First Responder Agencies:
OPTIONAL Naloxone Program
In collaboration with the Massachusetts
Department of Public Health,
Bureau of Substance Abuse Services and
Office of HIV/AIDS
“HOW TO COMPLY”
There has been amendments made to 105 CMR171.000,
Massachusetts First Responder Training, and 105 CMR
700.000, Implementation of M.G.L. c. 94C.
These amendments permit municipalities to register
with DPH in order for first responders to carry and
administer naloxone, and also set out the training
requirements for first responder agencies that choose to
utilize naloxone.
Naloxone is a drug that reverses the effects of an
opioid overdose.
Emergency Amendments to 105 CMR
700.000:
Implementation of M.G.L. c. 94C
Drug Control Regulations
“NALOXONE OR OTHER OPIOID ANTAGONIST
APPROVED BY THE DEPARTMENT”
700.004: Registration Requirements
Emergency Amendments to 105 CMR
171.000:
First Responder Training Regulations
What does a first responder agency need if it
chooses to have a naloxone program?
A. Memorandum of agreement (MOA) for medical oversight
B. Training for its first responders, meeting requirements of
A/R 2-100
C. Massachusetts Controlled Substances Registration
D. Naloxone and atomizers for nasal administration, or Evzio
auto-injectors in accordance with Statewide Treatment
Protocol 2.14 (which provides standing order)
A. Memorandum of agreement for medical oversight
i.
If your first responder agency has an MOA with a hospital to carry AEDs or EpiPens, update that current MOA to
include naloxone.
ii.
If your first responder agency does not have an MOA and carries and uses AEDs and/or EpiPens please be advised
that you must have such an MOA with a hospital, under the First Responder Training Regulations, at 105 CMR
171.225 (AED) and 105 CMR 171.225 (EpiPen). See: http://www.mass.gov/eohhs/docs/dph/regs/105cmr171.pdf.
iii. If you are going to now get an MOA with a hospital, to cover your current AED and/or EpiPen program, the
Department recommends you have it cover naloxone use as well. To get an MOA with a hospital, approach your local
hospital, or your local ambulance service, for assistance. Make sure the hospital knows that the MOA is for a first
responder agency, and must address the requirements for such MOAs in the First Responder Training regulations, as
cited above.
iv. If you do not carry AEDs or EpiPens, and do not have an MOA with a hospital:
• The Department recommends you attempt to obtain an MOA with a hospital for medical oversight of the
naloxone program, because it is the most efficient and sustainable way in the long term, for your first
responders to get appropriate medical oversight, training and your agency to get naloxone and atomizer
kit (through hospital pharmacy). Follow the recommendations in A. iii., above.
• If you have difficulty obtaining an MOA for medical oversight with a hospital, you have the option, during
this public health emergency, for naloxone only, of obtaining an MOA for oversight with a medical
director. See 105 CMR 171.227. To try this approach, contact your local ambulance service for a
recommendation of a medical director with experience in EMS or first responder agency oversight.
• If you have difficulty obtaining an MOA with either a hospital or a medical director, contact the
Department, at [email protected], for assistance with finding a medical director.
A.
Steps to Obtaining a Memorandum of Agreement for Medical Oversight
Update your existing MOA
to include naloxone
YES
START
HERE
Do you have an MOA with a
hospital to carry AEDs or EpiPens?
NO
You must have an MOA
with a hospital to carry
AED or EpiPens
YES
Do your First
Responders
carry AEDs or
EpiPens?
NO
Talk to your local hospital
or your ambulance service
for assistance
Obtain an MOA with a hospital for medical oversight of the naloxone program;
this is the most efficient and sustainable way for your first responders to have
oversight, training and supplies (naloxone and atomizer kit through hospital
pharmacy)
Were you able to obtain an
MOA with a hospital to
carry AEDs, EpiPens and
naloxone?
You are now ready
to proceed with
MCSR registration
and training steps
YES
YES
Were you able
to obtain an
MOA with a
hospital?
NO
NO
If you cannot get an MOA with a hospital, you can, for naloxone only, have
an MOA for medical oversight with a medical director. To do this, contact
your local ambulance service for assistance of a medical director
You are now ready
Were you able to
to proceed with
YES obtain an MOA with
MCSR registration
a medical director?
and training steps
NO
If you cannot obtain an MOA with a hospital or a medical director, contact
the Department, at the email listed below, for help finding a medical director
for your program during the public health emergency
B. Training for First Responders – See 105 CMR 171.165
i.
Training must be approved by your medical director.
ii.
Training must meet the minimum curriculum requirements of Administrative
Requirement 2-100, http://www.mass.gov/eohhs/docs/dph/emergencyservices/ar/2-100.pdf
C. Massachusetts Controlled Substances Registration – Required under 105
CMR700.003(D)
Print out MCSR form for municipalities at:
http://www.mass.gov/eohhs/docs/dph/quality/drugcontrol/naloxone-nerveantidote-epi-form.pdf
i.
Complete and send in with fee, if fee is applicable. During the pendency of
the public health emergency, if a municipality is registering ONLY for
naloxone (that is, your first responder agency does NOT carry nerve agents
or EpiPens) the fee is waived. But if the application is to obtain a DCP
registration for more than naloxone, as required by 105 CMR 700.003(D), the
fee is still applicable. The form and fee is required to be completed annually.
D. Naloxone and atomizers for nasal administration, or Evzio autoinjectors in accordance with Statewide Treatment Protocol 2.14
i.
If you have an MOA with a hospital, your first responder agency obtains
your supply of naloxone and atomizer kit from the hospital’s pharmacy.
ii. If you have an MOA with a medical director, follow his or her
instructions on which pharmacy to access for obtaining your supply of
naloxone and atomizer kit.
iii. First responders are authorized to administer nasal naloxone as a
standing order, under Statewide Treatment Protocol 2.14.
See: http://www.mass.gov/eohhs/docs/dph/emergencyservices/emergency-protocols-substance-abuse-overdose.pdf. There is no
need for a separate medical order from a physician.
Department contact:
[email protected]
Emergency Protocols
Standing Order
How Do I Purchase Naloxone?
1. Establish an MOA with a local hospital and hospital pharmacy which
includes dispensing and replenishing the naloxone
2. If that is not possible, you can purchase the amount needed to respond
to potential emergencies before you would be able to restock (a few kits
per vehicle or first aid kit).
3. Obtain a copy of the “Commonwealth of Massachusetts Board of
Registration in Medicine Active License” from the physician who is
providing the medical oversight for your department. You will be required
to fax and submit a copy to the pharmaceutical company.
4. Contact a pharmaceutical retailer and set up an account.
5. You will need a finalized Massachusetts Controlled Substance
Registration (MCSR) in place before deploying the kits.
Where Can I Purchase Naloxone?
Some Options Include:
MooreMedical
1-800-234-1464
www.mooremedical.com (Suggested: Item #11216 & Item #74042)
BoundTree Medical
1-800-533-0523
https://www.boundtree.com/naloxone-group-19176-335.aspx
Mckesson
http://www.mckesson.com/
Southeastern Emergency Equipment
1-800-334-6656
http://sfadmin.seequip.com/storefrontCommerce/
Example of reporting form