Draft: “Delhi Substance use Disorder Treatment, Counseling and Rehabilitation Centres rules,2018....Nada India
General comments
The proposed rules are long awaited and state intervention was certainly required to respond to the demand of the drug and alcohol in the National Capital Territory (NCT) of Delhi. The framing of these rules will help NGOs to contribute in the task of Government making Delhi healthy and drug free. There have been various initiatives by volunteers (recovering addicts) addressing the problem of drug and bridging the gap in service delivery at community level in the last three decades.
The accreditation of peer educators/counselors ,detox centers and rehabilitation centers both NGOs and government-run, to ensure standardization in rehabilitation by building a skilled cadre of peer educators/counselors, Therapeutic Community Manager, Rehabilitation social workers and psychologists; it is expected that this will help in mainstreaming hundreds of peer-led drug rehabilitation centers across the state. These drug-free peer educators can contribute in reducing the drug demand substantially as they connect directly at individual and community levels. It is paramount to strengthen patients and caregiver role and create a people-centered health care system in and around drug detox and rehabilitation centers. This will be vital for a drug free and healthy Delhi.
Treatment services should be diversified and offer different treatment approaches. Not one approach fits for all disorders and its various stages. Therefore, a diverse range of
interventions should be in place in various settings to address the needs of patients with
drug use disorders adequately.[1]People living with substance disorder (patient) and family members (caregiver) may like to choose what is best for them /appropriate.
interventions should be in place in various settings to address the needs of patients with
drug use disorders adequately.[1]People living with substance disorder (patient) and family members (caregiver) may like to choose what is best for them /appropriate.
35th report of Standing Committee on Social justice & Empowerment (2015 - 2016) (Sixteenth Lok Sabha) mentioned that there should be an agency for monitoring the working of NGOs to ensure that there is no prolonged usage of the pharmaceutical drugs after the treatment of the patient by them but also take stringent action against the NGOs/persons responsible for providing those drugs of treatment, to the patients after their treatment is over.[2]
(i) a psychiatrist as defined in clause (x); or
(ii) a professional registered with the concerned State Authority under section 55; or
(iii) a professional having a post-graduate degree (Ayurveda) in Mano Vigyan Avum Manas Roga or a post-graduate degree (Homoeopathy) in Psychiatry or a post-graduate degree (Unani) in Moalijat (Nafasiyatt) or a post-graduate degree (Siddha) in Sirappu Maruthuvam;.
Description of the settingResidential treatment for drug use disorders exists in a variety of forms, having developed independently in a variety of settings. Residential treatment which intends to promote therapeutic change must be distinguished from supported accommodation that primarily functions as a housing intervention that is not providing active treatment
Not every setting in which people with drug use disorders live together in an attempt to
create a supportive environment for each other necessarily qualifies as a health care
facility
create a supportive environment for each other necessarily qualifies as a health care
facility
Specific Comments
1. The rules are titled “Delhi substance use disorder treatment, counseling and rehabilitation centres rules” which capture the long term goal of rehabilitation and after care that there can be two types of centres operating in Delhi- Detox centers (Treatment) and Rehabilitation centres.
2. Most of these rehabilitation centers are following the structure and principles of Therapeutic Communities and 12 Steps. The unique characteristic of the therapeutic community is that while it has the standards of a health care facility, it also maintains the less formal beneficial aspects of community living.
Separate Detox Center and rehabilitation centers (long term care):
Accordingto Haryana De-addiction (Amendment) Rules 2018 “No patient would be admitted to a Centre till he undergoes detoxification from a Psychiatric Nursing Home or Hospital (Mental Health act). This fact would be on record as a certificate. There could be separate detox center (as per standard of care) and separate counselling cum rehabilitation centers (long term care). Or arrangement could be made available in government hospitals to deliver detoxification for patients with substance use disorders, This arrangement will be cost effective and utilize the human resource rationally.
3. In the composition of State and district Level Committee, non-official members include representatives of NGOs which is indeed appreciable. Rehabilitation services for substance use are provided by the social workers and hence, a representative of the National Association of Professional Social workers in India can also be included as non-official member.
4. Another suggestion is non-official member for State Level Committee may be someone representing the voice of affected community (Patient and Care giver). A representative or member of patient or caregiver support group or Narcotic/ Alcoholic Anonymous (NA/AA).
5. Among various functions listed for the State Level Committee, all the others are acceptable and appropriate. However, I think that this committee should take the task of leading the prevention programs at state and district level.” [4 (iv)]. Or an autonomous body for drug prevention with suitable mechanism may be created.
6.Keeping in view the recommendation of ‘Standing Committee on Social justice & Empowerment’ (2015 - 2016) that counseling programmes should also be conducted in District Courts to address the offences related to alcohol/drug abuse under trial in family courts and traffic courts.
7.There is a need to define the process and procedure how the committee/institutions are going to deal with people harming others or self /under influence of intoxicants or withdrawals inside and outside of the clinical setting or emergency rooms.
8.All non-ex-officio members and any special invitees may be paid a daily fee for
attending the meetings of the committee or any work undertaken for the committee
as per existing norms of Government from time to time.
attending the meetings of the committee or any work undertaken for the committee
as per existing norms of Government from time to time.
With best regards,
Founding board member, Healthy India Alliance. Chairperson, Nada India Foundation
Mobile 9810594544