Massachusetts Medical Society: Testimony in Support of The Findings of The Massachusetts Harm Reduction Commission

Testimony in Support of The Findings of The Massachusetts Harm Reduction Commission

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),

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