specific service settings that present further barriers to treatment such as prisons, public/private clinics, GP practices, nurse led models, Aboriginal Community Controlled Health Services.
o outreach models.
o flexible models that incorporate accessible options for modified release buprenorphine injections.

Draft Terms of Reference Two

2. Examine the consumer experience, focusing on equity of access and affordability of ODT medicines across the different models of delivery. This will include consideration of access to ODT for at risk population groups including people living in rural and remote areas and Aboriginal and Torres Strait Islander peoples

ToR-2
It is essential that the consumer experience be highlighted and that consumers be represented on the review panel.

Additional vulnerable and at-risk populations should include:
• People with mental health concerns
• Pregnant women
• Women with children in their care
• People experiencing domestic and family violence
• People in custody
• Older people
• People who are homeless or at risk of homelessness

The negative impact and subsequent cost of stigma and discrimination on people on ODT needs to be fully examined and addressed.

Consumer experiences of the ODTP during Covid should be examined to inform future models of service delivery, for example, outreach models including home deliveries.

Draft Terms of Reference Three

3. Explore the utilisation of PBS subsidised ODT medicines in Australia, including funding and costs incurred in the supply and dispensing of Opiate Dependence Treatment Program (ODTP) medicines in pharmacy and non-pharmacy settings. This will include examination of current PBS restriction criteria and the impact of the listing of modified release buprenorphine injections on the PBS ODTP

ToR-3
The review will be valuable in the long run, however it should be timely and equitable given the ongoing adverse health, social and economic impacts the current arrangements are having on people accessing ODT.

Utilisation of PBS subsidised ODT medicines does not measure unmet need. An assessment of unmet need is required to fully understand and respond to the need for ODTP and the barriers to accessing the program.

A consistent and equitable cost structure for ODT is required across jurisdictions and settings.

Any examination of the cost of the ODTP should be informed by the considerable evidence of benefit to the economy, health system, individuals, families, children and the community in general.

Examination of the governing legislation of the PBS with respect to ODTP, regardless of dispensing site or the current co-payment and safety net arrangements, is required.

Draft Terms of Reference Four

4. Propose alternative service delivery arrangements for access to ODT medicines, with an aim of identifying an accessible, cost-effective and efficient ODTP for both consumers and the Australian Government

ToR-4
Consideration of alternative models should include nurse led models, GP incentives, and collaboration and incentives for the non government AOD sector. Monitoring of incentives would be required to ensure compliance, efficiency and effectiveness.

Explore service delivery arrangements for access to ODT medicines within residential rehabilitation that address stabilization, reduction and cessation of ODT medicines.

Final comments

Do you have any additional comments or feedback regarding the draft ToR for the ODTP PMR?

Additional
Committee representation should include the following:
• Consumers
• Aboriginal and Torres Strait Islander people
• Representative groups
• Service providers representing all service delivery types