The Honorable Julian Cyr
Chair, Joint Committee on Mental Health, Substance Use and Recovery
State House, Room 312-E
Boston, MA 02133
The Honorable Adrian Madaro
Chair, Joint Committee on Mental Health,
Substance Use and Recovery
State House, Room 33
Boston, MA 02133
Dear Committee Chairs,
The Massachusetts physician community writes to urgently request that the legislature pass House bill 2088 and Senate bill 1272 which would save lives by allowing the establishment of supervised consumption sites (SCS) in the Commonwealth. The
Massachusetts Medical Society (MMS), along with the undersigned physician organizations, representing primary care, specialty, and addiction medicine specialists, collectively writes to convey that SCSs are an evidence-based intervention that fill
a dangerous gap in our state’s capabilities to address the opioid overdose crisis.
Public Health Need, Racial Equity Imperative
The physician community reaffirms the necessity, at present, to expand overdose prevention services in Massachusetts. With more than 2,000 confirmed overdose deaths in 2020, and with an increase in the first three months of 2021 over the same time period
in 2020, there is a strong clinical need for new, evidence-based harm reduction services.
Supervised consumption sites are necessary to address racial inequities in health. Recently released 2020 MA-DPH overdose data shows tragic trends, with the opioid-related overdose death rate for Black men, for example, having increased 69%, from 32.6
to 55.1 per 100,000 people, the highest increase of any ethnic or racial group.
While the past year has elevated many vital public health priorities, the physician community underscores that the opioid overdose crisis remains of paramount importance. There has never been a more critical time for the state to pass legislation expanding
the public health approach to the overdose crisis. Low-barrier treatment and other harm reduction services promoted by the state have been crucial, but the data clearly show that more and novel options are needed to prevent overdose deaths and save
lives.
Strong Evidence Base
In 2017, the Massachusetts Medical Society became the first state medical society in the country to support SCSs after a year-long comprehensive review of the robust international academic literature assessing SCSs. In the years since the seminal MMS
report calling for the establishment of these sites in Massachusetts, the evidence base has deepened and broadened, confirming that SCSs prevent lethal overdoses, reduce associated harms, and create a safe, supportive space for persons who use drugs.
In addition to this primary aim of reducing harms, SCSs connect patients with substance use disorder treatment. The research supporting these assertions is rigorous, stemming from multiple, peer-reviewed studies over many years at several of the more
than 120 SCSs that have been operational globally since the 1990s.
During the expansion of SCSs throughout Canada over the past several years, we have learned that many of the outcomes from well-studied sites, such as Insite in Vancouver, have extended into different geographic locations and through many different site
models, including mobile units and SCSs imbedded in community health centers. This continued positive experience lends yet additional confidence about the role of SCSs in Massachusetts.
Opportunity at Present
The physician community urges prompt passage of SCS-enabling legislation such as House bill 2088 and Senate bill 1272. State legislation would explicitly legalize a pilot program of these sites with annual reporting, amend select antiquated state-controlled
substance laws, and begin the process of clarifying other legal and regulatory barriers such as professional licensure. State legislation is necessary now so that potential sites can turn their legal focus to monitoring the fluid local and federal
issues and can be prepared to open when there is a broader legal path forward. In other words, we strongly encourage the state to pass enabling legislation so that sites can open when they feel confident that other legal issues have been resolved.
State legislation is a logical first step in the sequence of “legalizing” SCSs given the fluid dynamics of federal prosecutorial discretion, which can be offered in a moment’s notice, and given the speed at which local, municipal barriers such as
community buy-in and zoning can move. Accordingly, we urge Massachusetts to join Rhode Island, which recently passed legislation legalizing supervised consumptions sites, in enacting this landmark, proactive public health law.
Sincerely,
Carole E. Allen, MD, MBA, FAAP
The Massachusetts Medical Society
Elisa Choi, MD, FACP, FIDSA
Massachusetts Chapter, American College of Physicians
Dhrumil P. Shah, MD
Indian Medical Association of New England
Julie Johnston, MD
The Massachusetts Academy of Family Physicians
Lloyd Fisher, MD, FAAP
Massachusetts Chapter of the American Academy of Pediatrics
Glenn Markenson, MD
Massachusetts Chapter of the American College of Obstetricians and Gynecologists
Kathleen Kerrigan, MD, FACOG, FACEP
Massachusetts College of Emergency Physicians
Todd Kerensky, MD
Massachusetts Society of Addiction Medicine
Sylvia H. Yoo, MD
Massachusetts Society of Eye Physicians and Surgeons
John Bradley, MD, DFAPA
The Massachusetts Psychiatric Society
View a PDF version of this letter here.
