Status Report on Protecting Our Infants Act Implementation Plan

The Protecting Our Infants Act of 2015 (POIA) became law on November 25, 2015. The Act (Public Law 114-91) addressed problems related to prenatal opioid exposure called for HHS to review planning and coordination of HHS activities related to prenatal opioid exposure and neonatal abstinence syndrome (NAS), and to study and develop recommendations for the prevention, identification, and treatment of NAS as well as the treatment of opioid use disorder (OUD) in pregnant women. In May of 2017 HHS released a POIA strategy to address gaps in research, overlap of federal programs and coordination of federal efforts to address NAS and NOWS. Section 7062 of the SUPPORT for Patients and Communities Act (P.L. 115-271, enacted October 24, 2018) requires a report about the implementation of the recommendations in the POIA strategy, to be submitted to specified congressional committees and made available to the public on the Department's website. HHS developed an implementation plan focusing on preventing prenatal opioid exposure, providing evidence-based treatment for both mother and infant, increasing the accessibility of family-friendly services for pregnant and parenting women with OUD, supporting continuing education for healthcare providers, and determining optimal family and developmental support services for children who have experienced prenatal opioid exposure. [101 PDF pages]

For additional information about this subject, you can visit the HHS/ASPE/Office of Disability, Aging and Long-Term Care Policy home page at http://aspe.hhs.gov/office-disability-aging-and-long-term-care-policy-daltcp or contact the ASPE Project Officer, Kristina West, at HHS/ASPE/DALTCP, Room 424E, H.H. Humphrey Building, 200 Independence Avenue, S.W., Washington, D.C. 20201, Kristina.West@hhs.gov.

ABBREVIATIONS

AAP American Academy of Pediatrics
ACF Administration for Children and Families
ACT NOW Advancing Clinical Trials for Neonatal Opioid Withdrawal
ACYF Administration on Children, Youth and Families
ACOG American College of Obstetrics and Gynecology
AFCARS Adoption and Foster Care Analysis and Reporting System
AHRQ Agency for Healthcare Research and Quality
AIM Alliance for Innovation on Maternal Health
AIMS Access Increases in Mental Health and Substance Abuse Services
AI/AN American Indian/Alaskan Native
ASHTO Association of State and Territorial Health Officials
ASPE Office of the Assistant Secretary for Planning and Evaluation
BHCC Behavioral Health Coordinating Council
BRFSS Behavioral Risk Factor Surveillance System
CAHPG Children and Adults Health Programs Group
CARA Comprehensive Addiction and Recovery Act of 2016
CAPTA Child Abuse Prevention and Treatment Act
CDC Centers for Disease Control and Prevention
CEU Continuing Education Units
CME Continuing Medical Education
CMCS Center for Medicaid and CHIP Services
CMMI Center for Medicare and Medicaid Innovation
CMS Centers for Medicare & Medicaid Services
CONACH Committee on Native American Child Health
CSAT Center for Substance Abuse Treatment
CSTE Council of State and Territorial Epidemiologists
DAST Drug Abuse Screening Test
DBP Developmental-Behavioral Pediatrics
DEHPG Disabled and Elderly Health Programs Group
ECHO Extension for Community Care Outcomes
EPSDT Early and Periodic Screening, Diagnostic and Treatment
ESC Eat, Sleep, Console
FASD Fetal Alcohol Spectrum Disorders
FOA Funding Opportunity Announcement
GAO Government Accountability Office
GPRA Government Performance and Results Act
HCUP Healthcare Cost and Utilization Project
HEDIS Healthcare Effectiveness Data and Information Set
HHS Health and Human Services
HIV/AIDS Human Immunodeficiency Virus/Acquired Immunodeficiency Syndrome
HOPE Heroin, Opioids, and Pain Efforts
HRSA Health Resources and Services Administration
IAA Institutional Review Board Authorization Agreements
IAP MedicaidInnovation Accelerator Program
ICD International Statistical Classification of Diseases
IDeA Institutional Development Awards
IMD Institutions for Mental Diseases
IHS Indian Health Services
ISPCTN IDeA States Pediatric Clinical Trials Network
IUD Intrauterine Device
LARCs Long-acting reversible contraceptives
LAUNCH Linking Actions for Unmet Needs in Children's Health
MAT Medication-Assisted Treatment
MAT-PDOA Medication-Assisted Treatment--Prescription Drug and Opioid Addiction
MCH Maternal and Child Health
MCHB Maternal and Child Health Bureau
MIECHV Maternal, Infant, and Early Childhood Home Visiting
MMRC Maternal Mortality Review Committees
MOU Memorandum of Understanding
NAS Neonatal Abstinence Syndrome
NCANDS National Child Abuse and Neglect Data System
NCSACW National Center on Substance Abuse and Child Welfare
NICHD The Eunice Kennedy Shriver National Institute of Child Health and Human Development
NICU Neonatal Intensive Care Unit
NIDA National Institute on Drug Abuse
NOWS Neonatal Opioid Withdrawal Syndrome
NRN Neonatal Research Network
NSDUH National Survey on Drug Use and Health
OASH Office of the Assistant Secretary for Health
OAT Opioid Addiction Treatment
OCA Office of Community Awareness
OCAN Office on Child Abuse and Neglect
OMB Office of Management and Budget
OTC Over-The-Counter
OUD Opioid Use Disorder
OWH Office on Women's Health
OWHPA Office on Women's Health Prevention Award
PCSS-O Providers' Clinical Support System--Opioid Therapies
PICs Practice and Implementation Centers
POIA Protecting Our Infants Act
PPW Pregnant and Postpartum Women
PQC Perinatal Quality Collaboratives
PRAMS Pregnancy Risk Assessment Monitoring System
RCT Randomized Controlled Trial
RFA Request For Application
RHOP Rural Health Opioid Program
SAMHSA Substance Abuse and Mental Health Services Administration
SABG Substance Abuse Prevention and Treatment Block Grant
SBIRT Screening, Brief Intervention, and Referral to Treatment
SEI IDTA Substance Exposed Infant In-Depth Technical Assistance Program
SGM Special General Memorandums
SNOMED Systematized Nomenclature of Medicine
SUD Substance Use Disorder
TA Technical Assistance
UDS Uniform Data System

BACKGROUND

A new study revealed that from 2004 to 2014, the rate of US infants diagnosed with opioid withdrawal symptoms increased 433%, from 1.5 to 8.0 per 1000 hospital births. This translates to one infant being born every 15 minutes with withdrawal symptoms due to prenatal opioid exposure. [1], [2]

The Protecting Our Infants Act of 2015 (POIA) became law on November 25, 2015. The Act (Public Law 114-91) addressed problems related to prenatal opioid exposure and included several mandates for the U.S. Department of Health and Human Services (HHS). The law called for HHS to review planning and coordination of HHS activities related to prenatal opioid exposure and neonatal abstinence syndrome (NAS), which includes neonatal opioid withdrawal syndrome (NOWS), and to study and develop recommendations for the prevention, identification, and treatment of NAS as well as the treatment of opioid use disorder (OUD) in pregnant women. In May of 2017 HHS released a POIA strategy to address gaps in research, overlap of federal programs and coordination of federal efforts to address NAS and NOWS.

In addition, the Comprehensive Addiction and Recovery Act of 2016 (CARA) included a provision for the Government Accountability Office (GAO) to examine NAS in the United States and related treatment services for the condition. The GAO study was published in October, 2017 and found limited physical capacity to care for infants with NAS; limited coordination of care for mothers and infants with NAS; and gaps in research and data on NAS.

Finally, Section 7062 of the SUPPORT for Patients and Communities Act (P.L. 115-271, enacted October 24, 2018) requires a report about the implementation of the recommendations in the POIA strategy, to be submitted to specified congressional committees and made available to the public on the Department's website within 60 days of enactment.

In response to POIA, the GAO study, and the SUPPORT for Patients and Communities Act, HHS developed an implementation plan to inform planning and policy across the Department. Recommendations range from aspirational to practical and include preventing prenatal opioid exposure, providing evidence-based treatment for both mother and infant, increasing the accessibility of family-friendly services for pregnant and parenting women with OUD, supporting continuing education for healthcare providers, and determining optimal family and developmental support services for children who have experienced prenatal opioid exposure.

IMPLEMENTATION PLAN PURPOSE AND DEVELOPMENT PROCESS

In recognition of the need for an organizing framework to guide and track implementation of recommendations in the POIA Strategy, the HHS Behavioral Health Coordinating Council (BHCC) Opioid and Controlled Substances Subcommittee, NAS Workgroup developed this implementation work plan. This plan provides an update on the POIA implementation plan activities that are completed, in process, and planned by HHS agencies, targeting activities for research and evaluation, programs and services, data and surveillance, and education.

The development of the plan represents an iterative process with the first draft completed on March 30, 2018 and the final plan to be completed by September 1, 2018. HHS agencies updated their NAS-related activities in March, April, and August 2018.

IMPLEMENTATION PLAN PROGRESS

All POIA recommendations are being addressed by HHS, with the majority of recommendations being addressed through dedicated cross-agency collaboration. Of the 39 recommendations, the Administration for Children and Families (ACF) is addressing 15, the Agency for Healthcare Research and Quality (AHRQ) is addressing two, the Centers for Disease Control and Prevention (CDC) is addressing 26, the Centers for Medicare & Medicaid Services (CMS) is addressing 21, the Food and Drug Administration is addressing seven, the Health Resources and Services Administration (HRSA) is addressing 29, Indian Health Services (IHS) is addressing 29, the Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD) is addressing 14, the National Institute on Drug Abuse (NIDA) is addressing 18, HHS's Office of the Assistant Secretary for Health (OASH) is addressing 14, and the Substance Abuse and Mental Health Services Administration (SAMHSA) is addressing 25.

All agency activities are listed in the tables below. Updates are listed by recommendations, which in turn are organized into functional categories (Systemic, Clinical, Data and Surveillance, and Research and Evaluation).

Examples of Cross-Agency Collaboration

As highlighted above, the majority of recommendations are addressed through cross-agency collaboration with dedicated cross-agency activities for 36 of the 39 recommendations. For instance, ACF and SAMHSA jointly fund the National Center on Substance Abuse and Child Welfare (NCSACW) -- a technical assistance and training resource -- to improve family recovery, safety, and stability by advancing practices and collaboration among agencies, organizations, and courts working with families affected by substance use and co-occurring mental disorders and child abuse or neglect. ACF/Administration on Children, Youth and Families (ACYF) and SAMHSA also conducted a Policy Academy entitled "Improving Outcomes for Pregnant and Postpartum Women with Opioid Use Disorders, and their Infants and Families" on February 7-8, 2017, in Baltimore, MD to develop action plans on the complex needs of pregnant and parenting women. CMS and HRSA jointly issued guidance regarding Coverage of Maternal, Infant, and Early Childhood Home Visiting Services. NICHD (Office of the Director, Institutional Development Awards [IDeA] States Pediatric Clinical Trial Network) and NIDA partner on multiple research projects, including the "ACT NOW: Advancing Clinical Trials in NOWs" Initiative to evaluate treatment options and improve clinical care of infants with NAS. SAMHSA leads several joint efforts, including a work group entitled "Children and Families Impacted by the Opioid Crisis," a cross-agency collaboration with the Maternal and Child Health Bureau/HRSA, OASH/OWH, NIDA, and ACF in collaboration with CDC. OASH/OWH and IHS partnered to address opioid misuse among women of reproductive age in the American Indian/Alaskan Native (AI/AN) communities. OASH/OWH is also partnering with the HRSA Office of Women's Health on an initiative to produce a care coordination model for women impacted by opioids who receive healthcare services via HRSA-administered programs.

SUSTAINING HHS POIA IMPLEMENTATION PLAN EFFORTS

After the final implementation plan is approved, the BHCC Opioid and Controlled Substances Subcommittee will assume responsibility for the ongoing implementation and coordination of NAS and prenatal opioid exposure related activities to assess progress, evaluate effectiveness, and publicize NAS-specific programs and tools, contingent on funding.

IMPLEMENTATION STATUS OVERVIEW

The table below provides an overview of the recommendations by category, federal actions to address the recommendations, and funding and status for each action. The details of the implementation status for each recommendation is detailed in the following pages.

Recommendation Category Number of Recommendations Number of actions Funding
(Number of Actions | Percent of Actions)
Status
(Number of Actions | Percent of Actions)
39 423 Funded Proposed/Contingent on Funding Completed Ongoing
Systemic Changes 16 198 164 82.82% 34 17.17% 8 4.04% 190 95.95%
Clinical Changes 7 90 79 87.77% 11 12.22% 9 10% 81 90%
Data and Surveillance Changes 5 55 36 65.45% 19 34.55% 0 0% 55 100%
Research and Evaluation Changes 11 80 57 71.25% 23 28.75% 9 11.25% 71 88.75%

IMPLEMENTATION STATUS BY RECOMMENDATION

Recommendations Addressing Systemic Changes

Recommendations addressed by the following agencies:

1. Increase access to the broad range of contraceptive options for women at risk of experiencing a substance-exposed pregnancy, including barrier free access to long-acting reversible contraception. (Programs & Services, Maternal)

  1. CDC, CMS, HRSA, IHS

2. Provide ready access to effective SUD treatment, including tobacco cessation counseling/treatment, prior to conception and during pregnancy. (Programs & Services, Maternal)

  1. CMS, FDA, HRSA, IHS, NIDA, OASH/OWH, SAMHSA

3. Make available family-friendly relapse prevention and recovery support for parents in recovery. (Programs & Services, Maternal)

  1. ACF/Children's Bureau, CMS, HRSA, IHS

4. Provide ready access to family-friendly SUD treatment for parents. (Programs & Services, Maternal)

  1. ACF/Children's Bureau, CMS, HRSA, IHS, SAMHSA

5. Provide ready access to parental support and early intervention services. (Programs & Services, Child)

  1. ACF/Children's Bureau, CDC, CMS, HRSA, IHS, SAMHSA

6. Provide access to effective and alternative treatment options for pain prior to conception and during pregnancy and breastfeeding (Programs & Services, Maternal)

  1. CDC, CMS, HRSA, IHS, NIDA

7. Promote general public awareness of the effectiveness of SUD treatment, to reduce barriers to seeking treatment prior to conception and in early pregnancy. (Education, Maternal)

  1. ACF/Children's Bureau, CDC, CMS, FDA, HRSA, IHS, SAMHSA, OASH/OWH

8. Promote shift in public perceptions of SUD so that it is regarded as a disease rather than as a criminal or moral problem to reduce barriers to seeking treatment prior to conception and in early pregnancy. (Education, Maternal)

  1. ACF/Children's Bureau, CMS, HRSA, IHS, NIDA, OASH/OWH, SAMHSA

9. Develop effective strategies to support informed decision making around pain management or SUD treatment when these conditions are identified prenatally. (Programs & Services, Maternal)

  1. CDC, FDA, HRSA, IHS, OASH/OWH, SAMHSA

10. Promote non-pharmacologic interventions, such as rooming in, for managing mild to moderate NAS/NOWS. (Programs & Services, Child)

  1. ACF/Children's Bureau, CDC, CMS, HRSA, IHS, NICHD, NIDA, SAMHSA

11. Promote breastfeeding for women who receive opioids for pain or the treatment of OUD when not otherwise contraindicated and consistent with appropriate guidelines. (Education, Maternal)

  1. ACF/Children's Bureau, CDC, CMS, HRSA, IHS, OASH/OWH, SAMHSA

12. Promote breastfeeding of infants of women who receive opioids for pain or OUD when not otherwise contraindicated and consistent with appropriate guidelines. (Education, Maternal)

  1. CDC, CMS, HRSA, IHS, NICHD, OASH/OWH, SAMHSA

13. Provide continuing medical education to the provider for managing pain in the pregnant woman with OUD. (Education, Maternal)

  1. CDC, CMS, HRSA, IHS, SAMHSA

14. Provide continuing medical education to the provider for managing the infant with NAS symptoms. (Education, Maternal)

  1. CDC, HRSA, IHS, OASH/OWH

15. Identify a history of prenatal substance exposure and NAS/NOWS when children receive developmental assessment, early intervention services or enter child welfare. (Data & Surveillance, Child)

  1. ACF/Children's Bureau, CDC, CMS, HRSA, IHS

16. Promote public and health professional awareness of ongoing parental treatment engagement, recovery support, and early-intervention services in family function and mitigation of consequences of prenatal substance exposure and NAS/NOWS. (Education, Maternal)

  1. ACF/Children's Bureau, CMS, FDA, HRSA, IHS, SAMHSA

Examples of agency activities to address recommendations:

*The hyperlinks allow readers to move to the next recommendation the specific agency addresses. For example, the first hyperlink for CDC takes the reader to recommendation #5, which is the next recommendation CDC addresses. The hyperlink for CDC in recommendation #5 then takes the reader to recommendation #6, the next recommendation CDC addresses; etc.