AOAT, AATOD and NABH Send Letter to Senate Opposing MOTAA

August 4, 2026  

Dear Members of Congress,

As representatives of addiction treatment providers, we are writing to express our strong opposition to the Modernizing Opioid Treatment Access Act (MOTAA) 2.0 of 2026, H.R. 9790. Our organizations are committed to expanding access to safe, evidence-based treatment for individuals living with opioid use disorder (OUD) and understand the profound importance of ensuring that everyone who needs treatment can access it. While we share the goal of improving treatment access, this legislation will significantly undermine important patient and public safety protections without meaningfully improving access to care.

Our organizations are committed to expanding access to safe, evidence-based treatment for individuals living with opioid use disorder (OUD) and understand the profound importance of ensuring that everyone who needs treatment can access it. While we share the goal of improving treatment access, MOTAA will significantly undermine important patient and public safety protections without meaningfully improving access to care.

Methadone Requires Careful Clinical Oversight

Methadone is a powerful Schedule II narcotic with a complex safety profile that requires careful clinical management. The Centers for Disease Control and Prevention (CDC) warns of methadone’s dangers: “The difference between appropriate prescribed doses and dangerous doses of methadone is small.”¹ One CDC study of opioid-related deaths warns, “Health-care providers who choose to prescribe methadone should have substantial experience with its use…”2 The Substance Abuse and Mental Health Services Administration (SAMHSA) further warns, “Even after the effects of methadone wear off, the medication’s active ingredients remain in the body for much longer. Unintentional overdose is possible if patients do not take methadone as prescribed.”³

For more than five decades, federally certified Opioid Treatment Programs (OTPs) have provided methadone through a comprehensive model of care that includes a medical evaluation, carefully individualized dose induction and titration, ongoing patient monitoring, important diversion controls, critical counseling and therapy, and recovery support services. This system was developed in recognition of the potential for fatal overdose associated with methadone, as our country witnessed during the 2000s when overdoses began to skyrocket at the start of the opioid epidemic.

MOTAA would allow methadone to be prescribed by private practice physicians and dispensed through pharmacies for unsupervised use. In doing so, it would substantially alter the existing treatment framework by separating the medication from the comprehensive clinical oversight that has long ensured its safe use. We are also particularly concerned that MOTAA would allow the Secretary of the Department of Health & Human Services (HHS) to expand methadone prescribing privileges to any prescriber, including nurse practitioners, physician assistants and physicians without addiction treatment training. Eliminating longstanding patient and public safety protections increases the risk of diversion, misuse, and inappropriate prescribing while undermining the proven safety measures and comprehensive treatment model that has ensured effective medication-assisted treatment (MAT) with methadone for decades. Moreover, we are concerned about the potential for an increase in “pill mills” like those that have fueled the opioid crisis.

Past Experience Raises Important Concerns

Our concerns are informed by experience. Five federal government reports found that physician prescribing of methadone in the early-to-mid 2000s contributed to dramatic increases in death, overdose, and diversion across the U.S.^4-8 The United Kingdom, Canada, Sweden, and Denmark tried relaxing methadone safeguards by allowing for unsupervised pharmacy pick-up and saw higher methadone-related overdose deaths, increased diversion, and lower patient treatment retention. When countries reinstated supervised dosing, like we currently have in the U.S., they saw substantial declines in methadone-related overdose deaths.^10-14 These experiences demonstrate the importance of maintaining appropriate clinical oversight for a medication with a high-risk profile and should give policymakers pause before fundamentally changing the framework that has governed methadone dispensing for decades.

Notably, the American Society of Addiction Medicine’s own clinical practice guidelines states, “The administration of methadone should be monitored because unsupervised administration can lead to misuse and diversion. OTP regulations require monitored medication.”⁹ When health care professionals who prescribe a different medication to help treat OUD were asked if they support office-based methadone prescribing with pharmacy pickup, 78% were opposed.¹⁵

Major Law Enforcement Groups Have Opposed MOTAA

Several national law enforcement organizations have expressed strong concerns with MOTAA. These groups warned MOTAA:

• “could impact progress that has been made to support communities across the nation;”
• ”could contribute to a rise in crimes associated with the illegal trade of methadone;”
• “enabling access to methadone without proper support and supervision would exacerbate current challenges to maintaining safe access to and administration of MAT;” and
• “could lead to unintended consequences for an individual’s recovery plan, risk abuse and relapse, and potentially lead to improper treatment.”²³

MOTAA will not meaningfully expand access to MAT.

The vast majority Americans (87%) already live within 40 minutes/30 miles of an OTP, which is the definition of “reasonable access” codified in the Affordable Care Act. Not surprisingly, the prescribers included in MOTAA overwhelmingly practice in these same communities.¹⁶

Additionally, MOTAA would not increase access for Medicaid beneficiaries because, unlike OTPs, most office-based addiction specialists do not accept Medicaid. While 74% of low-income non-elderly OUD patients are uninsured or have Medicaid coverage,¹⁷ only 38% of office-based addiction providers accept Medicaid patients.¹⁸ As the 2024 HHS’ Office of Inspector General’s report stated, “If providers are unable or unwilling to treat Medicare and Medicaid enrollees, these actions [policy changes] will have limited success in expanding access to treatment.”¹⁹ It’s also important to note that wait times to commence treatment at an OTP are almost non-existent.

SAMHSA’s recent reforms are already safely expanding access and improving treatment outcomes and overdose death rates.

Congress does not need to choose between expanding access and protecting patient safety when both are already occurring. Significant progress is already being made through reforms that allow OTPs more flexibility to deliver individualized treatment. SAMHSA recently expanded take-home medication privileges so that patients do not need to visit the clinic every day, authorized telehealth initiation of treatment which helps patients in underserved communities access care and permitted mobile medication units to treat patients where they work and live. As SAMHSA recently reported, OTPs have embraced these changes with 98% of OTPs having implemented at least one of the new regulatory flexibilities. ²⁰ Importantly, OTPs are often hindered by more stringent state guidelines. Only 37% of states report having adopted all the SAMHSA flexibilities. ²¹ These reforms are changing the patient experience. Data aggregated from four OTP networks representing 382 treatment centers demonstrate how care is becoming more individualized and accessible due to the SAMHSA regulatory flexibilities: 50% of patients come into the clinic for medication just once a week or less; 78% receive at least 3 take-homes a week; 29% of patients are initiated through telehealth.  At the same time, emerging evidence indicates counseling services and retention have increased while drug use has decreased.

These findings demonstrate that the OTP system is already providing substantially greater flexibility and convenience for patients while preserving the clinical oversight that makes methadone treatment safe and effective and has contributed to the 39% decline in overdose deaths in the last three years.²²

Reconsider MOTAA. It’s not worth the risk to patient and public safety.

We would be honored to work with you to continue building on these evidence-based reforms rather than replacing them with a dangerous, failed framework that weakens longstanding safeguards. Policies that strengthen the addiction treatment workforce, improve reimbursement, expand treatment capacity, and increase access in rural and underserved communities will do far more to improve patient outcomes than legislation that separates methadone from the comprehensive treatment model that has guided its safe use for decades.

We hope you will join providers, patients, law enforcement, and other stakeholders to advance policies that safely expand access to evidence-based treatment while preserving the patient protections and clinical oversight that are fundamental to effective MAT with methadone. We welcome the opportunity to work with you to identify safe, bipartisan solutions that improve access to care while protecting patients, families, and communities rather than repeat the mistakes of the past.

Thank you for your consideration and for your continued commitment to improving treatment for individuals living with opioid use disorder.

Sincerely,

American Association for the Treatment of Opioid Dependence

Advocates for Opioid Addiction Treatment

National Association for Behavioral Healthcare