The Massachusetts Medical Society (MMS)
wishes to be recorded in strong support of the key findings and recommendations
released March 1, 2019 by the Massachusetts Harm Reduction Commission
(Commission), established by Section 100 of Chapter 208 of the Acts of 2018. MMS was involved in this report through the important
contributions of Dr. Jessie Gaeta, Chief Medical Officer of the Boston Health
Care for the Homeless Program, who was appointed to the Commission to represent
the Medical Society. The Commission was
charged with reviewing the evidence base and experiences of other
states/countries that have established harm reduction strategies and making
recommendations regarding harm reduction opportunities to address substance use
disorder in the Commonwealth. Among
other important findings, the Commission recommended that, to continue fighting
the opioid crisis and to effectively foster a culture of harm reduction
throughout the state, Massachusetts should adopt a pilot program of one or more
supervised consumption sites (SCSs).
The Medical Society has been active in supporting
harm reduction efforts in the Commonwealth.
As the Commission notes, existing harm reduction efforts in the state are
primarily focused on increasing access to naloxone and the expansion of needle
exchange programs, implementing promising practice pilots, and public awareness
campaigns. MMS policy supports increasing public access to
needle exchange programs, as well as increasing affordable access to naloxone, as these are proven, effective harm
reduction strategies. We believe that
real public health promise lies when these harm reduction initiatives are
matched with continued expansion of access to low-barrier medication treatment
for substance use disorder, a second key priority of the Medical Society’s
approach to the current fentanyl-driven opioid crisis.
The
Medical Society takes great pride in a 2017 report produced by its own Task Force on Opioid
Therapy and Physician Communication (Task Force), which recommends support for
a pilot supervised injection facility (SIF) program. SIFs are designed to: reduce drug-related
risks including the transmission of human immunodeficiency virus (HIV), hepatitis
B and C (HCV) and other blood-borne infections; decrease the number of
overdoses; minimize public order problems (including public drug use); and
improve access to health and social services, including drug treatment and
recovery services. After extensive
research and review of data, ethical analysis, legal analysis, and professional
liability analysis, the Task Force determined that SIFs constitute legitimate
medical interventions that offer a unique opportunity to target and engage some
of the most at-risk and socially marginalized individuals. A review and analysis of published literature
on SIFs show that they reduce harms associated with drug use by: reducing
overdose deaths; providing an alternative to unsafe injection practices that
lead to HIV, HCV, and other diseases; and facilitating entry into drug
treatment. Studies suggest that SIFs are
cost effective and the impact on the communities in the areas around the SIFs
has been positive. The MMS Task Force
voted unanimously on a set of recommendations which advocate for the
establishment of a pilot SIF program in Massachusetts.[1]
The Task Force’s findings are
consistent with those of the Commission.
Both reports address the peer-reviewed publications detailing decreased
overdose rates and related clinical and public health successes of SIFs. Each report also details the legal barriers to
establishing a SIF in Massachusetts, from federal, to state, to local laws,
regulations and ordinances. The Medical
Society commends the Commission for inclusion of recent legal scholarship and
analysis that has continued to identify potential paths forward for federal
legality, and for reference to the pending legal case in Philadelphia, which
may soon shed light on the merits of some of these legal considerations. For these reasons, it is prudent to push
forward a plan to remove state legal and regulatory barriers that present
challenges to a pilot SIF program while the federal legal concerns continue to
be addressed.
The Medical Society was pleased to see the
legislature allocate $5M in the FY 20 budget to DPH to coordinate a
comprehensive statewide strategy to promote existing commonwealth harm
reduction efforts, to foster a culture of harm reduction, and to promote
community-based harm reduction services as recommended by the Commission. This funding will bolster existing harm
reduction programs to increase the availability of sterile and safe injection
equipment and syringe disposal services and also increase access to naloxone
rescue kits. Funding was also earmarked
to increase access to fentanyl testing strips or other drug checking
equipment. This is critical, as the
Commission noted that fentanyl is present in 89% of opioid-related deaths and
recommended expansion of fentanyl testing as promising intervention
that can reduce the risk of overdose and transmission of blood-borne diseases
among people who use drugs. Notably, the
budget line-item directed that money shall be expended to promote pilot
programming to advance the creation of new supportive places for treatment and
related observation that offer medical monitoring, nasal naloxone rescue kit
distribution, counseling and connection to primary care, behavioral health, and
addiction treatment services.
Massachusetts is among the top ten states with the
highest rates of opioid-related overdose deaths. Significant investments in Massachusetts
have made positives strides in combatting the opioid crisis; while
Massachusetts reported an overall 4% decline in opioid-related overdose deaths
from 2016 to 2018, certain trends remain alarming. Geographic disparities exist, with
communities including Framingham, Lawrence, Lowell and Springfield seeing a
significant increase in overdose deaths.
While the vast majority of fatal overdoses are male, deaths among women
of all races increased from 2017 to 2018.
In the Spring of 2018, the Department of Public Health (DPH) released a
report finding that that more than a third (38.3%) of pregnancy-associated deaths
among women between 2011 and 2015 were fatal opioid-related overdoses. This data underscores the need for further
investment and expansion of comprehensive, coordinated harm reduction efforts
in Massachusetts.
The current opioid epidemic represents the greatest
public health crisis our state and the nation has faced in recent memory and it
will take a variety of aggressive efforts to change its course and sustain progress. The Baker Administration has rightfully
focused on using data to drive decision-making around programs and policies
that are proven effective. The analysis
and findings of both the Commission and the Medical’s Society’s report
demonstrate that SCSs/SIFs are an important, evidence-based tool that should be
incorporated into Commonwealth’s comprehensive approach.
[1]
Establishment of a Pilot Medically Supervised Injection Facility in
Massachusetts, Massachusetts Medical Society Task Force on Opioid Therapy
and Physician Communication (April 2017), http://www.massmed.org/Advocacy/State-Advocacy/SIF-Report-2017/.
