ADMINISTRATIVE RULES FOR SUBSTANCE

USE DISORDER SERVICE PROGRAMS,

PUBLIC HEARING

August 31, 2022

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ADMINISTRATIVE RULES FOR SUBSTANCE USE DISORDER SERVICE PROGRAMS, PUBLIC HEARING

August 31, 2022

STATE OF MICHIGAN

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

BUREAU OF COMMUNITY AND HEALTH SYSTEMS

RE: ADMINISTRATIVE RULES

FOR SUBSTANCE USE DISORDER

SERVICE PROGRAMS,

RULE SET 2021-90 LR

_____________________________/

PUBLIC HEARING

Lansing, Michigan - Wednesday, August 31, 2022

APPEARANCES:

On Behalf of the

Department of

MS. TAMMY BAGBY

MR. MATT JORDAN

Licensing and

Bureau of Community & Health Systems

P.O. Box 30664

Lansing, Michigan 48909

Regulatory Affairs:

Recorded By:

Karen L. Banks, CER 3592

Certified Electronic Recorder

Network Reporting Corporation

Firm Registration Number 8151

1-800-632-2720

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August 31, 2022

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Lansing, Michigan

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Wednesday, August 31, 2022 - 9:01 a.m.

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MS. BAGBY: Good morning. My name is Tammy Bagby

and I am an analyst in the Bureau of Community and Health

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Systems in the Department of Licensing and Regulatory Affairs.

This hearing regarding the Administrative Rules for

Substance Use Disorder Programs is being called to order at

9:01 on August 31st at the G. Mennen Williams Building

auditorium located at 525 West Ottawa Street in Lansing,

Michigan. The hearing is being conducted under the authority

of the Administrative Procedures Act, P.A. 306 of 1969.

The notice of public hearing was published in three

newspapers of general circulation, as well as the Michigan

Register published on August 15, 2022.

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Regulatory Impact Statement copies are available in

the hall where you came in, for further explanation of these

rule sets. They can also be found on the website for the

Michigan Office of Administrative Hearings and Rules.

Pursuant to section 45 of the Administrative

Procedures Act, the public hearing is an opportunity for the

public to present data, views, questions and arguments

regarding the proposed rules.

The Department will use the testimony and documents

presented at this hearing to determine if any changes should

be made to the proposed rules before they are adopted. If you

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have comments, please make sure they relate directly to the

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proposed rules. If you have questions regarding the rules,

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please submit your questions as part of your testimony for the

Department's review. If you have suggested changes to the

proposed rules, please include the specific reasons why the

changes would be in the public interest.

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If you wish to comment, complete a white card,

available when you came in. This will help the Department

prepare the hearing record. When you testify, please identify

yourself by name and organization, if any, that you may be

speaking for.

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Written statements can be submitted directly to me.

The Department will also accept written statements e-mailed or

postmarked until 5 p.m. on today, August 31st. Additional

information can be found in the notice of the public hearing

that we have made available in the hall.

If you wish to testify and have not completed a

card, you can grab one from the hallway.

The Department staff from the Bureau of Community

and Health Systems include myself; Larry Horvath, Director of

the Bureau of Community and Health Systems; Matt Jordan, Jim

Hoyt, and Kelly Moore from the Non-Long-Term Care State

Licensing Program.

Before we start the public comments, I invite Matt

Jordan to the podium.

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MR. JORDAN: Good morning. Thank you for coming

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today. My name is Matt Jordan. I'm the manager for the

Non-Long-Term Care State Licensing Section, which includes

oversight of the substance use disorder licensed programs.

Today I'm going to touch briefly on the SUD rule

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changes that are going to occur. This is just a broad

overview. It's not exclusive -- or inclusive of every change

in there, but these are the significant points within these

rules. This is the first rule change since the December 2018

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previous administrative rule change for substance use disorder

programs.

To begin, these rules proposed will:

Clarify that licensure is not required inside local,

state or federal facilities such as correctional institutions;

Eliminates licensure for screening, Buprenorphine

and Naltrexone programs by rule change;

Eliminates rule requirements for prevention and for

hospitals that will require legislation to deregulate unlike

the previous-mentioned Buprenorphine and Naltrexone screening;

Will create branch offices for outpatient services,

allowing for a single license to serve a larger market;

Will create mobile services, allowing for a single

license to serve a larger market area;

Requires Naloxone policy and procedure to assure

access;

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Clarifies training requirements for staffing;

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Adds additional licensed professionals that can

provide substance use disorder counseling services, such as

marriage and family therapists;

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Adds an additional certified professional that can

provide substance use disorder counseling services, the

limited certified counselor with a limited recipient ratio;

Creates new service categories for residential

detoxification programs to include clinically managed and

medically monitored withdrawal management service categories;

And finally, aligns screening and take-home

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treatment schedules for Methadone programs with the federal

standards.

MS. BAGBY: Great. We will now begin the public

comment time frame. Do we have any other white cards?

Anybody else that would like to speak before we start? No?

Okay.

The first person that I have is Dave Blankenship.

Please come to the microphone and remember to state your name

and who you are with.

MR. BLANKENSHIP: Good morning. My name is David

Blankenship. I'm representing Michigan Association for

Treatment of Opioid Dependence and Victory Clinical Services.

I'd like by saying I appreciate the rule changes. I

think they're going to help the outpatient Methadone programs

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significantly following the 42 C.F.R. Part A, so I really

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appreciate that.

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There were a couple concerns that I wanted to

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address. The main one is R-325.1381, which talks about the

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limited certified counselor, and the question that I have, the

ratio of 32 consumers, patients that they can counsel, it

takes almost three years to get that, the CADC through MBCAP.

So my question was, is there any chance to modify that to

maybe 50-to-one or potentially look at progressing it from

32-to-one for maybe six months to a year, and then allow 50 to

one patient. That's it. Thank you.

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MS. BAGBY: Thank you, David.

The next card I have is -- Peter, did you want to

speak? How do you pronounce your last name?

MR. BUCCI: "BOO-chee" (ph.).

MS. BAGBY: "BOO-chee."

MR. BUCCI: Like Gucci, but with a "B."

MS. BAGBY: Gotcha. We were going with "Bocci"

earlier.

MR. BUCCI: My name is Peter Bucci. I'm the

executive director of Harbor Hall. It's nice to see

everybody. Thank you for the opportunity.

My only critique or something that I would like to

see within the rule change is some specifics on that limited

certified counselor, what exactly that entails, and then, you

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know, what the credential -- or what the marker would be to

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meet that particular credential. It seems a little broad, a

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little vague.

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And preferably, at least on my end as far as the new

clinicians and new employees coming in, some of their training

seems to be a little lax or a little sped up in their

particular programming, and so if the test itself was that

reliable and valid source to indicate that they have met the

markers necessary to provide these professional services, I

think that would be a very smooth process. Whether it's a

year thing or a C.E. thing, that can all be sort of sped along

a little quicker than it should be, and so at least the test

would be something that they'd actually have to prepare for

and it could be valid. So, thank you.

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MS. BAGBY: Thank you, Peter.

Does anybody else have any public comment at this

time? Okay.

MR. PRICE: Sam Price. I'm the CEO for Ten16

Recovery Network, as well as representing the SUD Contingent

Other Provider Alliance, and we've already submitted our

written comments, but the particular ones we'd want to

emphasize would again be related to some of the open areas

related to the limited certified counselor in terms of

understanding what it takes to get that status. We know part

of that's a coordination with MBCAP, but it gets into

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significant employment issues for us as providers if we don't

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know how we can get compensated for the services that they may

be eligible for until they can secure that distinction.

And as David was talking about in terms of the

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limited caseload, we don't have -- see the same kind of

limitations for somebody with a limited license in social work

or a limited license in professional counseling. So why is

there a specific reduction in caseload being applied to these

individuals who may have a four-year degree -- may not. So we

understand some of those things.

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The other thing that we would particularly want to

highlight would be questions regarding the clinically managed

withdrawal management program, particularly in three areas.

Well, one specific to the clinically one is the statement

about not being able to offer, administer controlled

substances. Really what we're looking for is clarification of

how that would be interpreted and applied. For example, the

CARF policies, ASAM policies in the Michigan Medicaid manual

all allow for some programs to monitor self-administration of

prescriptions that have been prescribed and dispensed to an

individual by a physician. So if a program that is clinically

managed could do monitoring of self-administration, then

there's no concern about the language. But it really is a lot

of interpretation and application and enforcement

The other two, I think, go to all of the withdrawal

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management programs in terms of there is reference about being

seen by a physician upon admission and medications not being

started until seen by a physician at admission, and that, just

for even a medically monitored program, a doctor is not

necessarily on site 24/7 to be able to do those kinds of

things. So to withhold medications until they can see the

physician can be quite problematic and really quite -- create

a risky situation for that particular recipient.

And then one little caveat from some of my friends

in the U.P. specific to the satellite language. When they're

working in frontier counties, they were wondering if a branch

office could be up to a hundred miles, because in some of

those remote communities they have to go even further

distances in order to be available a day or two a week for,

you know, people in those counties.

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So again, it's all captured in our written ones, but

we wanted to bring it to your attention again today. Thank

you.

MS. BAGBY: Thank you, Sam. We did receive your

written comments.

The next person I have is Lucila Ryder.

MS. RYDER: Good morning. My name is Lucila Ryder.

I'm from Star Center, located in Detroit, and I'm also with

the Michigan Association --

(Drops microphone)

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MS. RYDER: For my next act --

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(Laughter)

MS. RYDER: I am also with the Michigan Association

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for the Treatment of Opioid Dependence.

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I also wanted to address what my colleague David

Blankenship referred to earlier in regards to the R-325.3381,

number 6. I'm sure everybody's aware of the shortage that we

have in professional staff and in the field of social work,

and it's very, very difficult for us throughout the state of

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Michigan to find the correct staff that we need to service our

patients that we have. That's why we really would like to

enforce the people that are interested in becoming certified

addiction counselors to increase their load past the thirty

mark. It would provide better training for them, it would

give patients -- more patients access to treatment, and

financially it would make better sense.

If you have someone who is servicing only thirty

patients, that would possibly be just a part-time job for

them, and how do they go where they're having a part-time job?

We could spend more time educating them and helping them to be

better professionals in our field. Again, we are having an

extreme emergency in our field getting licensed Masters of

Social Work, Masters of Social Work, Bachelors of Social Work.

Very, very difficult to find the professionals that we need.

Thank you for all your time and all your efforts.

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MS. BAGBY: Thank you for your comments.

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The next person we have -- and I

apologize -- Kanzoni Asabigi. Is that even close?

MR. ASABIGI: Kanzoni Asabigi.

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MS. BAGBY: Got that.

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MR. ASABIGI: Good morning. My name is Kanzoni

Asabigi from the Detroit Recovery Project in the city of

Detroit, and also representing the Detroit/Wayne County

Association of Substance Addiction Professionals.

I just wanted to make a comment in support of the

revisions proposed, and especially for those individuals that

are receiving MAT treatment, especially Methadone, and also

just making sure that these individuals continue to get the

treatment that they need. So eliminating the rule whereby

people are discharged, it's a good one, because we want to

continue to get people into treatment. You know, they're

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sick, so if they are non-compliant, that's not a reason to get

them out of treatment, you know. So as long as they are

engaged in that, receiving services, I think that's a good

thing to do.

And also, you know, the mobile unit provision

allowing for those that have already been licensed, you know,

to continue to provide the service, I think it's a good one

instead of creating another barrier for them for mobile units

to get a separate number or license, you know, to provide that

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service. One of the things that we providers must do to make

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sure that people are not moving from one provider to another,

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you know, getting double doses or potential overdose, and just

to make sure we work together to make sure that we provide the

services to the individuals that need it. Thank you.

MS. BAGBY: Thank you for your comments.

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Next we have Deidre Goldsmith. Welcome.

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MS. GOLDSMITH: Good morning.

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Hi, I'm Deirdre Goldsmith with Therapeutics. So I'm

referring to the limited counselor. We've tried the

scheduling for the limited counselor, and I wonder first of

all where they got the cap, because I understand that these

are counselors in training, but they need the hours to get

their training, and scheduling them for 32 or 35 clients is

not enough for them to get the training. There are a lot of

gaps in their schedules, and as Ms. Ryder said, it's like a

part-time job. So I'd kind of like to know where they arrived

at these figures, because it's very, very difficult to train

people, pay people, and get the patients seen because they're

not considering the breakage. A lot of people, they'll cancel

appointments, won't show up, and if they're limited in their

caseloads, can we have someone from another caseload to see

them or -- you know, it's limiting us. Thank you.

MS. BAGBY: Thank you.

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Do we have any other people that would like to

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comment?

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MR. RYDER: Hi. I'm Matthew Ryder from Star Center.

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Just one quick comment I have regarding the role with

32-to-one, the development plans. Employers are going to

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choose CADCs. You know, if they have a ton of applications in

front of them and they see CADC or development plan, they're

going to choose a CADC every time, knowing that they can have

65 patients. So that kind of also creates a barrier for those

who have development plans to get the hours needed so that

they become full-fledged CADCs. So I think that's another

reason why they should be allowed more patients so that gives

more development plans more opportunities with every employer.

Thank you.

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MS. BAGBY: Thank you, Matthew.

Do we have any other people that would like to

comment? Okay. Not seeing any, we will take a ten-minute

recess and come back at 9:30.

(Recess from 9:21 a.m. until 9:30 a.m.)

MS. BAGBY: We're officially back on the record now.

It is 9:30.

Last call. Do we have anybody else that would like

to submit comments?

MS. SHOCK: (indiscernible)

REPORTER: You have to come to the microphone.

MS. BAGBY: Okay. Yeah, yeah, just state your name

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and we'll --

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MS. SHOCK: I'm Dayna Shock. I'm from Mid-Michigan

Community Health Services in Houghton Lake. I would like to

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put a little more attention on the satellite locations and

potentially mobile units. Being in Houghton Lake in rural

Michigan, we have a severe lack of insurance rides for

patients. If patients are able to get scheduled, they are

probably 95 percent of the time cancelled because they can't

get a ride. So being able to branch off and have those

satellite locations would provide an extreme opening for

access of care to patients. I know we have patients that

drive like hour-and-a-half, two hours to come and see us.

MS. BAGBY: Okay. Any other public comments?

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Seeing none, I would like to thank everybody for attending

today and for your comments. Everything that we have received

both today, verbally and written, will be reviewed and

evaluated. And with that, I will close at 9:32. We're now

off the record.

(Public hearing concluded at 9:32 a.m.)

-0-0-0-

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3:16 9:14

aware 10:7

caveat 9:9

Center 9:23 13:2

CEO 7:18

correct 10:10

correctional 4:14

counsel 6:6

counseling 5:3,6 8:7

counselor 5:7 6:5,25

7:23 12:10,11

counselors 10:13

12:13

counties 9:11,15

County 11:8

couple 6:3

create 4:20,22 9:7

creates 5:8 13:8

creating 11:24

credential 7:1,2

critique 6:23

double 12:3

drive 14:12

Drops 9:25

A

a.m 2:2 13:18,18

14:19

able 8:15 9:5 14:7,9

accept 3:13

access 4:25 10:15

14:11

act 2:11,20 10:1

addiction 10:13

11:9

additional 3:14 5:2

5:5

address 6:4 10:5

Adds 5:2,5

administer 8:15

administrative 1:4

2:6,11,18,19 4:10

admission 9:2,3

adopted 2:25

Affairs 1:2,14 2:5

aligns 5:11

Alliance 7:20

allow 6:10 8:19

allowed 13:11

allowing 4:21,22

11:22

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CER 1:16

E

B 6:17

certified 1:16 5:5,7

6:5,25 7:23 10:12

chance 6:8

change 4:7,9,10,16

6:24

changes 2:24 3:4,6

4:6 5:24

choose 13:5,7

circulation 2:13

city 11:7

Bachelors 10:23

back 13:17,19

Bagby 1:12 2:3,3

5:14 6:12,16,18

7:15 9:19 11:1,5

12:6,24 13:14,19

13:25 14:13

e-mailed 3:13

earlier 6:19 10:6

educating 10:20

efforts 10:25

Electronic 1:16

eligible 8:3

Eliminates 4:15,17

eliminating 11:14

emergency 10:22

emphasize 7:22

employees 7:5

employer 13:12

Employers 13:4

employment 8:1

enforce 10:12

Banks 1:16

barrier 11:24 13:8

becoming 10:12

Behalf 1:12

better 10:14,16,21

Blankenship 5:18

5:21,22 10:6

Bocci 6:18

BOO-chee 6:15,16

Box 1:14

branch 4:20 9:11

14:9

breakage 12:20

briefly 4:5

clarification 8:16

Clarifies 5:1

Clarify 4:13

D

data 2:21

Dave 5:18

David 5:21 6:12 8:4 enforcement 8:24

10:5

day 9:14

Dayna 14:2

December 4:9

degree 8:9

Deidre 12:7

Deirdre 12:9

Department 1:2,13

2:5,23 3:8,13,19

Department's 3:4

Dependence 5:23

10:4

deregulate 4:18

determine 2:24

detoxification 5:9

Detroit 9:23 11:7,8

Detroit/Wayne 11:8

development 13:4,6

13:9,12

clients 12:14

Clinical 5:23

clinically 5:9 8:12

8:14,21

clinicians 7:5

close 11:3 14:17

colleague 10:5

come 5:19 13:17,24

14:12

coming 4:1 7:5

comment 3:7 5:15

7:16 11:10 13:1,3

13:16

comments 3:1,24

7:21 9:20 11:1

12:6 13:22 14:13

14:15

communities 9:13

Community 1:3,13

2:4 3:19,21 14:3

compensated 8:2

complete 3:7

completed 3:17

concern 8:23

concerns 6:3

concluded 14:19

conducted 2:10

considering 12:20

consumers 6:6

Contingent 7:19

continue 11:13,16

11:23

engaged 11:19

entails 6:25

especially 11:11,12

evaluated 14:17

everybody 6:22

14:14

everybody's 10:7

exactly 6:25

example 8:17

exclusive 4:7

bring 9:17

analyst 2:4

anybody 5:16 7:16

13:21

broad 4:6 7:2

Bucci 6:15,17,20,20

Building 2:8

Buprenorphine

4:15,19

apologize 11:3

APPEARANCES

1:11

application 8:24

applications 13:5

applied 8:8,17

appointments 12:21

appreciate 5:24 6:2

area 4:23

areas 7:22 8:13

arguments 2:21

arrived 12:17

Asabigi 11:3,4,4,6,7

ASAM 8:18

Association 5:22

9:24 10:3 11:9

assure 4:24

executive 6:21

explanation 2:16

extreme 10:22 14:10

Bureau 1:3,13 2:4

3:19,21

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F

C.E 7:11

C.F.R 6:1

CADC 6:7 13:6,7

CADCs 13:5,10

call 13:21

facilities 4:14

family 5:4

far 7:4

federal 4:14 5:12

field 10:8,21,22

figures 12:18

finally 5:11

financially 10:16

find 10:10,24

Firm 1:17

first 4:9 5:18 12:11

following 6:1

found 2:17 3:15

four-year 8:9

frame 5:15

difficult 10:9,24

12:18

called 2:7

cancel 12:20

cancelled 14:8

cap 12:12

captured 9:16

card 3:7,18 6:13

cards 5:15

care 3:22 4:3 14:11

CARF 8:18

caseload 8:5,8 12:22

caseloads 12:22

categories 5:8,10

directly 3:1,12

director 3:20 6:21

discharged 11:15

disorder 1:5 2:7 4:4

4:10 5:3,6

dispensed 8:20

distances 9:14

distinction 8:3

doctor 9:4

attending 14:14

attention 9:17 14:4

auditorium 2:9

August 1:9 2:2,8,14

3:14

controlled 8:15

coordination 7:25

copies 2:15

friends 9:9

front 13:6

documents 2:23

doses 12:3

authority 2:10

available 2:15 3:8

Corporation 1:17

Page 1

ADMINISTRATIVE RULES FOR SUBSTANCE USE DISORDER SERVICE PROGRAMS, PUBLIC HEARING

August 31, 2022

frontier 9:11

full-fledged 13:10

further 2:16 9:13

increase 10:13

indicate 7:8

licensure 4:13,15

limitations 8:6

limited 5:7,7 6:5,24 mobile 4:22 11:21

7:23 8:5,6,7 12:10

12:11,21

limiting 12:23

little 7:2,3,6,6,12 9:9 monitored 5:10 9:4

14:4

load 10:13

local 4:13

Mid-Michigan 14:2 order 2:7 9:14

miles 9:12 organization 3:10

indiscernible 13:23

individual 8:21

individuals 8:9

11:11,13 12:5

information 3:15

inside 4:13

institutions 4:14

insurance 14:6

interest 3:6

interested 10:12

interpretation 8:24 long 11:18

interpreted 8:17

invite 3:24

issues 8:1

Ottawa 2:9

11:24 14:5

modify 6:8

monitor 8:19

outpatient 4:20 5:25

overdose 12:3

oversight 4:4

overview 4:7

G

G 2:8

gaps 12:16

general 2:13

getting 10:22 12:3

give 10:15

monitoring 8:22

months 6:10

Moore 3:22

morning 2:3 4:1

5:21 9:22 11:6

12:8

P

P.A 2:11

p.m 3:14

P.O 1:14

gives 13:11

located 2:9 9:23

locations 14:4,10

go 8:25 9:13 10:19

going 4:5,6 5:25

6:18 13:4,7

Goldsmith 12:7,8,9

good 2:3 4:1 5:21

9:22 11:6,15,19

11:23 12:8

Gotcha 6:18

grab 3:18

Great 5:14

part 3:3 6:1 7:24

part-time 10:18,19

12:17

particular 7:2,7,21

9:8

particularly 8:11,13

patient 6:11

patients 6:6 10:11

10:15,15,18 12:19

13:8,11 14:7,7,11

14:11

look 6:9

moving 12:2

looking 8:16

lot 8:23 12:15,20

LR 1:6

N

Naloxone 4:24

Naltrexone 4:16,19

name 2:3 3:10 4:2

5:19,21 6:14,20

9:22 11:6 13:25

necessarily 9:5

necessary 7:9

J

Lucila 9:21,22

Jim 3:21

job 10:18,19 12:17

Jordan 1:13 3:21,25 main 6:4

4:1,2 making 11:13

M

Gucci 6:17

managed 5:9 8:12

8:22

H

K

need 10:10,24 11:14 pay 12:19

hall 2:16 3:16 6:21

hallway 3:18

Harbor 6:21

Health 1:3,13 2:4

3:20,21 14:3

hearing 1:8 2:6,10

2:12,20,24 3:9,15

14:19

Hearings 2:18

help 3:8 5:25

helping 10:20

Hi 12:9 13:2

highlight 8:12

Horvath 3:20

hospitals 4:18

Houghton 14:3,5

hour-and-a-half

14:12

Kanzoni 11:3,4,6

Karen 1:16

Kelly 3:22

kind 8:5 12:17 13:8

kinds 9:5

know 7:1,24 8:2

9:15 11:16,18,21

11:22,25 12:3,17

12:23 13:5 14:11

knowing 13:7

management 5:10

8:13 9:1

manager 4:2

manual 8:18

mark 10:14

12:5,13

people 9:15 10:12

needed 13:9

Network 1:17 7:19

new 5:8 7:4,5

newspapers 2:13

nice 6:21

non-compliant

11:17

Non-Long-Term

3:22 4:3

11:15,16 12:2,19

12:19,20,25 13:15

percent 14:8

person 5:18 9:21

11:2

Peter 6:13,20 7:15

ph 6:15

physician 8:21 9:2,3

9:7

marker 7:1

markers 7:9

market 4:21,23

marriage 5:4

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MAT 11:12

notice 2:12 3:15

number 1:17 10:7

11:25

plan 13:6

L

Matt 1:13 3:21,24

4:2

plans 13:4,9,12

please 3:1,3,5,9 5:19

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points 4:8

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policy 4:24

possibly 10:18

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potentially 6:9 14:5

preferably 7:4

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prescribed 8:20

prescriptions 8:20

present 2:21

L 1:16

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Matthew 13:2,14

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Medicaid 8:18

medically 5:10 9:4

medications 9:2,6

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met 7:8

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11:12

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14:6

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9:25 13:24

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Lake 14:3,5

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11:25

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office 2:18 9:12

offices 4:20

hours 12:13 13:9

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13:16,25 14:13

ones 7:21 9:16

open 7:22

opening 14:10

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opportunities 13:12

opportunity 2:20

6:22

hundred 9:12

I

identify 3:9

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includes 4:3

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10:22 11:22

Licensing 1:2,13 2:5

3:23 4:3

presented 2:24

prevention 4:17

previous 4:10

Page 2

ADMINISTRATIVE RULES FOR SUBSTANCE USE DISORDER SERVICE PROGRAMS, PUBLIC HEARING

August 31, 2022

previous-mentioned receive 9:19

spend 10:20

staff 3:19 10:8,10

staffing 5:1

standards 5:13

Star 9:23 13:2

start 3:24 5:16

started 9:3

three 2:12 6:7 8:13

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4:19

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14:18

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9:17 14:15,16

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14:10

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Procedures 2:11,20

process 7:10

saying 5:24

scheduled 14:7

schedules 5:12

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screening 4:15,19

5:11

touch 4:5

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state 1:1 3:22 4:3,14 train 12:18

professional 5:5 7:9 Recorder 1:16

5:19 10:9 13:25

statement 2:15 8:14

statements 3:12,13

status 7:24

Street 2:9

submit 3:3 13:22

training 5:1 7:5

8:7 10:8

Recovery 7:19 11:7

10:14 12:13,14,15

treatment 5:12,23

10:4,15 11:12,14

11:16,18

professionals 5:2

10:21,24 11:9

program 3:23 8:13

8:21 9:4

programming 7:7

programs 1:5 2:7

4:4,11,16 5:9,12

5:25 8:19 9:1

reduction 8:8

reference 9:1

referred 10:6

referring 12:10

regarding 2:6,22

3:2 8:12 13:3

regards 10:6

Register 2:14

Registration 1:17

Regulatory 1:2,14

2:5,15

section 2:19 4:3

secure 8:3

tried 12:10

see 6:21,24 8:5 9:6

12:22 13:6 14:12

seeing 13:16 14:14

seen 9:2,3 12:19

self-administration

8:19,22

submitted 3:12 7:20 two 8:25 9:14 14:12

substance 1:5 2:7

U

4:4,10 5:3,6 11:9

substances 8:16

SUD 4:5 7:19

suggested 3:4

support 11:10

sure 3:1 10:7 11:13

12:2,4,4

U.P 9:10

understand 8:10

12:12

understanding 7:24

unit 11:21

units 11:24 14:5

use 1:5 2:7,23 4:4,10

5:3,6

progressing 6:9

Project 11:7

sense 10:16

pronounce 6:14

proposed 2:22,25

3:2,5 4:12 11:11

provide 5:3,6 7:9

10:14 11:23,25

12:4 14:10

provider 7:20 12:2

providers 8:1 12:1

provision 11:21

public 1:8 2:12,20

2:21 3:6,15,24

5:14 7:16 14:13

14:19

separate 11:25

serve 4:21,23

service 1:5 5:8,10

10:10 11:23 12:1

services 4:20,22 5:3

5:6,23 7:9 8:2

11:19 12:5 14:3

servicing 10:17

SET 1:6

relate 3:1

related 7:22,23

reliable 7:8

Systems 1:3,13 2:5

3:20,21

remember 5:19

remote 9:13

REPORTER 13:24

Reporting 1:17

representing 5:22

7:19 11:8

require 4:18

required 4:13

requirements 4:17

5:1

V

vague 7:3

valid 7:8,14

verbally 14:16

Victory 5:23

views 2:21

T

take 13:16

take-home 5:11

takes 6:7 7:24

talking 8:4

sets 2:17

severe 14:6

talks 6:4

Shock 13:23 14:2,2

shortage 10:7

show 12:21

Tammy 1:12 2:3

ten-minute 13:16

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terms 7:23 8:4 9:1

test 7:7,12

W

want 6:13 7:21 8:11

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wanted 6:3 9:17

10:5 11:10

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we're 8:16 13:19

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website 2:17

Wednesday 1:9 2:2

week 9:14

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West 2:9

white 3:7 5:15

Williams 2:8

wish 3:7,17

withdrawal 5:10

8:13,25

published 2:12,14

Pursuant 2:19

put 14:4

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residential 5:8

review 3:4

sick 11:17

significant 4:8 8:1

significantly 6:1

single 4:21,22

site 9:5

situation 9:8

six 6:10

smooth 7:10

social 8:6 10:8,23,23

10:23

somebody 8:6

sort 7:11

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question 6:5,8

questions 2:21 3:2,3

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testimony 2:23 3:3

thank 4:1 6:11,12

6:22 7:14,15 9:17

9:19 10:25 11:1

12:5,6,23,24

13:13,14 14:14

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therapists 5:4

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thing 7:11,11 8:11

11:20

things 8:10 9:6 12:1

think 5:25 7:10 8:25

11:19,23 13:10

thirty 10:13,17

rides 14:6

quick 13:3

risky 9:8

quicker 7:12

quite 9:7,7

role 13:3

rule 1:6 2:17 4:5,9

4:10,16,17 5:24

6:24 11:14

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R-325.1381 6:4

R-325.3381 10:6

ratio 5:7 6:6

rules 1:4 2:6,18,22

2:25 3:2,2,5 4:9

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speak 5:16 6:14

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9:10

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really 6:1 8:16,23

9:7 10:11

reason 11:17 13:11

reasons 3:5

rural 14:5

Ryder 9:21,22,22

10:1,3 12:16 13:2

13:2

withhold 9:6

Page 3

ADMINISTRATIVE RULES FOR SUBSTANCE USE DISORDER SERVICE PROGRAMS, PUBLIC HEARING

August 31, 2022

wonder 12:11

6

wondering 9:11

work 8:6 10:8,23,23

10:23 12:4

6 10:7

65 13:8

working 9:11

written 3:12,13 7:21

9:16,20 14:16

7

8

8151 1:17

X

9

Y

yeah 13:25,25

year 6:10 7:11

years 6:7

9:01 2:2,8

9:21 13:18

9:30 13:17,18,20

9:32 14:17,19

95 14:8

Z

0

0-0-0- 14:20

1

1-800-632-2720

1:18

15 2:14

1969 2:11

2

2018 4:9

2021-90 1:6

2022 1:9 2:2,14

24/7 9:5

3

306 2:11

30664 1:14

31 1:9 2:2

31st 2:8 3:14

32 6:6 12:14

32-to-one 6:10 13:4

35 12:14

3592 1:16

4

42 6:1

45 2:19

48909 1:14

5

5 3:14

50 6:10

50-to-one 6:9

525 2:9

Page 4