Report on the Drug Situation 2010 - Bundesministerium für ...

all questions defined by the EMCDDA, and in addition, data on infectious diseases (also
according to EMCDDA guidelines) and ICD-10 codes are collected on a voluntary basis.
The substitution registry, which has been maintained at the Federal Ministry of Health
since 1989 (see ST3 and ST TDI), is a further data source worth mentioning. Regarding
personal data of clients, only gender, age and province of residence are registered.
5.1 Strategy/policy
Drug treatment strategies and policies are defined in the drug or addiction strategies
of the individual provinces and in the corresponding laws. In December 2009 two
decrees were issued (BGBl II 2009/485 and 2009/487), which again amended the legal
framework for substitution treatment and further training for doctors providing OST.
This was a response to the need for optimisation that showed when the effects of the
amendments of the legal framework effective as of 2007 were evaluated (see
GÖG/ÖBIG 2009b). One of the relevant aspects was the question of maintaining the
necessary treatment and supply structures. The new regulations have been described
in Chapter 1.1. The provisions regarding substances that should preferably be
prescribed have not changed, and as to further training for doctors providing OST, now
the Medical Association of Austria has to submit to the Ministry of Health an annual
report on the state of development and organisation of said training (Section 4, Paras.
1 and 5). The lists of doctors providing substitution treatments are no longer public,
and it has been specified who is entitled to access to these lists (Section 5, Para. 3). If
the requirements for entry in the list are not, or no longer, met, or if doctors do not
meet their professional obligations or violate these obligations, the district authorities,
after hearing the Austrian Medical Association, may delete the corresponding entries or
specify conditions for keeping these doctors on the list (Section 7, Paras. 1 and 3). The
transitional period was extended until 31 December 2010, and further training has to
be organised in a way that permits doctors to complete the basic training module by
this deadline (Section 9, Para. 8). Public health officers are also obliged to attend the
basic training module and have to meet the annual further training prerequisite.
From the point of view of many experts, the amendments have definitely helped
improve the situation regarding substitution treatment of opioid users, although a
number of provisions are still criticised (see GÖG/ÖBIG 2008c and 2009b as well as
Chapter 11.3). By the end of 2010 it will show whether the easing of requirements
regarding further training for doctors providing OST has actually had positive effects
on the supply situation. In several provinces, the number of doctors entitled to opioid
substitution treatment has meanwhile gone down further: for instance, Upper Austria
saw a decline from 200 in 2007 to 80 in 2010 (Ömer 2010). According to
Schwarzenbrunner (personal communication), after expiry of the transition period this
figure is expected to decrease by another 50%. In Lower Austria, after a decline in mid-
Chapter 5 / Drug-related Treatment: Treatment Demand and Treatment Availability 33