Addiction Medicine: Closing the Gap between Science and Practice

 Professional staffing requirements to assure
that clinical staff are adequately qualified to
implement evidence-based practices;

 Requirements related to services to be
delivered; or

 Requirements that treatment services
actually help patients achieve desired
outcomes of improved health and
functioning.^139

Like health care facilities, addiction treatment
programs* are subject to state licensing
requirements; however, for addiction treatment
programs, these requirements typically are set by
state agencies separately charged with authority
to oversee addiction services rather than by the
agencies responsible for regulating health care
facilities.^140 CASA Columbia’s review of
licensing and certification requirements for
addiction treatment facilities and programs†
found that the nature and extent of these
regulations vary significantly among states and
that certain addiction treatment programs (e.g.,
many state-run and religious programs) are
exempt entirely from state regulation. In
facilities that are subject to state regulation, the
staffing requirements do not consistently
mandate the involvement of professionals who
are capable of providing a full range of effective
interventions (including pharmaceutical and
psychosocial therapies), services rarely are
required to reflect best practices and quality

• Including (1) organizations or facilities that provide

non-hospital based residential or outpatient addiction
treatment, or opioid replacement therapy (e.g.,
methadone maintenance clinics) and (2) hospital-
based inpatient and outpatient addiction treatment
programs.
† This entailed online reviews and analyses of

publicly available documents related to federal and
state laws and regulations (in all 50 states and the
District of Columbia), including the use of the
Lexis/Nexis database to supplement information
related to state laws and regulations available on the
Internet. Because licensing and certification
requirements are found in a wide variety of laws and
regulations and can change on a state by state basis,
findings from this review cannot be guaranteed to be
complete and current.

assurance requirements seldom stipulate that

patient outcome data be collected, analyzed or

made available to the public. For no other

health condition are such exemptions from

routine governmental oversight considered

acceptable practice.

State Licensing Requirements....................................................................................

Health care facilities such as hospitals and

ambulatory care (outpatient) clinics are licensed

by state departments of health, whereas the

licensing authority for addiction treatment

facilities and programs is distributed across a

variety of governmental agencies and the

content of statutes and regulations varies greatly

by state.^141

Most (81.9 percent) addiction treatment facilities

and programs that voluntarily participate in a

national survey of such providers‡ are licensed

by the state agency responsible for addiction

services (which varies from state to state): 41.4

percent of facilities are licensed by the state

department of health; 35.3 percent by the state

mental health department; and 7.1 percent by the

hospital licensing authority.§ 142

Despite the abundant evidence that addiction

and mental health conditions co-occur at very

high rates and are best addressed in an integrated

manner, in some states, treatment facilities and

programs cannot be dually licensed to provide

both mental health and addiction treatment

services.^143

‡ The National Survey of Substance Abuse Treatment

Services (N-SSATS) of the Substance Abuse and

Mental Health Services Administration (SAMHSA)

is a national survey of public and private addiction

treatment programs and facilities in the United States,

excluding treatment programs in jails and prisons.

Participation is voluntary and the survey does not

represent all treatment providers.

§ These categories are not mutually exclusive. More

than half (57.7 percent) of the addiction treatment

facilities that participate in the survey are not

licensed either by the state department of health or

the hospital agency--the two departments responsible

for licensing health care facilities.