National Council Comments on Proposed Recovery Housing Guidelines
Last week, the National Council provided official comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) on the agency’s proposed Recovery Housing Guidelines. The guidelines are the result of requirements included in the SUPPORT Act of 2018, a wide-ranging opioid package, for the federal government to identify and disseminate best practices for operating recovery housing. While the guidance is intended to help states increase the availability of quality recovery housing, the National Council raised numerous concerns that the guidance would instead reduce access to recovery housing and undermine existing recovery housing standards and certification programs.
Recovery housing refers to family-like living environments that are free from alcohol and illicit drug use and are centered on peer support and connections that promote sustained recovery from substance use disorders (SUDs). Recovery residences are largely unregulated, which has led to inconsistencies in the quality of recovery housing, including substandard housing, insurance schemes and exploitative operators. To address this issue, Congress included measures to provide recovery housing best practices as well as indicators of potential fraud as part of the recently-enacted opioid crisis law known as the SUPPORT Act.
As a longtime supporter of robust recovery housing standards, the National Council was disappointed to see the proposed Recovery Housing Guidelines mischaracterize recovery housing as a treatment intervention, rather than housing, and correspondingly offer guidance that was more appropriate for clinical treatment settings than recovery homes. Importantly, the proposed guidance fails to build off the extensive work done by states and the recovery housing community to implement nationally-recognized recovery housing standards.
Highlights of the National Council’s concerns and recommendations include:
Overly Clinical Focus: The document confuses the purpose of recovery housing as treatment and contains many references to a clinical treatment perspective, using clinical language and clinical assumptions that frequently do not align with recovery housing and recovery community perspectives. Much of the fraud involving recovery housing identified in recent years has involved insurance schemes, in which recovery housing operators receive compensation for referrals to inappropriate treatment services. Notably, by confusing the role of recovery residences with clinical treatment, the guidance may actually expose more residents to this kind of fraud and abuse, instead of achieving the directive of the SUPPORT Act to mitigate these practices.
Additionally, focusing the guidance on treatment ignores nonclinical recovery residences (Level I and II), which make up the most affordable and widely available recovery housing models across the U.S. As a result, the guidance would likely have the extremely damaging result of decreasing access to Level I and II recovery residences.
Lack of Specificity/Failure to Reference NARR Standards: The guidance fails to recognize the importance of the recovery housing quality standards developed by the National Alliance for Recovery Residences (NARR). The NARR standards outline necessary written policies and procedures that ensure resident safety and appropriate support. Yet, many of the policies and procedures required by NARR are not even mentioned in the proposed guidance. The NARR standards should be prominently featured in the document and regarded as the gold standard for operating a recovery residence.
By offering “10 Minimum Standards” that do not directly align with the NARR standards, the guidance is likely to create confusion for states and operators. Worse yet, this discrepancy could undo the time, effort and financial investment many states have already made to develop and implement recovery housing certification programs based upon the NARR standards.
Further, the SUPPORT Act specified that the Department of Health and Human Services (HHS) may include reference to “model state laws” as part of its recovery housing guidance. However, the agency offers no guidance on potential legislative or regulatory strategies to help states increase quality recovery housing. The National Council recommends that SAMHSA refer to a joint report by the National Council for Behavioral Health and NARR entitled Building Recovery: State Policy Guide for Supporting Recovery Housing to identify and disseminate best policy practices developed by states to promote quality recovery housing.