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On July 28, 2023, ASAM responded to a request for information (RFI) from the US Department of Health and Human Services (HHS) regarding a proposed framework to support and accelerate treatment and remission from nicotine/tobacco use disorder (TUD). The framework places an acute emphasis on serving populations and communities disproportionately impacted by smoking-related morbidity and mortality and is partly driven by President Biden’s Cancer Moonshot Initiative and related executive orders aimed at advancing racial equity and supporting underserved communities.

Under the draft framework, HHS proposes six goals:

• Eliminate smoking and cessation-related disparities;
• Increase awareness and knowledge related to smoking and cessation;
• Strengthen and sustain cessation services and supports;
• Increase access to and coverage of comprehensive, evidence-based cessation treatment;
• Expand surveillance of smoking and cessation behaviors and strengthen performance measurement and evaluation; and
• Promote ongoing and innovative research to support and accelerate smoking cessation.
  

HHS sought comment on:

• Whether the proposed goals are appropriate and relevant for addressing the needs of populations disparately affected by smoking;
• If the broad strategies capture the key components and aspects needed to drive progress toward increasing cessation;
• Where there are additional goals or broad strategies that should be included in the Framework;
• What targeted actions HHS could take to advance these goals and strategies;
• What metrics and benchmarks should be included to ensure that the Framework drives progress?
  

ASAM provided comment on a number of areas, including requesting that HHS:

• Clearly define the populations that are disproportionately affected by smoking and detail how to advance interventions that are effective for these populations;
• Ensure targeted prevention and treatment interventions for children, adolescents, young adults, adults, pregnant people, geriatric patients, and patients with addiction to other substances/behaviors vs. nicotine addiction only;
• Encourage engagement in partnerships with private sector stakeholders to amplify the impact of tobacco control efforts to complement the strategies listed in the framework;
• Engage people with lived experience in the development of policy and services related to nicotine/tobacco use and its social determinants;
• Consider additional resources for treatment for nicotine/tobacco use beyond the scope of traditional quit-lines;
• Encourage all healthcare settings to consider and address social determinants of health—including housing, education, transportation, employment, and racism itself—as part of a patient’s comprehensive treatment and recovery for TUD;
• Ensure that existing mental health and addiction parity laws are vigorously enforced in the provision of treatment and services for nicotine/tobacco;
• Guarantee that Black, Indigenous, People of Color (BIPOC) with lived experience be better represented as part of clinical trials;
• Consider adding the practice of vaping and prevention from nicotine/tobacco use as part of the framework; and
• Use language consistent with the most current version of the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM), including treatment and remission from nicotine/tobacco use disorder in lieu of the term, “cessation.”
  

ASAM’s full comment letter can be found . The HHS RFI can be found .