HomeMy WebLinkAbout2021 12 13 Consent 302 - Resolution Authorizing the City to join MOU and agreements for opioid settlement funds • CONSENT AGENDA ITEM 302
,n m=ared CITY COMMISSION AGENDA I DECEMBER 13, 2021 REGULAR MEETING
1959
TITLE
Resolution Authorizing the City to join MOU and agreements for opioid
settlement funds
SUMMARY
The State of Florida has had ongoing opioid litigation and separate negotiations with
defendants in the litigation (including separate counsel for cities and counties). The
State of Florida has proposed an opioid litigation settlement, where, based on the
status of this litigation, the likely structure of any resolution, and the potential litigation
risks in the absence of such an agreement, the State believes that this proposal
reflects a reasonable compromise between the State and its political subdivisions. The
State recommends that cities and counties accept this allocation.
This is an opt-in settlement. Generally, the more subdivisions that participate, the
greater the amount of funds that flow to the state and participating subdivisions. Any
subdivision which does not participate cannot directly share in any of the settlement
funds. Almost all settlement funds received must go towards abatement activities,
which are laid out in the attached letter.
In order to participate, the city first had to be registered on the national settlement
website so that information and documents required to participate may be provided,
which has been completed.
The attached resolution, which approves the offered memorandum of understanding
("MOU") relating to potential settlements, must be adopted by the governing body. The
deadline for electronic submission of the resolution to be a participating subdivision is
January 2, 2022.
After the deadline for subdivisions to opt-in for participation,Johnson &Johnson and
included distributors will decide whether there are enough subdivisions involved to
proceed with the respective settlements.
At this time, the city may be eligible for $159,088.63 (which is not guaranteed and is
the maximum potential amount).
RECOMMENDATION
Staff recommends that the City Commission approve Resolution Number
71
2021-25 authorizing the City to join MOU and agreements for opioid
settlement funds.
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RESOLUTION NO. 2021-25
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF
WINTER SPRINGS, FLORIDA,AUTHORIZING THE CITY OF WINTER
SPRINGS TO JOIN WITH THE STATE OF FLORIDA AND OTHER
LOCAL GOVERNMENTAL UNITS AS A PARTICIPANT IN THE
FLORIDA MEMORANDUM OF UNDERSTANDING AND FORMAL
AGREEMENTS IMPLEMENTING A UNIFIED PLAN FOR THE
ALLOCATION AND USE OF PROSPECTIVE SETTLEMENT DOLLARS
FROM OPIOID RELATED LITIGATION; PROVIDING AN EFFECTIVE
DATE.
WHEREAS, the City Winter Springs, Florida, ("City")has suffered harm from the opioid
epidemic; and
WHEREAS, the City recognizes that the entire State of Florida has suffered harm as a
result from the opioid epidemic; and
WHEREAS,the State of Florida has Piled an action pending in Pasco County,Florida, and
a number of Florida Cities and Counties have also filed an action In re: National Prescription
Opiate Litigation, MDL No. 2804 (N.D. Ohio) (the "Opioid Litigation") and the City is not a
litigating participant in that action; and
WHEREAS, the State of Florida and lawyers representing certain various local
governments involved in the Opioid Litigation have proposed a unified plan for the allocation and
use of prospective settlement dollars from opioid related litigation; and
WHEREAS, the Florida Memorandum of Understanding (the "Florida Plan") sets forth
sets forth a framework of a unified plan for the proposed allocation and use of opioid settlement
proceeds and it is anticipated that formal agreements implementing the Florida Plan will be entered
into at a future date; and,
WHEREAS, participation in the Florida Plan by a large majority of Florida cities and
counties will materially increase the amount of funds to Florida and should improve Florida's
relative bargaining position during additional settlement negotiations; and
WHEREAS, failure to participate in the Florida Plan will reduce funds available to the
State, the City, and every other Florida city and county; and
WHEREAS, the City Commission finds that this Resolution is in the best interests of the
public health, safety and welfare of the citizens of Winter Springs.
NOW,THEREFORE,BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF WINTER SPRINGS,AS FOLLOWS:
SECTION 1. That the Winter Springs City Commission finds that participation in the
Florida Plan would be in the best interest of the City and its citizens in that such a plan ensures
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that almost all of the settlement funds go to abate and resolve the opioid epidemic and each and
every city and county receives funds for the harm that it has suffered.
SECTION 2. That the Winter Springs City Commission hereby expresses its support of a
unified plan for the allocation and use of opioid settlement proceeds as generally described in the
Florida Plan, attached hereto as Exhibit"A."
SECTION 3. That the City Manager is hereby expressly authorized to execute the Florida
Plan in substantially the form contained in Exhibit"A."
SECTION 4. That the City Manager is hereby authorized to execute any formal
agreements implementing a unified plan for the allocation and use of opioid settlement proceeds
that is not substantially inconsistent with the Florida Plan and this Resolution.
SECTION 5. That the City Clerk be and hereby is instructed to record this Resolution in
the appropriate record book upon its adoption.
SECTION 6. The City Clerk is hereby directed to furnish a certified copy of this
Resolution to the Florida League of Cities, directed to:
Attorney General Ashley Moody
c\o John M. Guard
The Capitol,
PL-01
Tallahassee, FL 32399-1050
SECTION 7. Effective Date. This Resolution shall become effective immediately upon
adoption by the City Commission of the City of Winter Springs, Florida.
ADOPTED by the City Commission of the City of Winter Springs, Florida, in a Regular
Meeting duly assembled on the 13th day of December, 2021.
KEVIN McCANN,Mayor
ATTEST:
CHRISTIAN GOWAN, City Clerk
Approved as to legal form and sufficiency for
the City of Winter Springs,Florida only:
ANTHONY A. GARGANESE, City Attorney
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Exhibit A
PROPOSAL
MEMORANDUM OF UNDERSTANDING
Whereas, the people of the State of Florida and its communities have been harmed by
misfeasance, nonfeasance and malfeasance committed by certain entities within the
Pharmaceutical Supply Chain;
Whereas, the State of Florida, through its Attorney General, and certain Local
Governments, through their elected representatives and counsel, are separately engaged in
litigation seeking to hold Pharmaceutical Supply Chain Participants accountable for the damage
caused by their misfeasance,nonfeasance and malfeasance;
Whereas, the State of Florida and its Local Governments share a common desire to abate
and alleviate the impacts of that misfeasance, nonfeasance and malfeasance throughout the State
of Florida;
Whereas, it is the intent of the State of Florida and its Local Governments to use the
proceeds from Settlements with Pharmaceutical Supply Chain Participants to increase the amount
of funding presently spent on opioid and substance abuse education, treatment and other related
programs and services, such as those identified in Exhibits A and B, and to ensure that the funds
are expended in compliance with evolving evidence-based"best practices";
Whereas, the State of Florida and its Local Governments, subject to the completion of
formal documents that will effectuate the Parties' agreements, enter into this Memorandum of
Understanding("MOU")relating to the allocation and use of the proceeds of Settlements described
herein; and
Whereas, this MOU is a preliminary non-binding agreement between the Parties, is not
legally enforceable, and only provides a basis to draft formal documents which will effectuate the
Parties' agreements.
A. Definitions
As used in this MOU:
1. "Approved Purpose(s)" shall mean forward-looking strategies, programming and
services used to expand the availability of treatment for individuals impacted by substance use
disorders, to: (a) develop, promote, and provide evidence-based substance use prevention
strategies; (b) provide substance use avoidance and awareness education; (c) decrease the
oversupply of licit and illicit opioids; and(d)support recovery from addiction. Approved Purposes
shall include, but are not limited to, the opioid abatement strategies listed on Exhibits A and B
which are incorporated herein by reference.
2. "Local Governments" shall mean all counties, cities, towns and villages located
within the geographic boundaries of the State.
3. "Managing Entities" shall mean the corporations selected by and under contract
with the Florida Department of Children and Families or its successor ("DCF") to manage the
000003/01288125_1
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daily operational delivery of behavioral health services through a coordinated system of care. The
singular"Managing Entity" shall refer to a singular of the Managing Entities.
4. "County" shall mean a political subdivision of the state established pursuant to s.
1, Art. VIII of the State Constitution.
5. "Municipalities" shall mean cities, towns, or villages of a County within the State
with a Population greater than 10,000 individuals and shall also include cities, towns or villages
within the State with a Population equal to or less than 10,000 individuals which filed a Complaint
in this litigation against Pharmaceutical Supply Chain Participants. The singular "Municipality"
shall refer to a singular of the Municipalities.
6. "Negotiating Committee" shall mean a three-member group comprised by
representatives of the following: (1) the State; and (2)two representatives of Local Governments
of which one representative will be from a Municipality and one shall be from a County
(collectively,"Members")within the State. The State shall be represented by the Attorney General
or her designee.
7. "Negotiation Class Metrics" shall mean those county and city settlement allocations
which come from the official website of the Negotiation Class of counties and cities certified on
September 11, 2019 by the U.S. District for the Northern District of Ohio in In re National
Prescription Opiate Litigation, MDL No. 2804 (N.D. Ohio). The website is located at
https:Hallocationmap.iclaimsonline.com.
8. "Opioid Funds" shall mean monetary amounts obtained through a Settlement as
defined in this MOU.
9. "Opioid Related" shall have the same meaning and breadth as in the agreed Opioid
Abatement Strategies attached hereto as Exhibits A or B.
10. "Parties" shall mean the State and Local Governments. The singular word"Parry"
shall mean either the State or Local Governments.
11. "PEC" shall mean the Plaintiffs' Executive Committee of the National Prescription
Opiate Multidistrict Litigation pending in the United States District Court for the Northern District
of Ohio.
12. "Pharmaceutical Supply Chain" shall mean the process and channels through which
Controlled Substances are manufactured, marketed, promoted, distributed or dispensed.
13. "Pharmaceutical Supply Chain Participant" shall mean any entity that engages in,
or has engaged in the manufacture, marketing, promotion, distribution or dispensing of an opioid
analgesic.
14. "Population" shall refer to published U.S. Census Bureau population estimates as
of July 1, 2019, released March 2020, and shall remain unchanged during the term of this MOU.
These estimates can currently be found at https://www.census.gov
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15. "Qualified County" shall mean a charter or non-chartered county within the State
that: has a Population of at least 300,000 individuals and (a)has an opioid taskforce of which it is
a member or operates in connection with its municipalities or others on a local or regional basis;
(b)has an abatement plan that has been either adopted or is being utilized to respond to the opioid
epidemic; (c)is currently either providing or is contracting with others to provide substance abuse
prevention,recovery, and treatment services to its citizens; and(d)has or enters into an agreement
with a majority of Municipalities (Majority is more than 50% of the Municipalities' total
population)related to the expenditure of Opioid Funds. The Opioid Funds to be paid to a Qualified
County will only include Opioid Funds for Municipalities whose claims are released by the
Municipality or Opioid Funds for Municipalities whose claims are otherwise barred.
16. "SAMHSA" shall mean the U.S. Department of Health & Human Services,
Substance Abuse and Mental Health Services Administration.
17. "Settlement" shall mean the negotiated resolution of legal or equitable claims
against a Pharmaceutical Supply Chain Participant when that resolution has been jointly entered
into by the State and Local Governments or a settlement class as described in (13)(1)below.
18. "State" shall mean the State of Florida.
B. Terms
I. Only Abatement- Other than funds used for the Administrative Costs and Expense
Fund as hereinafter described in paragraph 6 and paragraph 9, respectively), all Opioid Funds shall
be utilized for Approved Purposes. To accomplish this purpose,the State will either file anew action
with Local Governments as Parties or add Local Governments to its existing action, sever settling
defendants, and seek entry of a consent order or other order binding both the State, Local
Governments, and Pharmaceutical Supply Chain Participant(s) ("Order"). The Order may be part
of a class action settlement or similar device. The Order shall provide for continuing jurisdiction of
a state court to address non-performance by any party under the Order. Any Local Government that
objects to or refuses to be included under the Order or entry of documents necessary to effectuate a
Settlement shall not be entitled to any Opioid Funds and its portion of Opioid Funds shall be
distributed to, and for the benefit of, the other Local Governments.
2. Avoid Claw Back and Recoupment-Both the State and Local Governments wish
to maximize any Settlement and Opioid Funds. In addition to committing to only using funds for
the Expense Funds,Administrative Costs and Approved Purposes,both Parties will agree to utilize
a percentage of funds for the core strategies highlighted in Exhibit A. Exhibit A contains the
programs and strategies prioritized by the U.S. Department of Justice and/or the U.S. Department
of Health & Human Services ("Core Strategies"). The State is trying to obtain the United States'
agreement to limit or reduce the United States' ability to recover or recoup monies from the State
and Local Government in exchange for prioritization of funds to certain projects. If no agreement
is reached with the United States, then there will be no requirement that a percentage be utilized
for Core Strategies.
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3. Distribution Scheme -All Opioid Funds will initially go to the State, and then be
distributed according to the following distribution scheme. The Opioid Funds will be divided into
three funds after deducting costs of the Expense Fund detailed in paragraph 9 below:
(a) Ci . /Coun . Fund- The city/county fund will receive 15% of all Opioid Funds to
directly benefit all Counties and Municipalities. The amounts to be distributed to
each County and Municipality shall be determined by the Negotiation Class Metrics
or other metrics agreed upon,in writing,by a County and a Municipality. For Local
Governments that are not within the definition of County or Municipality, those
Local Governments may receive that government's share of the City/County Fund
under the Negotiation Class Metrics, if that government executes a release as part
of a Settlement. Any Local Government that is not within the definition of County
or Municipality and that does not execute a release as part of a Settlement shall
have its share of the City/County Fund go to the County in which it is located.
(b) Regional Fund- The regional fund will be subdivided into two parts.
(i) The State will annually calculate the share of each County within the State
of the regional fund utilizing the sliding scale in section 4 of the allocation
contained in the Negotiation Class Metrics or other metrics that the Parties
agree upon.
(ii) For Qualified Counties, the Qualified County's share will be paid to the
Qualified County and expended on Approved Purposes, including the
Core Strategies identified in Exhibit A, if applicable.
(iii) For all other Counties, the regional share for each County will be paid to
the Managing Entities providing service for that County. The Managing
Entities will be required to expend the monies on Approved Purposes,
including the Core Strategies. The Managing Entities shall endeavor to
the greatest extent possible to expend these monies on counties within
the State that are non-Qualified Counties and to ensure that there are
services in every County.
(c) State Fund - The remainder of Opioid Funds after deducting the costs of the
Expense Fund detailed in paragraph 9,the City/County Fund and the Regional Fund
will be expended by the State on Approved Purposes, including the provisions
related to Core Strategies, if applicable.
(d) To the extent that Opioid Funds are not appropriated and expended in a year by the
State, the State shall identify the investments where settlement funds will be
deposited. Any gains, profits, or interest accrued from the deposit of the Opioid
Funds to the extent that any funds are not appropriated and expended within a
calendar year, shall be the sole property of the Party that was entitled to the initial
deposit.
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4. Regional Fund Sliding Scale- The Regional Fund shall be calculated by utilizing
the following sliding scale of the Opioid Funds available in any year:
A. Years 1-6: 40%
B. Years 7-9: 35%
C. Years 10-12: 34%
D. Years 13-15: 33%
E. Years 16-18: 30%
5. Opioid Abatement Taskforce or Council - The State will create an Opioid
Abatement Taskforce or Council (sometimes hereinafter"Taskforce" or"Council") to advise the
Governor, the Legislature, Florida's Department of Children and Families ("DCF"), and Local
Governments on the priorities that should be addressed as part of the opioid epidemic and to review
how monies have been spent and the results that have been achieved with Opioid Funds.
(a) Size - The Taskforce or Council shall have ten Members equally balanced between
the State and the Local Governments.
(b) Appointments Local Governments - Two Municipality representatives will be
appointed by or through Florida League of Cities. Two county representatives, one
from a Qualified County and one from a county within the State that is not a
Qualified County, will be appointed by or through the Florida Association of
Counties. The final representative will alternate every two years between being a
county representative (appointed by or through Florida Association of Counties) or
a Municipality representative (appointed by or through the Florida League of
Cities). One Municipality representative must be from a city of less than 50,000
people. One county representative must be from a county less than 200,000 people
and the other county representative must be from a county whose population
exceeds 200,000 people.
(c) Appointments State -
(i) The Governor shall appoint two Members.
(ii) The Speaker of the House shall appoint one Member.
(iii) The Senate President shall appoint one Member.
(iv) The Attorney General or her designee shall be a Member.
(d) Chair - The Attorney General or designee shall be the chair of the Taskforce or
Council.
(e) Term -Members will be appointed to serve a two-year term.
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(f) Support-DCF shall support the Taskforce or Council and the Taskforce or Council
shall be administratively housed in DCF.
(g) Meetings - The Taskforce or Council shall meet quarterly in person or virtually
using communications media technology as defined in section 120.54(5)(b)(2),
Florida Statutes.
(h) Reporting - The Taskforce or Council shall provide and publish a report annually
no later than November 30th or the first business day after November 30th, if
November 30th falls on a weekend or is otherwise not a business day. The report
shall contain information on how monies were spent the previous fiscal year by the
State, each of the Qualified Counties, each of the Managing Entities, and each of
the Local Governments. It shall also contain recommendations to the Governor,
the Legislature, and Local Governments for priorities among the Approved
Purposes for how monies should be spent the coming fiscal year to respond to the
opioid epidemic.
(i) Accountability_- Prior to July lst of each year, the State and each of the Local
Governments shall provide information to DCF about how they intend to expend
Opioid Funds in the upcoming fiscal year. The State and each of the Local
Government shall report its expenditures to DCF no later than August 31st for the
previous fiscal year. The Taskforce or Council will set other data sets that need to
be reported to DCF to demonstrate the effectiveness of Approved Purposes. All
programs and expenditures shall be audited annually in a similar fashion to
SAMHSA programs. Local Governments shall respond and provide documents to
any reasonable requests from the State for data or information about programs
receiving Opioid Funds.
(j) Conflict of Interest-All Members shall adhere to the rules,regulations and laws of
Florida including, but not limited to, Florida Statute §112.311, concerning the
disclosure of conflicts of interest and recusal from discussions or votes on
conflicted matters.
6. Administrative Costs- The State may take no more than a 5% administrative fee
from the State Fund ("Administrative Costs") and any Regional Fund that it administers for
counties that are not Qualified Counties. Each Qualified County may take no more than a 5%
administrative fee from its share of the Regional Funds.
7. Negotiation of Non-Multistate Settlements -If the State begins negotiations with
a Pharmaceutical Supply Chain Participant that is separate and apart from a multi-state negotiation,
the State shall include Local Governments that are a part of the Negotiating Committee in such
negotiations. No Settlement shall be recommended or accepted without the affirmative votes of
both the State and Local Government representatives of the Negotiating Committee.
8. Negotiation of Multistate or Local Government Settlements - To the extent
practicable and allowed by other parties to a negotiation, both Parties agree to communicate with
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members of the Negotiation Committee regarding the terms of any other Pharmaceutical Supply
Chain Participant Settlement.
9. Expense Fund-The Parties agree that in any negotiation every effort shall be made
to cause Pharmaceutical Supply Chain Participants to pay costs of litigation, including attorneys'
fees, in addition to any agreed to Opioid Funds in the Settlement. To the extent that a fund
sufficient to pay the entirety of all contingency fee contracts for Local Governments in the State
of Florida is not created as part of a Settlement by a Pharmaceutical Supply Chain Participant,the
Parties agree that an additional expense fund for attorneys who represent Local Governments
(herein "Expense Fund") shall be created out of the City/County fund for the purpose of paying
the hard costs of a litigating Local Government and then paying attorneys' fees.
(a) The Source of Funds for the Expense Fund- Money for the Expense Fund shall be
sourced exclusively from the City/County Fund.
(b) The Amount of the Expense Fund- The State recognizes the value litigating Local
Governments bring to the State of Florida in connection with the Settlement
because their participation increases the amount Incentive Payments due from each
Pharmaceutical Supply Chain Participant. In recognition of that value, the amount
of funds that shall be deposited into the Expense fund shall be contingent upon on
the percentage of litigating Local Government participation in the Settlement,
according to the following table:
Litigating Local Government Amount that shall be paid
Participation in the into the Expense Fund
Settlement(by percentage of from (and as a percentage
the population) i /Coun fund
96 to 100% 10%
91 to 95% 7.5%
86 to 90% 5%
85% 2.5%
Less than 85% 0%
If fewer than 85% percent of the litigating Local Governments (by population)
participate,then the Expense Fund shall not be funded,and this Section of the MOU
shall be null and void.
(c) The Timing of Payments into the Expense Fund- Although the amount of the
Expense Fund shall be calculated based on the entirety of payments due to the
City/County fund over a ten to eighteen year period, the Expense Fund shall be
funded entirely from payments made by Pharmaceutical Supply Chain Participants
during the first two years of the Settlement. Accordingly, to offset the amounts
being paid from the City/County to the Expense Fund in the first two years,
Counties or Municipalities may borrow from the Regional Fund during the first two
years and pay the borrowed amounts back to the Regional Fund during years three,
four, and five.
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For the avoidance of doubt, the following provides an illustrative example regarding the
calculation of payments and amounts that may be borrowed under the terms of this MOU,
consistent with the provisions of this Section:
Opioid Funds due to State of Florida and Local Governments (over 10 to 18 years): $1,000
Litigating Local Government Participation: 100%
City/County Fund(over 10 to 18 years): $150
Expense Fund (paid over 2 years): $15
Amount Paid to Expense Fund in 1st year: $7.5
Amount Paid to Expense Fund in 2nd year $7.5
Amount that may be borrowed from Regional Fund in 1 st year: $7.5
Amount that may be borrowed from Regional Fund in 2nd year: $7.5
Amount that must be paid back to Regional Fund in 3rd year: $5
Amount that must be paid back to Regional Fund in 4th year: $5
Amount that must be paid back to Regional Fund in 5th year: $5
(d) Creation of and Jurisdiction over the Expense Fund- The Expense Fund shall be
established, consistent with the provisions of this Section of the MOU,by order of
the Circuit Court of the Sixth Judicial Circuit in and for Pasco County, West Pasco
Division New Port Richey, Florida, in the matter of The State of Florida, Office of
the Attorney General, Department of Legal Affairs v. Purdue Pharma L.P., et al.,
Case No. 2018-CA-001438 (the "Court"). The Court shall have jurisdiction over
the Expense Fund, including authority to allocate and disburse amounts from the
Expense Fund and to resolve any disputes concerning the Expense Fund.
(e) Allocation of Payments to Counsel from the Expense Fund- As part of the order
establishing the Expense Fund, counsel for the litigating Local Governments shall
seek to have the Court appoint a third-neutral to serve as a special master for
purposes of allocating the Expense Fund. Within 30 days of entry of the order
appointing a special master for the Expense Fund, any counsel who intend to seek
an award from the Expense Fund shall provide the copies of their contingency fee
contracts to the special master. The special master shall then build a mathematical
model, which shall be based on each litigating Local Government's share under the
Negotiation Class Metrics and the rate set forth in their contingency contracts, to
calculate a proposed award for each litigating Local Government who timely
provided a copy of its contingency contract.
10. Dispute resolution-Any one or more of the Local Governments or the State may
object to an allocation or expenditure of Opioid Funds solely on the basis that the allocation or
expenditure at issue (a) is inconsistent with the Approved Purposes; (b) is inconsistent with the
distribution scheme as provided in paragraph 3, or(c)violates the limitations set forth herein with
respect to administrative costs or the Expense Fund. There shall be no other basis for bringing an
objection to the approval of an allocation or expenditure of Opioid Funds.
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Schedule A
Core Strategies
States and Qualifying Block Grantees shall choose from among the abatement strategies listed in
Schedule B. However,priority shall be given to the following core abatement strategies ("Core
Strategies")[, such that a minimum of %of the [aggregate] state-level abatement distributions shall
be spent on [one or more of] them annually].'
A.Naloxone or other FDA-approved drug to reverse opioid overdoses
1. Expand training for first responders, schools, community support groups and families; and
2. Increase distribution to individuals who are uninsured or whose insurance does not cover the needed
service.
B. Medication-Assisted Treatment("MAT") Distribution and other opioid-related treatment
1. Increase distribution of MAT to non-Medicaid eligible or uninsured individuals;
2. Provide education to school-based and youth-focused programs that discourage or prevent misuse;
3. Provide MAT education and awareness training to healthcare providers, EMTs, law enforcement,
and other first responders; and
4. Treatment and Recovery Support Services such as residential and inpatient treatment, intensive
outpatient treatment, outpatient therapy or counseling, and recovery housing that allow or integrate
medication with other support services.
C. Pregnant& Postpartum Women
1. Expand Screening, Brief Intervention, and Referral to Treatment("SBIRT") services to non-
Medicaid eligible or uninsured pregnant women;
2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for women
with co-occurring Opioid Use Disorder("OUD") and other Substance Use Disorder("SUD")/Mental
Health disorders for uninsured individuals for up to 12 months postpartum; and
3. Provide comprehensive wrap-around services to individuals with Opioid Use Disorder(OUD)
including housing,transportation,job placement/training, and childcare.
D. Expanding Treatment for Neonatal Abstinence Syndrome
1. Expand comprehensive evidence-based and recovery support for NAS babies;
2. Expand services for better continuum of care with infant-need dyad; and
3. Expand long-term treatment and services for medical monitoring of NAS babies and their families.
1 As used in this Schedule A,words like"expand,""fund,""provide"or the like shall not indicate a preference for new or
existing programs. Priorities will be established through the mechanisms described in the Term Sheet.
1
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E. Expansion of Warm Hand-off Programs and Recovery Services
1. Expand services such as navigators and on-call teams to begin MAT in hospital emergency
departments;
2. Expand warm hand-off services to transition to recovery services;
3. Broaden scope of recovery services to include co-occurring SUD or mental health conditions. ;
4. Provide comprehensive wrap-around services to individuals in recovery including housing,
transportation,job placement/training, and childcare; and
5. Hire additional social workers or other behavioral health workers to facilitate expansions above.
F. Treatment for Incarcerated Population
1. Provide evidence-based treatment and recovery support including MAT for persons with OUD and
co-occurring SUD/MH disorders within and transitioning out of the criminal justice system; and
2. Increase funding for jails to provide treatment to inmates with OUD.
G. Prevention Programs
1. Funding for media campaigns to prevent opioid use (similar to the FDA's "Real Cost" campaign to
prevent youth from misusing tobacco);
2. Funding for evidence-based prevention programs in schools.;
3. Funding for medical provider education and outreach regarding best prescribing practices for opioids
consistent with the 2016 CDC guidelines,including providers at hospitals (academic detailing);
4. Funding for community drug disposal programs; and
5. Funding and training for first responders to participate in pre-arrest diversion programs,post-
overdose response teams, or similar strategies that connect at-risk individuals to behavioral health
services and supports.
H. Expanding Syringe Service Programs
1. Provide comprehensive syringe services programs with more wrap-around services including linkage
to OUD treatment, access to sterile syringes, and linkage to care and treatment of infectious diseases.
I. Evidence-based data collection and research analyzing the effectiveness of the abatement strategies
within the State.
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Schedule B
Approved Uses
PART ONE: TREATMENT
A. TREAT OPIOID USE DISORDER(OUD)
Support treatment of Opioid Use Disorder(OUD) and any co-occurring Substance Use Disorder or
Mental Health (SUD/MH) conditions through evidence-based or evidence-informed programs or
strategies that may include,but are not limited to,the following:'
1. Expand availability of treatment for OUD and any co-occurring SUD/MH conditions, including all
forms of Medication-Assisted Treatment(MAT) approved by the U.S. Food and Drug Administration.
2. Support and reimburse evidence-based services that adhere to the American Society of Addiction
Medicine (ASAM)continuum of care for OUD and any co-occurring SUD/MH conditions
3. Expand telehealth to increase access to treatment for OUD and any co-occurring SUD/MH
conditions, including MAT, as well as counseling, psychiatric support, and other treatment and
recovery support services.
4. Improve oversight of Opioid Treatment Programs (OTPs)to assure evidence-based or evidence-
informed practices such as adequate methadone dosing and low threshold approaches to treatment.
5. Support mobile intervention,treatment, and recovery services, offered by qualified professionals and
service providers, such as peer recovery coaches, for persons with OUD and any co-occurring
SUD/MH conditions and for persons who have experienced an opioid overdose.
6. Treatment of trauma for individuals with OUD (e.g.,violence, sexual assault,human trafficking, or
adverse childhood experiences) and family members (e.g., surviving family members after an overdose
or overdose fatality), and training of health care personnel to identify and address such trauma.
7. Support evidence-based withdrawal management services for people with OUD and any co-
occurring mental health conditions.
8. Training on MAT for health care providers, first responders, students, or other supporting
professionals, such as peer recovery coaches or recovery outreach specialists, including telementoring
to assist community-based providers in rural or underserved areas.
9. Support workforce development for addiction professionals who work with persons with OUD and
any co-occurring SUD/MH conditions.
10. Fellowships for addiction medicine specialists for direct patient care, instructors, and clinical
research for treatments.
11. Scholarships and supports for behavioral health practitioners or workers involved in addressing
OUD and any co-occurring SUD or mental health conditions, including but not limited to training,
2 As used in this Schedule B,words like"expand,""fund,""provide"or the like shall not indicate a preference for new or
existing programs. Priorities will be established through the mechanisms described in the Term Sheet.
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scholarships, fellowships, loan repayment programs, or other incentives for providers to work in rural
or underserved areas.
12. [Intentionally Blank—to be cleaned up later for numbering]
13. Provide funding and training for clinicians to obtain a waiver under the federal Drug Addiction
Treatment Act of 2000 (DATA 2000)to prescribe MAT for OUD, and provide technical assistance and
professional support to clinicians who have obtained a DATA 2000 waiver.
14. Dissemination of web-based training curricula, such as the American Academy of Addiction
Psychiatry's Provider Clinical Support Service-Opioids web-based training curriculum and
motivational interviewing.
15. Development and dissemination of new curricula, such as the American Academy of Addiction
Psychiatry's Provider Clinical Support Service for Medication-Assisted Treatment.
B. SUPPORT PEOPLE IN TREATMENT AND RECOVERY
Support people in treatment for or recovery from OUD and any co-occurring SUD/MH conditions
through evidence-based or evidence-informed programs or strategies that may include,but are not
limited to, the following:
1. Provide comprehensive wrap-around services to individuals with OUD and any co-occurring
SUD/MH conditions, including housing,transportation, education,job placement,job training, or
childcare.
2. Provide the full continuum of care of treatment and recovery services for OUD and any co-occurring
SUD/MH conditions, including supportive housing, peer support services and counseling, community
navigators, case management, and connections to community-based services.
3. Provide counseling,peer-support, recovery case management and residential treatment with access to
medications for those who need it to persons with OUD and any co-occurring SUD/MH conditions.
4. Provide access to housing for people with OUD and any co-occurring SUD/MH conditions,
including supportive housing,recovery housing,housing assistance programs,training for housing
providers, or recovery housing programs that allow or integrate FDA-approved medication with other
support services.
5. Provide community support services, including social and legal services, to assist in
deinstitutionalizing persons with OUD and any co-occurring SUD/MH conditions.
6. Support or expand peer-recovery centers,which may include support groups, social events, computer
access, or other services for persons with OUD and any co-occurring SUD/MH conditions.
7. Provide or support transportation to treatment or recovery programs or services for persons with
OUD and any co-occurring SUD/MH conditions.
8. Provide employment training or educational services for persons in treatment for or recovery from
OUD and any co-occurring SUD/MH conditions.
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9. Identify successful recovery programs such as physician,pilot, and college recovery programs, and
provide support and technical assistance to increase the number and capacity of high-quality programs
to help those in recovery.
10. Engage non-profits, faith-based communities, and community coalitions to support people in
treatment and recovery and to support family members in their efforts to support the person with OUD
in the family.
11. Training and development of procedures for government staff to appropriately interact and provide
social and other services to individuals with or in recovery from OUD, including reducing stigma.
12. Support stigma reduction efforts regarding treatment and support for persons with OUD, including
reducing the stigma on effective treatment.
13. Create or support culturally appropriate services and programs for persons with OUD and any co-
occurring SUD/MH conditions, including new Americans.
14. Create and/or support recovery high schools.
15. Hire or train behavioral health workers to provide or expand any of the services or supports listed
above.
C. CONNECT PEOPLE WHO NEED HELP TO THE HELP THEY NEED (CONNECTIONS
TO CARE)
Provide connections to care for people who have—or at risk of developing—OUD and any co-
occurring SUD/MH conditions through evidence-based or evidence-informed programs or strategies
that may include,but are not limited to,the following:
1. Ensure that health care providers are screening for OUD and other risk factors and know how to
appropriately counsel and treat (or refer if necessary)a patient for OUD treatment.
2. Fund Screening, Brief Intervention and Referral to Treatment (SBIRT)programs to reduce the
transition from use to disorders, including SBIRT services to pregnant women who are uninsured or not
eligible for Medicaid.
3. Provide training and long-term implementation of SBIRT in key systems (health, schools, colleges,
criminal justice, and probation),with a focus on youth and young adults when transition from misuse to
opioid disorder is common.
4. Purchase automated versions of SBIRT and support ongoing costs of the technology.
5. Expand services such as navigators and on-call teams to begin MAT in hospital emergency
departments.
6. Training for emergency room personnel treating opioid overdose patients on post-discharge planning,
including community referrals for MAT, recovery case management or support services.
7. Support hospital programs that transition persons with OUD and any co-occurring SUD/MH
conditions, or persons who have experienced an opioid overdose, into clinically-appropriate follow-up
care through a bridge clinic or similar approach.
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8. Support crisis stabilization centers that serve as an alternative to hospital emergency departments for
persons with OUD and any co-occurring SUD/MH conditions or persons that have experienced an
opioid overdose.
9. Support the work of Emergency Medical Systems, including peer support specialists,to connect
individuals to treatment or other appropriate services following an opioid overdose or other opioid-
related adverse event.
10. Provide funding for peer support specialists or recovery coaches in emergency departments, detox
facilities,recovery centers,recovery housing, or similar settings; offer services, supports, or
connections to care to persons with OUD and any co-occurring SUD/MH conditions or to persons who
have experienced an opioid overdose.
11. Expand warm hand-off services to transition to recovery services.
12. Create or support school-based contacts that parents can engage with to seek immediate treatment
services for their child; and support prevention, intervention,treatment, and recovery programs focused
on young people.
13. Develop and support best practices on addressing OUD in the workplace.
14. Support assistance programs for health care providers with OUD.
15. Engage non-profits and the faith community as a system to support outreach for treatment.
16. Support centralized call centers that provide information and connections to appropriate services
and supports for persons with OUD and any co-occurring SUD/MH conditions.
D.ADDRESS THE NEEDS OF CRIMINAL-JUSTICE-INVOLVED PERSONS
Address the needs of persons with OUD and any co-occurring SUD/MH conditions who are involved
in, are at risk of becoming involved in, or are transitioning out of the criminal justice system through
evidence-based or evidence-informed programs or strategies that may include,but are not limited to,
the following:
1. Support pre-arrest or pre-arraignment diversion and deflection strategies for persons with OUD and
any co-occurring SUD/MH conditions, including established strategies such as:
a. Self-referral strategies such as the Angel Programs or the Police Assisted Addiction Recovery
Initiative (PAARI);
b. Active outreach strategies such as the Drug Abuse Response Team (DART)model;
c. "Naloxone Plus" strategies, which work to ensure that individuals who have received
naloxone to reverse the effects of an overdose are then linked to treatment programs or other
appropriate services;
d. Officer prevention strategies, such as the Law Enforcement Assisted Diversion (LEAD)
model;
e. Officer intervention strategies such as the Leon County, Florida Adult Civil Citation Network
or the Chicago Westside Narcotics Diversion to Treatment Initiative; or
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f. Co-responder and/or alternative responder models to address OUD-related 911 calls with
greater SUD expertise
2. Support pre-trial services that connect individuals with OUD and any co-occurring SUD/MH
conditions to evidence-informed treatment, including MAT, and related services.
3. Support treatment and recovery courts that provide evidence-based options for persons with OUD
and any co-occurring SUD/MH conditions
4. Provide evidence-informed treatment, including MAT, recovery support, harm reduction, or other
appropriate services to individuals with OUD and any co-occurring SUD/MH conditions who are
incarcerated in jail or prison.
5. Provide evidence-informed treatment, including MAT, recovery support, harm reduction, or other
appropriate services to individuals with OUD and any co-occurring SUD/MH conditions who are
leaving jail or prison have recently left jail or prison, are on probation or parole, are under community
corrections supervision, or are in re-entry programs or facilities.
6. Support critical time interventions (CTI),particularly for individuals living with dual-diagnosis
OUD/serious mental illness, and services for individuals who face immediate risks and service needs
and risks upon release from correctional settings.
7. Provide training on best practices for addressing the needs of criminal-justice-involved persons with
OUD and any co-occurring SUD/MH conditions to law enforcement, correctional, or judicial personnel
or to providers of treatment,recovery,harm reduction, case management, or other services offered in
connection with any of the strategies described in this section.
E. ADDRESS THE NEEDS OF PREGNANT OR PARENTING WOMEN AND THEIR
FAMILIES,INCLUDING BABIES WITH NEONATAL ABSTINENCE SYNDROME
Address the needs of pregnant or parenting women with OUD and any co-occurring SUD/MH
conditions, and the needs of their families, including babies with neonatal abstinence syndrome (NAS),
through evidence-based or evidence-informed programs or strategies that may include,but are not
limited to, the following:
1. Support evidence-based or evidence-informed treatment, including MAT,recovery services and
supports, and prevention services for pregnant women—or women who could become pregnant—who
have OUD and any co-occurring SUD/MH conditions, and other measures to educate and provide
support to families affected by Neonatal Abstinence Syndrome.
2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for
uninsured women with OUD and any co-occurring SUD/MH conditions for up to 12 months
postpartum.
3. Training for obstetricians or other healthcare personnel that work with pregnant women and their
families regarding treatment of OUD and any co-occurring SUD/MH conditions.
4. Expand comprehensive evidence-based treatment and recovery support for NAS babies; expand
services for better continuum of care with infant-need dyad; expand long-term treatment and services
for medical monitoring of NAS babies and their families.
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5. Provide training to health care providers who work with pregnant or parenting women on best
practices for compliance with federal requirements that children born with Neonatal Abstinence
Syndrome get referred to appropriate services and receive a plan of safe care.
6. Child and family supports for parenting women with OUD and any co-occurring SUD/MH
conditions.
7. Enhanced family supports and child care services for parents with OUD and any co-occurring
SUD/MH conditions.
8. Provide enhanced support for children and family members suffering trauma as a result of addiction
in the family; and offer trauma-informed behavioral health treatment for adverse childhood events.
9. Offer home-based wrap-around services to persons with OUD and any co-occurring SUD/MH
conditions, including but not limited to parent skills training.
10. Support for Children's Services—Fund additional positions and services, including supportive
housing and other residential services,relating to children being removed from the home and/or placed
in foster care due to custodial opioid use.
PART TWO: PREVENTION
F. PREVENT OVER-PRESCRIBING AND ENSURE APPROPRIATE PRESCRIBING AND
DISPENSING OF OPIOIDS
Support efforts to prevent over-prescribing and ensure appropriate prescribing and dispensing of
opioids through evidence-based or evidence-informed programs or strategies that may include,but are
not limited to,the following:
1. Fund medical provider education and outreach regarding best prescribing practices for opioids
consistent with Guidelines for Prescribing Opioids for Chronic Pain from the U.S. Centers for Disease
Control and Prevention, including providers at hospitals(academic detailing).
2. Training for health care providers regarding safe and responsible opioid prescribing, dosing, and
tapering patients off opioids.
3. Continuing Medical Education (CME)on appropriate prescribing of opioids.
4. Support for non-opioid pain treatment alternatives, including training providers to offer or refer to
multi-modal, evidence-informed treatment of pain.
5. Support enhancements or improvements to Prescription Drug Monitoring Programs (PDMPs),
including but not limited to improvements that:
a. Increase the number of prescribers using PDMPs;
b. Improve point-of-care decision-making by increasing the quantity, quality, or format of data
available to prescribers using PDMPs,by improving the interface that prescribers use to access
PDMP data, or both; or
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c. Enable states to use PDMP data in support of surveillance or intervention strategies, including
MAT referrals and follow-up for individuals identified within PDMP data as likely to
experience OUD in a manner that complies with all relevant privacy and security laws and rules.
6. Ensuring PDMPs incorporate available overdose/naloxone deployment data, including the United
States Department of Transportation's Emergency Medical Technician overdose database in a manner
that complies with all relevant privacy and security laws and rules.
7. Increase electronic prescribing to prevent diversion or forgery.
8. Educate Dispensers on appropriate opioid dispensing.
G. PREVENT MISUSE OF OPIOIDS
Support efforts to discourage or prevent misuse of opioids through evidence-based or evidence-
informed programs or strategies that may include, but are not limited to, the following:
1. Fund media campaigns to prevent opioid misuse.
2. Corrective advertising or affirmative public education campaigns based on evidence.
3. Public education relating to drug disposal.
4. Drug take-back disposal or destruction programs.
5. Fund community anti-drug coalitions that engage in drug prevention efforts.
6. Support community coalitions in implementing evidence-informed prevention, such as reduced
social access and physical access, stigma reduction—including staffing, educational campaigns, support
for people in treatment or recovery, or training of coalitions in evidence-informed implementation,
including the Strategic Prevention Framework developed by the U.S. Substance Abuse and Mental
Health Services Administration (SAMHSA).
7. Engage non-profits and faith-based communities as systems to support prevention.
8. Fund evidence-based prevention programs in schools or evidence-informed school and community
education programs and campaigns for students, families, school employees, school athletic programs,
parent-teacher and student associations, and others.
9. School-based or youth-focused programs or strategies that have demonstrated effectiveness in
preventing drug misuse and seem likely to be effective in preventing the uptake and use of opioids.
10. Create of support community-based education or intervention services for families,youth, and
adolescents at risk for OUD and any co-occurring SUD/MH conditions.
11. Support evidence-informed programs or curricula to address mental health needs of young people
who may be at risk of misusing opioids or other drugs, including emotional modulation and resilience
skills.
12. Support greater access to mental health services and supports for young people, including services
and supports provided by school nurses,behavioral health workers or other school staff, to address
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mental health needs in young people that (when not properly addressed)increase the risk of opioid or
other drug misuse.
H. PREVENT OVERDOSE DEATHS AND OTHER HARMS (HARM REDUCTION)
Support efforts to prevent or reduce overdose deaths or other opioid-related harms through evidence-
based or evidence-informed programs or strategies that may include,but are not limited to,the
following:
1. Increase availability and distribution of naloxone and other drugs that treat overdoses for first
responders, overdose patients, individuals with OUD and their friends and family members, individuals
at high risk of overdose, schools, community navigators and outreach workers,persons being released
from jail or prison, or other members of the general public.
2. Public health entities provide free naloxone to anyone in the community
3. Training and education regarding naloxone and other drugs that treat overdoses for first responders,
overdose patients,patients taking opioids, families, schools, community support groups, and other
members of the general public.
4. Enable school nurses and other school staff to respond to opioid overdoses, and provide them with
naloxone,training, and support.
5. Expand, improve, or develop data tracking software and applications for overdoses/naloxone
revivals.
6. Public education relating to emergency responses to overdoses.
7. Public education relating to immunity and Good Samaritan laws.
8. Educate first responders regarding the existence and operation of immunity and Good Samaritan
laws.
9. Syringe service programs and other evidence-informed programs to reduce harms associated with
intravenous drug use, including supplies, staffing, space,peer support services,referrals to treatment,
fentanyl checking, connections to care, and the full range of harm reduction and treatment services
provided by these programs.
10. Expand access to testing and treatment for infectious diseases such as HIV and Hepatitis C resulting
from intravenous opioid use.
11. Support mobile units that offer or provide referrals to harm reduction services,treatment, recovery
supports, health care, or other appropriate services to persons that use opioids or persons with OUD and
any co-occurring SUD/MH conditions.
12. Provide training in harm reduction strategies to health care providers, students,peer recovery
coaches,recovery outreach specialists, or other professionals that provide care to persons who use
opioids or persons with OUD and any co-occurring SUD/MH conditions.
13. Support screening for fentanyl in routine clinical toxicology testing.
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PART THREE: OTHER STRATEGIES
L FIRST RESPONDERS
In addition to items in sections C, D, and H relating to first responders, support the following:
1. Educate law enforcement or other first responders regarding appropriate practices and precautions
when dealing with fentanyl or other drugs.
2. Provision of wellness and support services for first responders and others who experience secondary
trauma associated with opioid-related emergency events.
J. LEADERSHIP,PLANNING AND COORDINATION
Support efforts to provide leadership,planning, coordination, facilitation,training and technical
assistance to abate the opioid epidemic through activities,programs, or strategies that may include, but
are not limited to, the following:
1. Statewide,regional, local, or community regional planning to identify root causes of addiction and
overdose, goals for reducing harms related to the opioid epidemic, and areas and populations with the
greatest needs for treatment intervention services; to support training and technical assistance; or to
support other strategies to abate the opioid epidemic described in this opioid abatement strategy list.
2. A dashboard to share reports,recommendations, or plans to spend opioid settlement funds;to show
how opioid settlement funds have been spent; to report program or strategy outcomes; or to track, share,
or visualize key opioid-related or health-related indicators and supports as identified through
collaborative statewide,regional, local, or community processes.
3. Invest in infrastructure or staffing at government or not-for-profit agencies to support collaborative,
cross-system coordination with the purpose of preventing overprescribing, opioid misuse, or opioid
overdoses, treating those with OUD and any co-occurring SUD/MH conditions, supporting them in
treatment or recovery, connecting them to care, or implementing other strategies to abate the opioid
epidemic described in this opioid abatement strategy list.
4. Provide resources to staff government oversight and management of opioid abatement programs.
K. TRAINING
In addition to the training referred to throughout this document, support training to abate the opioid
epidemic through activities, programs, or strategies that may include, but are not limited to, the
following:
1. Provide funding for staff training or networking programs and services to improve the capability of
government, community, and not-for-profit entities to abate the opioid crisis.
2. Support infrastructure and staffing for collaborative cross-system coordination to prevent opioid
misuse,prevent overdoses, and treat those with OUD and any co-occurring SUD/MH conditions, or
implement other strategies to abate the opioid epidemic described in this opioid abatement strategy list
(e.g.,health care,primary care,pharmacies, PDMPs, etc.).
L. RESEARCH
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Support opioid abatement research that may include,but is not limited to,the following:
1. Monitoring, surveillance, data collection, and evaluation of programs and strategies described in this
opioid abatement strategy list.
2. Research non-opioid treatment of chronic pain.
3. Research on improved service delivery for modalities such as SBIRT that demonstrate promising but
mixed results in populations vulnerable to opioid use disorders.
4. Research on novel harm reduction and prevention efforts such as the provision of fentanyl test strips.
5. Research on innovative supply-side enforcement efforts such as improved detection of mail-based
delivery of synthetic opioids.
6. Expanded research on swift/certain/fair models to reduce and deter opioid misuse within criminal
justice populations that build upon promising approaches used to address other substances (e.g. Hawaii
HOPE and Dakota 24/7).
7. Epidemiological surveillance of OUD-related behaviors in critical populations including individuals
entering the criminal justice system, including but not limited to approaches modeled on the Arrestee
Drug Abuse Monitoring (ADAM) system.
8. Qualitative and quantitative research regarding public health risks and harm reduction opportunities
within illicit drug markets, including surveys of market participants who sell or distribute illicit opioids.
9. Geospatial analysis of access barriers to MAT and their association with treatment engagement and
treatment outcomes.
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OFFICE OF THE ATTORNEY GENERAL
PL-01 The Capitol
* Tallahassee,FL 32399-1050
ASHLEY MOODY Phone(850)414-3300
ATTORNEY GENERAL Fax(850)487-0168
STATE OF FLORIDA http://www.myfloridalegal.com
April 13, 2021
RE: Opioid Litigation
My name is John Guard and I am the Chief Deputy Attorney General for the State of
Florida(the "State"). Since she took office, Attorney General Moody has been heavily involved
in leading both the State's ongoing opioid litigation and several different negotiations with
defendants in that litigation. Those negotiations have included litigation counsel representing
cities and counties.
As part of those negotiations to enable Florida to achieve the maximum amount
recoverable for both the State and its subdivisions, the State has been negotiating for a lengthy
time with outside counsel for nearly all litigating political subdivisions within the State. After
multiple sessions and significant compromise by both sides, the attached memorandum of
understanding ("MOU")has been reached. We have offered and the lawyers for the litigating
subdivisions are recommending to their clients that the attached MOU be accepted. This
proposal is the result of numerous meetings and includes feedback and comments from many
local subdivisions. Based on the status of this litigation, the likely structure of any resolution,
the potential litigation risks in the absence of such an agreement, the State believe that this
proposal reflects a reasonable compromise between the State and its political subdivisions.
The purpose of this letter is to summarize the primary terms of the MOU and attempt to
anticipate questions that you, your commission, and your internal and/or other legal counsel may
have regarding this litigation and allocation proposal.
What cases does this MOU apply?
This allocation agreement is intended to govern the distribution of settlement proceeds
obtained through the Purdue Pharma L.P. ("Purdue") bankruptcy, the Mallinckrodt PLC
("Mallinckrodt")bankruptcy,the distributor (Cardinal Health, Inc_, McKesson Corp., and
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AmerisourceBergen Corp. (collectively referred to as the "Distributors")) and Johnson &
Johnson ("J&J")potential deal, as well as any additional settlements obtained related to the
opioid litigation.
Why is an allocation agreement necessary and why now?
Almost 100 political subdivisions within the State of Florida, as well as the State of
Florida itself,have filed suit against numerous entities engaged in the manufacture, marketing,
promotion, distribution or dispensing of opioids. Another 30 political subdivisions within the
State of Florida have filed claims in the Purdue bankruptcy.
The State and the Plaintiffs' Executive Committee for the Opioid Litigation Multi-
District Litigation panel (the "PEC") are in ongoing negotiations with Purdue, Mallinckrodt, the
Distributors, and J&J with potential resolutions anticipated in the coming weeks.
Under the likely settlement structure for these cases, states and their political subdivisions are
strongly incentivized to reach a joint resolution of all State and political subdivision claims.
Under the Distributor and J&J deal, the State and its subdivisions receive a substantially larger
settlement amount the higher the number of subdivisions sign on to the deal. Therefore, it is in
the best interest of all political subdivisions and the State of Florida to reach an allocation
agreement which will permit the joint resolution of all claims within the state.
The deals contemplate the need for relatively quick buy in by subdivisions in order to
maximize recovery. The pace of negotiations is accelerating, and Purdue has filed its plan of
reorganization. Given this accelerating pace, there is a greater sense of urgency among all
counsel to come to agreement and resolve how monies are going to be allocated, so that we can
move Purdue, Mallinckrodt, and other potential settlements toward finality. Given the Sunshine
law,the likely need for public notice and comment, and the complexity of the deals, we need to
agree to an allocation plan now to ensure that Florida maximizes recovery.
How can funds be utilized?
You will see as you review the MOU that the State and its subdivisions,who execute this
MOU, are agreeing that almost all the funds from any settlement will go to abatement activities.
In other words, funds must be utilized for strategies, programming and services used to expand
the availability of treatment for individuals impacted by Opioid Use Disorder or co-occurring
Substance Use Disorder and Mental Health disorders ("Approved Purposes"). A non-exclusive
list of potential abatement programs and uses are included in Exhibits A and B to the agreement.
The list was developed nationally consulting with public health officials in multiple states,
experts for the states and subdivisions, and officials within the United States Department of
Health and Human Services. These uses are intended to best serve the overall purpose and
intention of this litigation,which is to abate the continuing public health crisis of opioid
addiction within our communities.
While supported by the State, this requirement was imposed the defendants for tax and
other reasons. It is also necessary to militate against the United States seeking substantial
amounts of settlement funds from both the State and subdivisions as recoupment.
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How are the funds allocated amongst the States?
While not part of the MOU, the States have been negotiating the national allocation for
almost two years with an agreement reached in late 2019. Florida's interstate allocation is
7.03%. That allocation is the second largest allocation in the nation ahead of Texas, which is the
second largest state. Florida is one of a handful of states whose allocation is greater and greater
by a significant percentage above its population (Florida has 6.54% of the United States'
population). The only states that have larger gains over their population are the opioid belt
states: West Virginia, Kentucky, etc. The interstate allocation is the product of two measures.
One calculated by the PEC and the other calculated by the States. The data sets chosen are
slightly different(including different years and what measures were selected), but the main
difference is that some states demanded that population play a more significant factor in the state
allocation and it is not a factor in the PEC calculation. Given how much Florida's allocation
percentage is above its population, the need in these settlements to maximize the number of
states settling, and the potential litigation risks in the absence of such an agreement, it would be
our recommendation that cities and counties accept the interstate allocation.
How much money does the State expect for it and its subdivisions?
It depends. Each of the current or proposed settlements are for different lengths of time
and each contain different variability. In Purdue, payments are paid over a ten-year period and
vary with the performance of the ongoing business of the new company and payments from third
parties. In Mallinckrodt, payment amounts are still being negotiated, but will be paid over seven
years and will vary depending on the value of the emerging company seven years later as part of
the recovery is warrants in the re-emerged company. In the Distributor and J&J proposed deal,
the proposed deal is over eighteen years and the amount paid varies depending on subdivision
participation and whether other subdivisions file opioid related litigation in the future. As part of
the MOU, the State is willing to seek judicial or legislative action to reduce the variability of the
monies, especially in connection with the Distributor and J&J deal. Our current best guess based
on projections and assuming total participation is $120-140M a year for the first few years, $90-
110M a year for the middle years, and then $60-70M a year for the later years of the deal for the
State and its subdivisions. Again, these numbers can and will vary and hopefully will increase if
additional settlements are reached.
How are the funds allocated amongst the State and its subdivisions?
This Proposal divides all settlement funds between three funds: (1)the City/County Fund;
(2)the Regional Fund; and(3)the State Fund.
The City/County Fund consists of 15% of the total settlement amounts allocable to the
State of Florida. These funds are distributed to all counties and qualifying municipalities in the
State of Florida.
The allocation of the City/County Fund between counties and municipalities is based on a
model referred to as the "Negotiation Class Metrics." This model was developed in the National
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Prescription Opiate MDL by the PEC, and considers: (1)the amount of opioids shipped to the
county; (2)the number of opioid deaths that occurred in that county; and (3)the number of
people who suffer opioid use disorder in that county. Allocations between counties and
municipalities within each county use historical federal data showing how the specific county
and the cities within it have made opioids-related expenditures in the past.
We have attached a spreadsheet to this letter that provides you an estimated amount per
year for an amount within each range in the previous question.
The Regional Fund consists of a sliding scale between 30% and 40% of the total
settlement amounts allocable to the State of Florida, with the largest percentages occurring in the
immediate years after settlement and decreasing over time.
These funds are allocated to counties in accordance with the "Negotiating Class Metrics"
described above. In the case of counties with a population of over 300,000, and which satisfy
other criteria regarding abatement infrastructure, (termed"Qualified Counties")these funds are
provided directly to the county. For the remainder of counties within the State, these funds are
provided to the Managing Entity (the entity that the State has contracted with to provide
substance abuse treatment) for that county, to be spent on approved purposes within the region
that the county is a part.
For Counties with populations greater than 300,000: We encourage you to review the
definition of Qualified County in the MOU, so that you can understand the other
requirements that you will have to meet. Importantly, the definition of Qualified County
requires that you reach an agreement with at least some municipalities (at least 50% of
the population)within your county as to how these funds are spent. The requirements of
such agreements are subject to further discussion and negotiation.
We have attached a spreadsheet to this letter that provides you an estimated amount per
year for an amount within each range in the previous question. The amount will vary for
qualified counties depending on how many municipalities in that County: (1)join a
settlement; and (2) enter an agreement with a County.
For Counties with populations less than 300,000 or that do not qualms as a Qualified
County: Currently, a majority of the monies being utilized to respond to the opioid
epidemic in the State flow through Managing Entities located regionally who provide
service in each community. When we traveled the state before COVID and had
discussions with many of you, most(outside a couple large counties) indicated that they
had a good working relationship with their Managing Entity. Indeed, several indicated
that they were already involved with their Managing Entity. The actual dollar amounts
annually paid to smaller counties under the contemplated settlement agreements are not
substantial enough to support standalone programs. Given that reality, but wanting to
maximize services locally, it made sense to have the monies flow through the existing
structure to expand services in each county. If there are issues or problems with
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Managing Entities,we are happy to engage. We are also happy to try and help
communities get involved in or engage with their Managing Entity.
We have attached a spreadsheet to this letter that demonstrates the amounts attributable to
each county per year for an amount within each range in the previous question.
The State Fund consists of the remaining 45%to 55% of the total settlement amounts
allocable to the State of Florida, depending on the amount of the Regional Fund above. As with
the City/County Fund and Regional Fund,these funds must be spent on Approved Purposes
Why should we agree to this allocation?
The proposed allocation in the MOU is better than the alternative that subdivisions will
receive if they do not enter an agreement with the State. Two of the defendants who we have
negotiated with, Purdue and Mallinckrodt are now in bankruptcy. In advance of and in
connection with those bankruptcies, the states, the PEC, and city and county representatives
negotiated a default intrastate allocation and agreed that it will apply unless a state and its cities
and counties agree to something else. A Deputy County Attorney for Broward County, Florida,
was involved in the negotiations related to Purdue. Something like the Purdue default allocation
is currently in the draft connected to the Distributor and J&J deal.
The allocation above is superior for Florida's subdivisions than that default allocation.
Indeed, the State offered substantial improvements over those terms from the beginning of the
negotiations that led to this MOU. We have attached a copy of the Purdue abatement term sheet
for your review. Under that default allocation, there is no city/county fund. Only subdivisions
with populations greater than 400,000 people are eligible to receive any monies directly. Almost
all the monies will flow through the Managing Entities who are regionally supplying services.
The allocation percentages for the regional bucket are dollar based and decrease to half, far more
quickly than in the MOU. In other words, the allocation in this MOU allows a far greater
recovery directly to each Florida city and county than the alternative and greater recoveries
regionally for all subdivisions.
The allocation is also better than the cities and counties would achieve if damages were
proportionally allocated. In the Purdue bankruptcy, over one hundred twenty-five Florida
subdivisions filed proofs of claims. When the size of those claims is compared to that of the
State's claim, the State's claim was more than four, almost five times larger than all the
subdivisions' claims combined. Subdivisions are getting substantially more than what their
proportional share would be. The State is willing to agree to the larger because it frankly reflects
the reality of how monies are currently being spent and is consistent with how the legislature has
been appropriating monies to combat this crisis.
If individual subdivisions do not agree to a settlement,what will happen?
If there are hold outs or subdivisions that do not respond, the MOU contemplates that the
State will either file a new suit or sever its claims against settling defendants from its existing
opioid lawsuit and add political subdivisions and through either a class action mechanism or
declaratory relief seek to bar future subdivision claims. Such action is necessary to ensure that
the State and any subdivisions that agree to a settlement maximize their recoveries. This not a
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novel position and there is a substantial body of Florida law that exists that the State may resolve
and release public claims including subdivision claims.' That being said, the State would prefer
that we reach agreement on the allocation under the proposed MOU and handle things
consensually. But, if there are holdouts, the State is prepared to litigate or seek legislation from
the legislature to ensure that cities and counties that agree to this MOU are protected and will
receive the recovery contemplated under the allocation.
What are the next steps and the timeline?
We would ask that you review the attached MOU and proposed model resolution
supporting an agreement on the MOU terms. We will be scheduling calls to answer questions
about the MOU. We would ask each subdivision to think about who is attending each session
and ensure that any of those discussions will not violate Florida's government-in-the-sunshine
law. If you will contact my administrator, Janna Barineau, by e-mail
(Janna.Barineau unmyfloridale ag l.com),we will include you in those discussions. After those
discussions, we would then ask that you follow Florida law for approving such a resolution by
your commission and in due course, pass it, and return a copy to me at the address on the first
page of the letter.Potential settlements are anticipated in the coming weeks or months, but I
cannot tell you exactly when a settlement will be finalized. These proposed settlements are
anticipated to include provisions which establish time limits on agreements between states and
political subdivisions. As a result,we would request that you pass a resolution in the next 60-90
days, if possible.
Sincerely,
John M. Guard,
Chief Deputy Attorney General
Enc. Proposal with Ex. A and B
Recovery Spreadsheet
Purdue Abatement Term Sheet
I See Fla. Stat. §501.207(1)(c)(authorizing the Attorney General to bring "[a]n action on
behalf of one or more consumers or government entities for actual damages..."under Florida's
Deceptive and Unfair Trade Practices Act); e.g., Engle v. Liggett Group, Inc., 945 So. 2d 1246,
1258-62 (Fla. 2006); Young v. Miami Beach Improvement Co., 46 So. 2d 26, 30 (Fla. 1950);
Castro v. Sun Bank of Bal Harbour, 370 So. 2d 392, 393 (Fla. 3d DCA1979); City of New Port
Richey v. State ex rel. O'Malley, 145 So. 903, 905 (Fla. 2d DCA 1962); also State of Florida ex
rel. Shevin v. Exxon Corp., 526 F.2d 266, 275 (5th Cir. 1976) (holding that the Attorney General
could file suit seeking damages for injuries sustained by government entities who had not
specifically authorized the Attorney General to do so); Eggers v. City of Key West, 2007 WL
9702450, at *3 (S.D. Fla. Feb. 26, 2007) (concluding"[a]pplicable Florida law states that a
judgment in an action brought against a public entity that adjudicates matters of general interest
to the citizens of the jurisdiction is binding on all citizens of that jurisdiction.");Aerojet-General
Corp. v. Askew, 366 F. Supp. 901, 908-11 (N.D. Fla. 1973).
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PROPOSAL
MEMORANDUM OF UNDERSTANDING
Whereas, the people of the State of Florida and its communities have been harmed by
misfeasance, nonfeasance and malfeasance committed by certain entities within the
Pharmaceutical Supply Chain;
Whereas, the State of Florida, through its Attorney General, and certain Local
Governments, through their elected representatives and counsel, are separately engaged in
litigation seeking to hold Pharmaceutical Supply Chain Participants accountable for the damage
caused by their misfeasance, nonfeasance and malfeasance;
Whereas, the State of Florida and its Local Governments share a common desire to abate
and alleviate the impacts of that misfeasance, nonfeasance and malfeasance throughout the State
of Florida;
Whereas, it is the intent of the State of Florida and its Local Governments to use the
proceeds from Settlements with Pharmaceutical Supply Chain Participants to increase the amount
of funding presently spent on opioid and substance abuse education, treatment and other related
programs and services, such as those identified in Exhibits A and B, and to ensure that the funds
are expended in compliance with evolving evidence-based"best practices";
Whereas, the State of Florida and its Local Governments, subject to the completion of
formal documents that will effectuate the Parties' agreements, enter into this Memorandum of
Understanding("MOU")relating to the allocation and use of the proceeds of Settlements described
herein; and
Whereas, this MOU is a preliminary non-binding agreement between the Parties, is not
legally enforceable, and only provides a basis to draft formal documents which will effectuate the
Parties' agreements.
A. Definitions
As used in this MOU:
1. "Approved Purpose(s)" shall mean forward-looking strategies, programming and
services used to expand the availability of treatment for individuals impacted by substance use
disorders, to: (a) develop, promote, and provide evidence-based substance use prevention
strategies; (b) provide substance use avoidance and awareness education; (c) decrease the
oversupply of licit and illicit opioids; and(d)support recovery from addiction. Approved Purposes
shall include, but are not limited to, the opioid abatement strategies listed on Exhibits A and B
which are incorporated herein by reference.
2. "Local Governments" shall mean all counties, cities, towns and villages located
within the geographic boundaries of the State.
3. "Managing Entities" shall mean the corporations selected by and under contract
with the Florida Department of Children and Families or its successor ("DCF") to manage the
000003/01288125_1
101
daily operational delivery of behavioral health services through a coordinated system of care. The
singular"Managing Entity" shall refer to a singular of the Managing Entities.
4. "County" shall mean a political subdivision of the state established pursuant to s.
1, Art. VIII of the State Constitution.
5. "Municipalities" shall mean cities, towns, or villages of a County within the State
with a Population greater than 10,000 individuals and shall also include cities, towns or villages
within the State with a Population equal to or less than 10,000 individuals which filed a Complaint
in this litigation against Pharmaceutical Supply Chain Participants. The singular "Municipality"
shall refer to a singular of the Municipalities.
6. "Negotiating Committee" shall mean a three-member group comprised by
representatives of the following: (1) the State; and (2) two representatives of Local Governments
of which one representative will be from a Municipality and one shall be from a County
(collectively,"Members")within the State. The State shall be represented by the Attorney General
or her designee.
7. "Negotiation Class Metrics"shall mean those county and city settlement allocations
which come from the official website of the Negotiation Class of counties and cities certified on
September 11, 2019 by the U.S. District for the Northern District of Ohio in In re National
Prescription Opiate Litigation, MDL No. 2804 (N.D. Ohio). The website is located at
https://allocationmap.iclaimsonline.com.
8. "Opioid Funds" shall mean monetary amounts obtained through a Settlement as
defined in this MOU.
9. "Opioid Related' shall have the same meaning and breadth as in the agreed Opioid
Abatement Strategies attached hereto as Exhibits A or B.
10. "Parties" shall mean the State and Local Governments. The singular word"Party"
shall mean either the State or Local Governments.
11. "PEC"shall mean the Plaintiffs' Executive Committee of the National Prescription
Opiate Multidistrict Litigation pending in the United States District Court for the Northern District
of Ohio.
12. "Pharmaceutical Supply Chain"shall mean the process and channels through which
Controlled Substances are manufactured, marketed, promoted, distributed or dispensed.
13. "Pharmaceutical Supply Chain Participant" shall mean any entity that engages in,
or has engaged in the manufacture, marketing, promotion, distribution or dispensing of an opioid
analgesic.
14. "Population" shall refer to published U.S. Census Bureau population estimates as
of July 1, 2019,released March 2020, and shall remain unchanged during the term of this MOU.
These estimates can currently be found at https://www.census.gov
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15. "Qualified County" shall mean a charter or non-chartered county within the State
that: has a Population of at least 300,000 individuals and (a)has an opioid taskforce of which it is
a member or operates in connection with its municipalities or others on a local or regional basis;
(b)has an abatement plan that has been either adopted or is being utilized to respond to the opioid
epidemic; (c)is currently either providing or is contracting with others to provide substance abuse
prevention,recovery, and treatment services to its citizens; and(d)has or enters into an agreement
with a majority of Municipalities (Majority is more than 50% of the Municipalities' total
population)related to the expenditure of Opioid Funds. The Opioid Funds to be paid to a Qualified
County will only include Opioid Funds for Municipalities whose claims are released by the
Municipality or Opioid Funds for Municipalities whose claims are otherwise barred.
16. "SAMHSA" shall mean the U.S. Department of Health & Human Services,
Substance Abuse and Mental Health Services Administration.
17. "Settlement" shall mean the negotiated resolution of legal or equitable claims
against a Pharmaceutical Supply Chain Participant when that resolution has been jointly entered
into by the State and Local Governments or a settlement class as described in (13)(1)below.
18. "State" shall mean the State of Florida.
B. Terms
1. Only Abatement- Other than funds used for the Administrative Costs and Expense
Fund as hereinafter described in paragraph 6 and paragraph 9, respectively), all Opioid Funds shall
be utilized for Approved Purposes. To accomplish this purpose,the State will either file a new action
with Local Governments as Parties or add Local Governments to its existing action, sever settling
defendants, and seek entry of a consent order or other order binding both the State, Local
Governments, and Pharmaceutical Supply Chain Participant(s) ("Order"). The Order may be part
of a class action settlement or similar device. The Order shall provide for continuing jurisdiction of
a state court to address non-performance by any party under the Order. Any Local Government that
objects to or refuses to be included under the Order or entry of documents necessary to effectuate a
Settlement shall not be entitled to any Opioid Funds and its portion of Opioid Funds shall be
distributed to, and for the benefit of, the other Local Governments.
2. Avoid Claw Back and Recoupment-Both the State and Local Governments wish
to maximize any Settlement and Opioid Funds. In addition to committing to only using funds for
the Expense Funds,Administrative Costs and Approved Purposes,both Parties will agree to utilize
a percentage of funds for the core strategies highlighted in Exhibit A. Exhibit A contains the
programs and strategies prioritized by the U.S. Department of Justice and/or the U.S. Department
of Health & Human Services ("Core Strategies"). The State is trying to obtain the United States'
agreement to limit or reduce the United States' ability to recover or recoup monies from the State
and Local Government in exchange for prioritization of funds to certain projects. If no agreement
is reached with the United States, then there will be no requirement that a percentage be utilized
for Core Strategies.
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3. Distribution Scheme -All Opioid Funds will initially go to the State, and then be
distributed according to the following distribution scheme. The Opioid Funds will be divided into
three funds after deducting costs of the Expense Fund detailed in paragraph 9 below:
(a) Ci . /Coun . Fund- The city/county fund will receive 15% of all Opioid Funds to
directly benefit all Counties and Municipalities. The amounts to be distributed to
each County and Municipality shall be determined by the Negotiation Class Metrics
or other metrics agreed upon,in writing,by a County and a Municipality. For Local
Governments that are not within the definition of County or Municipality, those
Local Governments may receive that government's share of the City/County Fund
under the Negotiation Class Metrics, if that government executes a release as part
of a Settlement. Any Local Government that is not within the definition of County
or Municipality and that does not execute a release as part of a Settlement shall
have its share of the City/County Fund go to the County in which it is located.
(b) Regional Fund- The regional fund will be subdivided into two parts.
(i) The State will annually calculate the share of each County within the State
of the regional fund utilizing the sliding scale in section 4 of the allocation
contained in the Negotiation Class Metrics or other metrics that the Parties
agree upon.
(ii) For Qualified Counties, the Qualified County's share will be paid to the
Qualified County and expended on Approved Purposes, including the
Core Strategies identified in Exhibit A, if applicable.
(iii) For all other Counties, the regional share for each County will be paid to
the Managing Entities providing service for that County. The Managing
Entities will be required to expend the monies on Approved Purposes,
including the Core Strategies. The Managing Entities shall endeavor to
the greatest extent possible to expend these monies on counties within
the State that are non-Qualified Counties and to ensure that there are
services in every County.
(c) State Fund - The remainder of Opioid Funds after deducting the costs of the
Expense Fund detailed in paragraph 9,the City/County Fund and the Regional Fund
will be expended by the State on Approved Purposes, including the provisions
related to Core Strategies, if applicable.
(d) To the extent that Opioid Funds are not appropriated and expended in a year by the
State, the State shall identify the investments where settlement funds will be
deposited. Any gains, profits, or interest accrued from the deposit of the Opioid
Funds to the extent that any funds are not appropriated and expended within a
calendar year, shall be the sole property of the Parry that was entitled to the initial
deposit.
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4. Regional Fund Sliding Scale- The Regional Fund shall be calculated by utilizing
the following sliding scale of the Opioid Funds available in any year:
A. Years 1-6: 40%
B. Years 7-9: 35%
C. Years 10-12: 34%
D. Years 13-15: 33%
E. Years 16-18: 30%
5. Opioid Abatement Taskforce or Council - The State will create an Opioid
Abatement Taskforce or Council (sometimes hereinafter"Taskforce" or"Council") to advise the
Governor, the Legislature, Florida's Department of Children and Families ("DCF"), and Local
Governments on the priorities that should be addressed as part of the opioid epidemic and to review
how monies have been spent and the results that have been achieved with Opioid Funds.
(a) Size- The Taskforce or Council shall have ten Members equally balanced between
the State and the Local Governments.
(b) Appointments Local Governments - Two Municipality representatives will be
appointed by or through Florida League of Cities. Two county representatives, one
from a Qualified County and one from a county within the State that is not a
Qualified County, will be appointed by or through the Florida Association of
Counties. The final representative will alternate every two years between being a
county representative (appointed by or through Florida Association of Counties) or
a Municipality representative (appointed by or through the Florida League of
Cities). One Municipality representative must be from a city of less than 50,000
people. One county representative must be from a county less than 200,000 people
and the other county representative must be from a county whose population
exceeds 200,000 people.
(c) Appointments State -
(i) The Governor shall appoint two Members.
(ii) The Speaker of the House shall appoint one Member.
(iii) The Senate President shall appoint one Member.
(iv) The Attorney General or her designee shall be a Member.
(d) Chair - The Attorney General or designee shall be the chair of the Taskforce or
Council.
(e) Term -Members will be appointed to serve a two-year term.
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(f) Support-DCF shall support the Taskforce or Council and the Taskforce or Council
shall be administratively housed in DCF.
(g) Meetings - The Taskforce or Council shall meet quarterly in person or virtually
using communications media technology as defined in section 120.54(5)(b)(2),
Florida Statutes.
(h) Reporting_- The Taskforce or Council shall provide and publish a report annually
no later than November 30th or the first business day after November 30th, if
November 30th falls on a weekend or is otherwise not a business day. The report
shall contain information on how monies were spent the previous fiscal year by the
State, each of the Qualified Counties, each of the Managing Entities, and each of
the Local Governments. It shall also contain recommendations to the Governor,
the Legislature, and Local Governments for priorities among the Approved
Purposes for how monies should be spent the coming fiscal year to respond to the
opioid epidemic.
(i) Accountability - Prior to July 1st of each year, the State and each of the Local
Governments shall provide information to DCF about how they intend to expend
Opioid Funds in the upcoming fiscal year. The State and each of the Local
Government shall report its expenditures to DCF no later than August 31 st for the
previous fiscal year. The Taskforce or Council will set other data sets that need to
be reported to DCF to demonstrate the effectiveness of Approved Purposes. All
programs and expenditures shall be audited annually in a similar fashion to
SAMHSA programs. Local Governments shall respond and provide documents to
any reasonable requests from the State for data or information about programs
receiving Opioid Funds.
(j) Conflict of Interest-All Members shall adhere to the rules,regulations and laws of
Florida including, but not limited to, Florida Statute §112.311, concerning the
disclosure of conflicts of interest and recusal from discussions or votes on
conflicted matters.
6. Administrative Costs- The State may take no more than a 5% administrative fee
from the State Fund ("Administrative Costs") and any Regional Fund that it administers for
counties that are not Qualified Counties. Each Qualified County may take no more than a 5%
administrative fee from its share of the Regional Funds.
7. Negotiation of Non-Multistate Settlements -If the State begins negotiations with
a Pharmaceutical Supply Chain Participant that is separate and apart from a multi-state negotiation,
the State shall include Local Governments that are a part of the Negotiating Committee in such
negotiations. No Settlement shall be recommended or accepted without the affirmative votes of
both the State and Local Government representatives of the Negotiating Committee.
8. Negotiation of Multistate or Local Government Settlements - To the extent
practicable and allowed by other parties to a negotiation, both Parties agree to communicate with
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members of the Negotiation Committee regarding the terms of any other Pharmaceutical Supply
Chain Participant Settlement.
9. Expense Fund-The Parties agree that in any negotiation every effort shall be made
to cause Pharmaceutical Supply Chain Participants to pay costs of litigation, including attorneys'
fees, in addition to any agreed to Opioid Funds in the Settlement. To the extent that a fund
sufficient to pay the entirety of all contingency fee contracts for Local Governments in the State
of Florida is not created as part of a Settlement by a Pharmaceutical Supply Chain Participant, the
Parties agree that an additional expense fund for attorneys who represent Local Governments
(herein "Expense Fund") shall be created out of the City/County fund for the purpose of paying
the hard costs of a litigating Local Government and then paying attorneys' fees.
(a) The Source of Funds for the Expense Fund- Money for the Expense Fund shall be
sourced exclusively from the City/County Fund.
(b) The Amount of the Expense Fund- The State recognizes the value litigating Local
Governments bring to the State of Florida in connection with the Settlement
because their participation increases the amount Incentive Payments due from each
Pharmaceutical Supply Chain Participant. In recognition of that value, the amount
of funds that shall be deposited into the Expense fund shall be contingent upon on
the percentage of litigating Local Government participation in the Settlement,
according to the following table:
Litigating Local Government Amount that shall be paid
Participation in the into the Expense Fund
Settlement(by percentage of from (and as a percentage
the population) /County fund
96 to 100% 10%
91 to 95% 7.5%
86 to 90% 5%
85% 2.5%
Less than 85% 0%
If fewer than 85% percent of the litigating Local Governments (by population)
participate,then the Expense Fund shall not be funded,and this Section of the MOU
shall be null and void.
(c) The Timing of Payments into the Expense Fund- Although the amount of the
Expense Fund shall be calculated based on the entirety of payments due to the
City/County fund over a ten to eighteen year period, the Expense Fund shall be
funded entirely from payments made by Pharmaceutical Supply Chain Participants
during the first two years of the Settlement. Accordingly, to offset the amounts
being paid from the City/County to the Expense Fund in the first two years,
Counties or Municipalities may borrow from the Regional Fund during the first two
years and pay the borrowed amounts back to the Regional Fund during years three,
four, and five.
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For the avoidance of doubt, the following provides an illustrative example regarding the
calculation of payments and amounts that may be borrowed under the terms of this MOU,
consistent with the provisions of this Section:
Opioid Funds due to State of Florida and Local Governments (over 10 to 18 years): $1,000
Litigating Local Government Participation: 100%
City/County Fund (over 10 to 18 years): $150
Expense Fund (paid over 2 years): $15
Amount Paid to Expense Fund in 1st year: $7.5
Amount Paid to Expense Fund in 2nd year $7.5
Amount that may be borrowed from Regional Fund in 1st year: $7.5
Amount that may be borrowed from Regional Fund in 2nd year: $7.5
Amount that must be paid back to Regional Fund in 3rd year: $5
Amount that must be paid back to Regional Fund in 4th year: $5
Amount that must be paid back to Regional Fund in 5th year: $5
(d) Creation of and Jurisdiction over the Expense Fund- The Expense Fund shall be
established, consistent with the provisions of this Section of the MOU, by order of
the Circuit Court of the Sixth Judicial Circuit in and for Pasco County, West Pasco
Division New Port Richey, Florida, in the matter of The State of Florida, Office of
the Attorney General, Department of Legal Affairs v. Purdue Pharma L.P., et al.,
Case No. 2018-CA-001438 (the "Court"). The Court shall have jurisdiction over
the Expense Fund, including authority to allocate and disburse amounts from the
Expense Fund and to resolve any disputes concerning the Expense Fund.
(e) Allocation of Payments to Counsel from the Expense Fund- As part of the order
establishing the Expense Fund, counsel for the litigating Local Governments shall
seek to have the Court appoint a third-neutral to serve as a special master for
purposes of allocating the Expense Fund. Within 30 days of entry of the order
appointing a special master for the Expense Fund, any counsel who intend to seek
an award from the Expense Fund shall provide the copies of their contingency fee
contracts to the special master. The special master shall then build a mathematical
model,which shall be based on each litigating Local Government's share under the
Negotiation Class Metrics and the rate set forth in their contingency contracts, to
calculate a proposed award for each litigating Local Government who timely
provided a copy of its contingency contract.
10. Dispute resolution-Any one or more of the Local Governments or the State may
object to an allocation or expenditure of Opioid Funds solely on the basis that the allocation or
expenditure at issue (a) is inconsistent with the Approved Purposes; (b) is inconsistent with the
distribution scheme as provided in paragraph 3, or(c)violates the limitations set forth herein with
respect to administrative costs or the Expense Fund. There shall be no other basis for bringing an
objection to the approval of an allocation or expenditure of Opioid Funds.
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Schedule A
Core Strategies
States and Qualifying Block Grantees shall choose from among the abatement strategies listed in
Schedule B. However,priority shall be given to the following core abatement strategies ("Core
Strategies")[, such that a minimum of %of the [aggregate] state-level abatement distributions shall
be spent on [one or more of] them annually].'
A.Naloxone or other FDA-approved drug to reverse opioid overdoses
1. Expand training for first responders, schools, community support groups and families; and
2. Increase distribution to individuals who are uninsured or whose insurance does not cover the needed
service.
B. Medication-Assisted Treatment("MAT")Distribution and other opioid-related treatment
1. Increase distribution of MAT to non-Medicaid eligible or uninsured individuals;
2. Provide education to school-based and youth-focused programs that discourage or prevent misuse;
3. Provide MAT education and awareness training to healthcare providers, EMTs, law enforcement,
and other first responders; and
4. Treatment and Recovery Support Services such as residential and inpatient treatment, intensive
outpatient treatment, outpatient therapy or counseling, and recovery housing that allow or integrate
medication with other support services.
C. Pregnant& Postpartum Women
1. Expand Screening, Brief Intervention, and Referral to Treatment ("SBIRT") services to non-
Medicaid eligible or uninsured pregnant women;
2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for women
with co-occurring Opioid Use Disorder ("OUD") and other Substance Use Disorder("SUD")/Mental
Health disorders for uninsured individuals for up to 12 months postpartum; and
3. Provide comprehensive wrap-around services to individuals with Opioid Use Disorder(OUD)
including housing,transportation,job placement/training, and childcare.
D. Expanding Treatment for Neonatal Abstinence Syndrome
1. Expand comprehensive evidence-based and recovery support for NAS babies;
2. Expand services for better continuum of care with infant-need dyad; and
3. Expand long-term treatment and services for medical monitoring of NAS babies and their families.
1 As used in this Schedule A,words like"expand,""fund,""provide"or the like shall not indicate a preference for new or
existing programs. Priorities will be established through the mechanisms described in the Term Sheet.
1
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E. Expansion of Warm Hand-off Programs and Recovery Services
1. Expand services such as navigators and on-call teams to begin MAT in hospital emergency
departments;
2. Expand warm hand-off services to transition to recovery services;
3. Broaden scope of recovery services to include co-occurring SUD or mental health conditions. ;
4. Provide comprehensive wrap-around services to individuals in recovery including housing,
transportation,job placement/training, and childcare; and
5. Hire additional social workers or other behavioral health workers to facilitate expansions above.
F. Treatment for Incarcerated Population
1. Provide evidence-based treatment and recovery support including MAT for persons with OUD and
co-occurring SUD/MH disorders within and transitioning out of the criminal justice system; and
2. Increase funding for jails to provide treatment to inmates with OUD.
G. Prevention Programs
1.Funding for media campaigns to prevent opioid use (similar to the FDA's "Real Cost"campaign to
prevent youth from misusing tobacco);
2. Funding for evidence-based prevention programs in schools.;
3. Funding for medical provider education and outreach regarding best prescribing practices for opioids
consistent with the 2016 CDC guidelines, including providers at hospitals(academic detailing);
4. Funding for community drug disposal programs; and
5. Funding and training for first responders to participate in pre-arrest diversion programs,post-
overdose response teams, or similar strategies that connect at-risk individuals to behavioral health
services and supports.
H. Expanding Syringe Service Programs
1. Provide comprehensive syringe services programs with more wrap-around services including linkage
to OUD treatment, access to sterile syringes, and linkage to care and treatment of infectious diseases.
I. Evidence-based data collection and research analyzing the effectiveness of the abatement strategies
within the State.
2
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Schedule B
Approved Uses
PART ONE: TREATMENT
A. TREAT OPIOID USE DISORDER(OUD)
Support treatment of Opioid Use Disorder(OUD) and any co-occurring Substance Use Disorder or
Mental Health (SUD/MH) conditions through evidence-based or evidence-informed programs or
strategies that may include, but are not limited to,the following:'
1. Expand availability of treatment for OUD and any co-occurring SUD/MH conditions, including all
forms of Medication-Assisted Treatment (MAT) approved by the U.S. Food and Drug Administration.
2. Support and reimburse evidence-based services that adhere to the American Society of Addiction
Medicine (ASAM) continuum of care for OUD and any co-occurring SUD/MH conditions
3. Expand telehealth to increase access to treatment for OUD and any co-occurring SUD/MH
conditions, including MAT, as well as counseling,psychiatric support, and other treatment and
recovery support services.
4. Improve oversight of Opioid Treatment Programs (OTPs)to assure evidence-based or evidence-
informed practices such as adequate methadone dosing and low threshold approaches to treatment.
5. Support mobile intervention,treatment, and recovery services, offered by qualified professionals and
service providers, such as peer recovery coaches, for persons with OUD and any co-occurring
SUD/MH conditions and for persons who have experienced an opioid overdose.
6. Treatment of trauma for individuals with OUD (e.g.,violence, sexual assault,human trafficking, or
adverse childhood experiences) and family members (e.g., surviving family members after an overdose
or overdose fatality), and training of health care personnel to identify and address such trauma.
7. Support evidence-based withdrawal management services for people with OUD and any co-
occurring mental health conditions.
8. Training on MAT for health care providers, first responders, students, or other supporting
professionals, such as peer recovery coaches or recovery outreach specialists, including telementoring
to assist community-based providers in rural or underserved areas.
9. Support workforce development for addiction professionals who work with persons with OUD and
any co-occurring SUD/MH conditions.
10. Fellowships for addiction medicine specialists for direct patient care,instructors, and clinical
research for treatments.
11. Scholarships and supports for behavioral health practitioners or workers involved in addressing
OUD and any co-occurring SUD or mental health conditions, including but not limited to training,
2 As used in this Schedule B,words like"expand,"..fund,"..provide"or the like shall not indicate a preference for new or
existing programs. Priorities will be established through the mechanisms described in the Term Sheet.
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scholarships, fellowships, loan repayment programs, or other incentives for providers to work in rural
or underserved areas.
12. [Intentionally Blank—to be cleaned up later for numbering]
13. Provide funding and training for clinicians to obtain a waiver under the federal Drug Addiction
Treatment Act of 2000 (DATA 2000) to prescribe MAT for OUD, and provide technical assistance and
professional support to clinicians who have obtained a DATA 2000 waiver.
14. Dissemination of web-based training curricula, such as the American Academy of Addiction
Psychiatry's Provider Clinical Support Service-Opioids web-based training curriculum and
motivational interviewing.
15. Development and dissemination of new curricula, such as the American Academy of Addiction
Psychiatry's Provider Clinical Support Service for Medication-Assisted Treatment.
B. SUPPORT PEOPLE IN TREATMENT AND RECOVERY
Support people in treatment for or recovery from OUD and any co-occurring SUD/MH conditions
through evidence-based or evidence-informed programs or strategies that may include,but are not
limited to,the following:
1. Provide comprehensive wrap-around services to individuals with OUD and any co-occurring
SUD/MH conditions, including housing,transportation, education,job placement,job training, or
childcare.
2. Provide the full continuum of care of treatment and recovery services for OUD and any co-occurring
SUD/MH conditions, including supportive housing,peer support services and counseling, community
navigators, case management, and connections to community-based services.
3. Provide counseling,peer-support, recovery case management and residential treatment with access to
medications for those who need it to persons with OUD and any co-occurring SUD/MH conditions.
4. Provide access to housing for people with OUD and any co-occurring SUD/MH conditions,
including supportive housing,recovery housing,housing assistance programs,training for housing
providers, or recovery housing programs that allow or integrate FDA-approved medication with other
support services.
5. Provide community support services, including social and legal services, to assist in
deinstitutionalizing persons with OUD and any co-occurring SUD/MH conditions.
6. Support or expand peer-recovery centers,which may include support groups, social events, computer
access, or other services for persons with OUD and any co-occurring SUD/MH conditions.
7. Provide or support transportation to treatment or recovery programs or services for persons with
OUD and any co-occurring SUD/MH conditions.
8. Provide employment training or educational services for persons in treatment for or recovery from
OUD and any co-occurring SUD/MH conditions.
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9. Identify successful recovery programs such as physician,pilot, and college recovery programs, and
provide support and technical assistance to increase the number and capacity of high-quality programs
to help those in recovery.
10. Engage non-profits, faith-based communities, and community coalitions to support people in
treatment and recovery and to support family members in their efforts to support the person with OUD
in the family.
11. Training and development of procedures for government staff to appropriately interact and provide
social and other services to individuals with or in recovery from OUD, including reducing stigma.
12. Support stigma reduction efforts regarding treatment and support for persons with OUD, including
reducing the stigma on effective treatment.
13. Create or support culturally appropriate services and programs for persons with OUD and any co-
occurring SUD/MH conditions, including new Americans.
14. Create and/or support recovery high schools.
15. Hire or train behavioral health workers to provide or expand any of the services or supports listed
above.
C. CONNECT PEOPLE WHO NEED HELP TO THE HELP THEY NEED (CONNECTIONS
TO CARE)
Provide connections to care for people who have—or at risk of developing—OUD and any co-
occurring SUD/MH conditions through evidence-based or evidence-informed programs or strategies
that may include,but are not limited to,the following:
1. Ensure that health care providers are screening for OUD and other risk factors and know how to
appropriately counsel and treat (or refer if necessary) a patient for OUD treatment.
2. Fund Screening, Brief Intervention and Referral to Treatment (SBIRT)programs to reduce the
transition from use to disorders, including SBIRT services to pregnant women who are uninsured or not
eligible for Medicaid.
3. Provide training and long-term implementation of SBIRT in key systems (health, schools, colleges,
criminal justice, and probation), with a focus on youth and young adults when transition from misuse to
opioid disorder is common.
4. Purchase automated versions of SBIRT and support ongoing costs of the technology.
5. Expand services such as navigators and on-call teams to begin MAT in hospital emergency
departments.
6. Training for emergency room personnel treating opioid overdose patients on post-discharge planning,
including community referrals for MAT, recovery case management or support services.
7. Support hospital programs that transition persons with OUD and any co-occurring SUD/MH
conditions, or persons who have experienced an opioid overdose,into clinically-appropriate follow-up
care through a bridge clinic or similar approach.
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8. Support crisis stabilization centers that serve as an alternative to hospital emergency departments for
persons with OUD and any co-occurring SUD/MH conditions or persons that have experienced an
opioid overdose.
9. Support the work of Emergency Medical Systems, including peer support specialists,to connect
individuals to treatment or other appropriate services following an opioid overdose or other opioid-
related adverse event.
10. Provide funding for peer support specialists or recovery coaches in emergency departments, detox
facilities,recovery centers,recovery housing, or similar settings; offer services, supports, or
connections to care to persons with OUD and any co-occurring SUD/MH conditions or to persons who
have experienced an opioid overdose.
11. Expand warm hand-off services to transition to recovery services.
12. Create or support school-based contacts that parents can engage with to seek immediate treatment
services for their child; and support prevention, intervention, treatment, and recovery programs focused
on young people.
13. Develop and support best practices on addressing OUD in the workplace.
14. Support assistance programs for health care providers with OUD.
15. Engage non-profits and the faith community as a system to support outreach for treatment.
16. Support centralized call centers that provide information and connections to appropriate services
and supports for persons with OUD and any co-occurring SUD/MH conditions.
D. ADDRESS THE NEEDS OF CRIMINAL-JUSTICE-INVOLVED PERSONS
Address the needs of persons with OUD and any co-occurring SUD/MH conditions who are involved
in, are at risk of becoming involved in, or are transitioning out of the criminal justice system through
evidence-based or evidence-informed programs or strategies that may include, but are not limited to,
the following:
1. Support pre-arrest or pre-arraignment diversion and deflection strategies for persons with OUD and
any co-occurring SUD/MH conditions, including established strategies such as:
a. Self-referral strategies such as the Angel Programs or the Police Assisted Addiction Recovery
Initiative (PAARI);
b. Active outreach strategies such as the Drug Abuse Response Team (DART)model;
c. "Naloxone Plus" strategies,which work to ensure that individuals who have received
naloxone to reverse the effects of an overdose are then linked to treatment programs or other
appropriate services;
d. Officer prevention strategies, such as the Law Enforcement Assisted Diversion (LEAD)
model;
e. Officer intervention strategies such as the Leon County,Florida Adult Civil Citation Network
or the Chicago Westside Narcotics Diversion to Treatment Initiative; or
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f. Co-responder and/or alternative responder models to address OUD-related 911 calls with
greater SUD expertise
2. Support pre-trial services that connect individuals with OUD and any co-occurring SUD/MH
conditions to evidence-informed treatment, including MAT, and related services.
3. Support treatment and recovery courts that provide evidence-based options for persons with OUD
and any co-occurring SUD/MH conditions
4. Provide evidence-informed treatment, including MAT,recovery support,harm reduction, or other
appropriate services to individuals with OUD and any co-occurring SUD/MH conditions who are
incarcerated in jail or prison.
5. Provide evidence-informed treatment, including MAT,recovery support,harm reduction, or other
appropriate services to individuals with OUD and any co-occurring SUD/MH conditions who are
leaving jail or prison have recently left jail or prison, are on probation or parole, are under community
corrections supervision, or are in re-entry programs or facilities.
6. Support critical time interventions (CTI),particularly for individuals living with dual-diagnosis
OUD/serious mental illness, and services for individuals who face immediate risks and service needs
and risks upon release from correctional settings.
7. Provide training on best practices for addressing the needs of criminal justice-involved persons with
OUD and any co-occurring SUD/MH conditions to law enforcement, correctional, or judicial personnel
or to providers of treatment,recovery,harm reduction, case management, or other services offered in
connection with any of the strategies described in this section.
E. ADDRESS THE NEEDS OF PREGNANT OR PARENTING WOMEN AND THEIR
FAMILIES,INCLUDING BABIES WITH NEONATAL ABSTINENCE SYNDROME
Address the needs of pregnant or parenting women with OUD and any co-occurring SUD/MH
conditions, and the needs of their families, including babies with neonatal abstinence syndrome (NAS),
through evidence-based or evidence-informed programs or strategies that may include,but are not
limited to,the following:
1. Support evidence-based or evidence-informed treatment, including MAT,recovery services and
supports, and prevention services for pregnant women—or women who could become pregnant—who
have OUD and any co-occurring SUD/MH conditions, and other measures to educate and provide
support to families affected by Neonatal Abstinence Syndrome.
2. Expand comprehensive evidence-based treatment and recovery services, including MAT, for
uninsured women with OUD and any co-occurring SUD/MH conditions for up to 12 months
postpartum.
3. Training for obstetricians or other healthcare personnel that work with pregnant women and their
families regarding treatment of OUD and any co-occurring SUD/MH conditions.
4. Expand comprehensive evidence-based treatment and recovery support for NAS babies; expand
services for better continuum of care with infant-need dyad; expand long-term treatment and services
for medical monitoring of NAS babies and their families.
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115
5. Provide training to health care providers who work with pregnant or parenting women on best
practices for compliance with federal requirements that children born with Neonatal Abstinence
Syndrome get referred to appropriate services and receive a plan of safe care.
6. Child and family supports for parenting women with OUD and any co-occurring SUD/MH
conditions.
7. Enhanced family supports and child care services for parents with OUD and any co-occurring
SUD/MH conditions.
8. Provide enhanced support for children and family members suffering trauma as a result of addiction
in the family; and offer trauma-informed behavioral health treatment for adverse childhood events.
9. Offer home-based wrap-around services to persons with OUD and any co-occurring SUD/MH
conditions, including but not limited to parent skills training.
10. Support for Children's Services—Fund additional positions and services, including supportive
housing and other residential services,relating to children being removed from the home and/or placed
in foster care due to custodial opioid use.
PART TWO: PREVENTION
F. PREVENT OVER-PRESCRIBING AND ENSURE APPROPRIATE PRESCRIBING AND
DISPENSING OF OPIOIDS
Support efforts to prevent over-prescribing and ensure appropriate prescribing and dispensing of
opioids through evidence-based or evidence-informed programs or strategies that may include,but are
not limited to,the following:
1. Fund medical provider education and outreach regarding best prescribing practices for opioids
consistent with Guidelines for Prescribing Opioids for Chronic Pain from the U.S. Centers for Disease
Control and Prevention,including providers at hospitals (academic detailing).
2. Training for health care providers regarding safe and responsible opioid prescribing, dosing, and
tapering patients off opioids.
3. Continuing Medical Education (CME) on appropriate prescribing of opioids.
4. Support for non-opioid pain treatment alternatives, including training providers to offer or refer to
multi-modal, evidence-informed treatment of pain.
5. Support enhancements or improvements to Prescription Drug Monitoring Programs (PDMPs),
including but not limited to improvements that:
a. Increase the number of prescribers using PDMPs;
b. Improve point-of-care decision-making by increasing the quantity, quality, or format of data
available to prescribers using PDMPs,by improving the interface that prescribers use to access
PDMP data, or both; or
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116
c. Enable states to use PDMP data in support of surveillance or intervention strategies, including
MAT referrals and follow-up for individuals identified within PDMP data as likely to
experience OUD in a manner that complies with all relevant privacy and security laws and rules.
6. Ensuring PDMPs incorporate available overdose/naloxone deployment data, including the United
States Department of Transportation's Emergency Medical Technician overdose database in a manner
that complies with all relevant privacy and security laws and rules.
7. Increase electronic prescribing to prevent diversion or forgery.
8. Educate Dispensers on appropriate opioid dispensing.
G. PREVENT MISUSE OF OPIOIDS
Support efforts to discourage or prevent misuse of opioids through evidence-based or evidence-
informed programs or strategies that may include, but are not limited to,the following:
1. Fund media campaigns to prevent opioid misuse.
2. Corrective advertising or affirmative public education campaigns based on evidence.
3. Public education relating to drug disposal.
4. Drug take-back disposal or destruction programs.
5. Fund community anti-drug coalitions that engage in drug prevention efforts.
6. Support community coalitions in implementing evidence-informed prevention, such as reduced
social access and physical access, stigma reduction—including staffing, educational campaigns, support
for people in treatment or recovery, or training of coalitions in evidence-informed implementation,
including the Strategic Prevention Framework developed by the U.S. Substance Abuse and Mental
Health Services Administration (SAMHSA).
7. Engage non-profits and faith-based communities as systems to support prevention.
8. Fund evidence-based prevention programs in schools or evidence-informed school and community
education programs and campaigns for students, families, school employees, school athletic programs,
parent-teacher and student associations, and others.
9. School-based or youth-focused programs or strategies that have demonstrated effectiveness in
preventing drug misuse and seem likely to be effective in preventing the uptake and use of opioids.
10. Create of support community-based education or intervention services for families, youth, and
adolescents at risk for OUD and any co-occurring SUD/MH conditions.
11. Support evidence-informed programs or curricula to address mental health needs of young people
who may be at risk of misusing opioids or other drugs, including emotional modulation and resilience
skills.
12. Support greater access to mental health services and supports for young people, including services
and supports provided by school nurses,behavioral health workers or other school staff,to address
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mental health needs in young people that (when not properly addressed) increase the risk of opioid or
other drug misuse.
H. PREVENT OVERDOSE DEATHS AND OTHER HARMS (HARM REDUCTION)
Support efforts to prevent or reduce overdose deaths or other opioid-related harms through evidence-
based or evidence-informed programs or strategies that may include,but are not limited to, the
following:
1. Increase availability and distribution of naloxone and other drugs that treat overdoses for first
responders, overdose patients, individuals with OUD and their friends and family members, individuals
at high risk of overdose, schools, community navigators and outreach workers,persons being released
from jail or prison, or other members of the general public.
2. Public health entities provide free naloxone to anyone in the community
3. Training and education regarding naloxone and other drugs that treat overdoses for first responders,
overdose patients, patients taking opioids, families, schools, community support groups, and other
members of the general public.
4. Enable school nurses and other school staff to respond to opioid overdoses, and provide them with
naloxone, training, and support.
5. Expand, improve, or develop data tracking software and applications for overdoses/naloxone
revivals.
6. Public education relating to emergency responses to overdoses.
7. Public education relating to immunity and Good Samaritan laws.
8. Educate first responders regarding the existence and operation of immunity and Good Samaritan
laws.
9. Syringe service programs and other evidence-informed programs to reduce harms associated with
intravenous drug use, including supplies, staffing, space,peer support services,referrals to treatment,
fentanyl checking, connections to care, and the full range of harm reduction and treatment services
provided by these programs.
10. Expand access to testing and treatment for infectious diseases such as HIV and Hepatitis C resulting
from intravenous opioid use.
11. Support mobile units that offer or provide referrals to harm reduction services,treatment,recovery
supports, health care, or other appropriate services to persons that use opioids or persons with OUD and
any co-occurring SUD/MH conditions.
12. Provide training in harm reduction strategies to health care providers, students, peer recovery
coaches,recovery outreach specialists, or other professionals that provide care to persons who use
opioids or persons with OUD and any co-occurring SUD/MH conditions.
13. Support screening for fentanyl in routine clinical toxicology testing.
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PART THREE: OTHER STRATEGIES
L FIRST RESPONDERS
In addition to items in sections C, D, and H relating to first responders, support the following:
1. Educate law enforcement or other first responders regarding appropriate practices and precautions
when dealing with fentanyl or other drugs.
2. Provision of wellness and support services for first responders and others who experience secondary
trauma associated with opioid-related emergency events.
J. LEADERSHIP,PLANNING AND COORDINATION
Support efforts to provide leadership,planning, coordination, facilitation,training and technical
assistance to abate the opioid epidemic through activities,programs, or strategies that may include, but
are not limited to,the following:
1. Statewide, regional, local, or community regional planning to identify root causes of addiction and
overdose, goals for reducing harms related to the opioid epidemic, and areas and populations with the
greatest needs for treatment intervention services; to support training and technical assistance; or to
support other strategies to abate the opioid epidemic described in this opioid abatement strategy list.
2. A dashboard to share reports, recommendations, or plans to spend opioid settlement funds; to show
how opioid settlement funds have been spent; to report program or strategy outcomes; or to track, share,
or visualize key opioid-related or health-related indicators and supports as identified through
collaborative statewide,regional, local, or community processes.
3. Invest in infrastructure or staffing at government or not-for-profit agencies to support collaborative,
cross-system coordination with the purpose of preventing overprescribing, opioid misuse, or opioid
overdoses, treating those with OUD and any co-occurring SUD/MH conditions, supporting them in
treatment or recovery, connecting them to care, or implementing other strategies to abate the opioid
epidemic described in this opioid abatement strategy list.
4. Provide resources to staff government oversight and management of opioid abatement programs.
K. TRAINING
In addition to the training referred to throughout this document, support training to abate the opioid
epidemic through activities, programs, or strategies that may include,but are not limited to,the
following:
1. Provide funding for staff training or networking programs and services to improve the capability of
government, community, and not-for-profit entities to abate the opioid crisis.
2. Support infrastructure and staffing for collaborative cross-system coordination to prevent opioid
misuse,prevent overdoses, and treat those with OUD and any co-occurring SUD/MH conditions, or
implement other strategies to abate the opioid epidemic described in this opioid abatement strategy list
(e.g.,health care, primary care, pharmacies, PDMPs, etc.).
L. RESEARCH
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Support opioid abatement research that may include,but is not limited to,the following:
1. Monitoring, surveillance, data collection, and evaluation of programs and strategies described in this
opioid abatement strategy list.
2. Research non-opioid treatment of chronic pain.
3. Research on improved service delivery for modalities such as SBIRT that demonstrate promising but
mixed results in populations vulnerable to opioid use disorders.
4. Research on novel harm reduction and prevention efforts such as the provision of fentanyl test strips.
5. Research on innovative supply-side enforcement efforts such as improved detection of mail-based
delivery of synthetic opioids.
6. Expanded research on swift/certain/fair models to reduce and deter opioid misuse within criminal
justice populations that build upon promising approaches used to address other substances (e.g. Hawaii
HOPE and Dakota 24/7).
7. Epidemiological surveillance of OUD-related behaviors in critical populations including individuals
entering the criminal justice system, including but not limited to approaches modeled on the Arrestee
Drug Abuse Monitoring (ADAM) system.
8. Qualitative and quantitative research regarding public health risks and harm reduction opportunities
within illicit drug markets, including surveys of market participants who sell or distribute illicit opioids.
9. Geospatial analysis of access barriers to MAT and their association with treatment engagement and
treatment outcomes.
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RESOLUTION NO. [INSERT]
A Resolution authorizing [City/County] (herein referred to as this "Governmental Unit")to join
with the State of Florida and other local governmental units as a participant in the Florida Memorandum
of Understanding and Formal Agreements implementing a Unified Plan.
WHEREAS,the [City/County] has suffered harm from the opioid epidemic;
WHEREAS, the [City/County] recognizes that the entire State of Florida has suffered harm as a
result from the opioid epidemic;
WHEREAS, the State of Florida has filed an action pending in Pasco County, Florida, and a
number of Florida Cities and Counties have also filed an action In re:National Prescription Opiate
Litigation, MDL No. 2804 (N.D. Ohio) (the "Opioid Litigation") and [City/County] [is/is not] a litigating
participant in that action;
WHEREAS,the State of Florida and lawyers representing certain various local governments
involved in the Opioid Litigation have proposed a unified plan for the allocation and use of prospective
settlement dollars from opioid related litigation;
WHEREAS,the Florida Memorandum of Understanding (the "Florida Plan") sets forth sets forth
a framework of a unified plan for the proposed allocation and use of opioid settlement proceeds and it
is anticipated that formal agreements implementing the Florida Plan will be entered into at a future
date; and,
WHEREAS, participation in the Florida Plan by a large majority of Florida cities and counties will
materially increase the amount of funds to Florida and should improve Florida's relative bargaining
position during additional settlement negotiations;
WHEREAS, failure to participate in the Florida Plan will reduce funds available to the State,
[City/County], and every other Florida city and county;
NOW, THEREFORE, BE IT RESOLVED BY THIS GOVERNMENTAL UNIT:
SECTION 1.That this Governmental Unit finds that participation in the Florida Plan would be in
the best interest of the Governmental Unit and its citizens in that such a plan ensures that almost all of
the settlement funds go to abate and resolve the opioid epidemic and each and every city and county
receives funds for the harm that it has suffered.
SECTION 2.That this Governmental Unit hereby expresses its support of a unified plan for the
allocation and use of opioid settlement proceeds as generally described in the Florida Plan, attached
hereto as Exhibit "A."
SECTION 3.That [official name] is hereby expressly authorized to execute the Florida Plan in
substantially the form contained in Exhibit "A."
SECTION 4. That [official name] is hereby authorized to execute the any formal agreements
implementing a unified plan for the allocation and use of opioid settlement proceeds that is not
substantially inconsistent with the Florida Plan and this Resolution.
121
SECTION 5. That the Clerk be and hereby is instructed to record this Resolution in the
appropriate record book upon its adoption.
SECTION 6.The clerk of this Governmental Unit is hereby directed to furnish a certified copy of
this Ordinance/Resolution to the Florida
[Florida League of Cities/Florida Association of Counties]
Attorney General Ashley Moody
c\o John M. Guard
The Capitol,
PL-01
Tallahassee, FL 32399-1050
SECTION 7.This Resolution shall take effect immediately upon its adoption.
Adopted this day of, , 2021.
(Mayor/Commissioner/etc.)
ATTEST:
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AHC/NCSG/MSGE 06/04/20
CONFIDENTIAL SETTLEMENT,MEDIATION AND COMMON INTEREST MATERIALS
SUBJECT TO MEDIATION ORDER AND FRE 408: DO NOT COPY OR DISTRIBUTE
PURDUE PHARMA L.P.
ABATEMENT PLAN TERM SHEET
SUMMARY OF TERMS AND CONDITIONS
THIS TERM SHEET DOES NOT CONSTITUTE (NOR SHALL
IT BE CONSTRUED AS)AN OFFER,AGREEMENT OR COMMITMENT'
Issue Description
1. APPLICABILITY These terms (once agreed) shall apply to the allocation of value received
OF AGREEMENT under, and shall be incorporated into, any plan of reorganization (the
"Chapter 11 Plan") in the chapter 11 cases of Purdue Pharma L.P. and its
affiliates (collectively, "Purdue") pending in the U.S. Bankruptcy Court
for the Southern District of New York(the"Bankruptcy Court")between
the states, territories and the District of Columbia (each a "State") on the
one hand, each county, city, town, parish, village, municipality that
functions as a political subdivision under State law, or a governmental
entity that has the authority to bring Drug Dealer Liability Act ("DDLA
Claims") under State law (collectively, the "Local Governments"), and
each federally recognized Native American, Native Alaskan or American
Indian Tribe (each a"Tribe") on the other.
2. PURPOSE Virtually all creditors and the Court itself in the Purdue bankruptcy
recognize the need and value in developing a comprehensive abatement
strategy to address the opioid crisis as the most effective use of the funds
that can be derived from the Purdue estate (including without limitation
insurance proceeds and, if included in the Chapter 11 Plan, payments by
third-parties seeking releases). Because of the unique impact the crisis has
had throughout all regions of the country, and as repeatedly recognized by
Judge Drain, division of a substantial portion of the bankruptcy estate
should occur through an established governmental structure, with the use
of such funds strictly limited to abatement purposes as provided herein.2
'As a condition to participating in this abatement structure,the settlements that the states of Kentucky and
Oklahoma separately entered into with Purdue must be taken into account in any allocation to them or flowing
through them.Potential adjustments may include a different Government Participation Mechanism structure for the
disbursement of funds to benefit Local Governments in those states or some redirection of funds,which would still
be used solely for abatement purposes.
2 See, e.g., Hrg. Tr at 149:22-150:5 (Oct. 11,2019)(` "I would hope that those public health steps,once the difficult
allocation issues that the parties have addressed here,can be largely left up to the states and municipalities so that they
can use their own unique knowledge about their own citizens and how to address them. It may be that some states
think it's more of a law enforcement issue,i.e.interdicting illegal opioids at this point.Others may think education is
more important. Others may think treatment is more important."); id. At 175:24-176:6 ("1 also think, and again, I
didn't say this lightly, that my hope in the allocation process is that there would be an understanding between the
states and the municipalities and localities throughout the whole process that[,] subject to general guidelines on how
the money should be used,specific ways to use it would be left up to the states and the municipalities,with guidance
from the states primarily.");Hr'g Tr.At 165:3-165:14(Nov. 19, 2019) ("1 continue to believe that the states play a
major role in[the allocation]process.The role I'm envisioning for them is not one where they say we get everything.
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This approach recognizes that funding abatement efforts — which would
benefit most creditors and the public by reducing future effects of the crisis
through treatment and other programs — is a much more efficient use of
limited funds than dividing thin slices among all creditors with no
obligation to use it to abate the opioid crisis. Because maximizing
abatement of the opioid crisis requires coordination of efforts by all levels
of government, particularly when the abatement needs far exceed the
available funds,this structure requires a collaborative process between each
State and its Local Governments. This Term Sheet is intended to establish
the mechanisms for distribution and allocation of funds to States, Local
Governments and Tribes(the"Abatement Funds")to be incorporated into
the Chapter 11 Plan and any order approving the Chapter 11 Plan
(Abatement Funds net of the portion thereof allocated to a Tribal
Abatement Fund under Section 5 hereof are referred to herein as "Public
Funds"). The parties agree that 100%of the Public Funds distributed under
the Chapter 11 Plan shall be used to abate the opioid crisis. Specifically,
(i)no less than ninety five percent (95%)of the Public Funds distributed
under the Chapter 11 Plan shall be used for abatement of the opioid crisis
by funding opioid or substance use disorder related projects or programs
that fall within the list of uses in Schedule B (the "Approved Opioid
Abatement Uses"); (ii) priority shall be given to the core abatement
strategies ("Core Strategies") as identified on Schedule A; and (iii) no
more than five percent (5%) of the Public Funds may be used to fund
expenses incurred in administering the distributions for the Approved
Opioid Abatement Uses, including the process of selecting programs to
receive distributions of Public Funds for implementing those programs
and in connection with the Government Participation Mechanism'
("Allowed Administrative Expenses," and together with the Approved
Opioid Abatement Uses, "Approved Uses").4 Notwithstanding anything
in this term sheet that might imply to the contrary,projects or programs that
constitute Approved Opioid Abatement Uses may be provided by States,
State agencies, Local Governments, Local Government agencies or
nongovernmental parties and funded from Public Funds.
3. GENERAL NOTES The governmental entities maintain that the most beneficial and efficient
use of limited bankruptcy funds is to dedicate as large a portion as
ossible to abatement programs addressing the opioid crisis. If this
I think that should be clear and I think it is clear to them. But, rather, where they act— in the best principles of
federalism,for their state,the coordinator for the victims in their state.");Hr'g Tr.at 75:19-76:1(Jan.24,2020)("Even
if there ultimately is an allocation here—and there's not a deal now,obviously,at this point on a plan.But if there is
an allocation that leaves a substantial amount of the Debtors' value to the states and territories, one of the primary
benefits of a bankruptcy case is that the plan can lock in,perhaps only in general ways,but perhaps more in specific
ways,how the states use that money . . . .").
3 Capitalized terms not defined where first used shall have the meanings later ascribed to them in this Term Sheet.
4 Nothing in this term sheet is intended to,nor does it,limit or permit the ability of funds from the Purdue estate
(other than Public Funds)to be used to pay for legal fees and expenses incurred in anticipation of or during Purdue's
chapter I I case,or once confirmed,in implementing the Chapter I I Plan.
2
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approach is taken, the governmental entities involved in the mediation—
states, territories,tribes, counties, cities and others—would commit the
Public Funds allocated to them to such future abatement, in lieu of direct
payment for their claims.
a. Resolution of States' and Local Governments' claims under this
model presumes signoff by and support of the federal government,
including an agreement that the federal government will also forego
its past damages claims. Continued coordination with the federal
government therefore is necessary as this model is finalized.
b. This outline addresses the allocation of Abatement Funds among
governmental entities to provide abatement programs to the public
for the benefit of not only the governmental entities and their
constituents, but also a substantial number of other creditors. The
States and Local Governments welcome other,private-side creditor
groups to enter discussions concerning how such creditors may
participate in, contribute to and/or benefit from the government-
funded abatement programs contemplated herein in lieu of direct
payment on their claims for past damages.
c. In addition to providing abatement services, it is understood that,if
their claims are to be released in a reorganization plan, a portion of
the Purdue estate will also need to be dedicated to personal injury
claimants. A proposal regarding such claims is being developed
separately.
d. All Public Funds distributed from the Purdue bankruptcy estate as
part of this abatement structure shall be used only for such
Approved Uses. Compliance with these requirements shall be
verified through reporting, as set out in Section 8. This outline and
the terms herein are intended to apply solely to the use and
allocation of Public Funds in the Purdue Chapter 11 Plan, and do
not apply to the use or allocation of funds made available as the
result of judgments against or settlements with any party other than
those released as part of the Chapter 11 Plan.
4. DISBURSEMENT Disbursement of Abatement Funds
OF FUNDS The Bankruptcy Court shall appoint [a third-party administrator
("Administrator")] [Trustee(s)] who will perform the ministerial task of
overseeing distribution of all Abatement Funds, which will consist of all
assets transferred to such fund by way of the confirmed Chapter 11 Plan,
and any,growth,earnings,or revenues from such assets,as well as proceeds
from any future sale of such assets. The [Administrator] [Trustees] shall
distribute the Abatement Fund consistent with the Chapter 11 Plan and shall
provide to the Bankruptcy Court an annual report on such distributions.
[Points to be addressed regarding disbursements:
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• Trigger and timing for disbursements.
• Insert details to show how these funds shall be distributed for
abatement uses and that the funds will not flow into the state general
revenue accounts (unless constitutionally required and, in that
event, the funds shall still be disbursed for abatement uses as
required by the terms of the document), including possible
distribution to state points of contact and block grant recipients.
• Possible creation of template document for Abatement Funds
distribution requests.
• If trust mechanism is employed, trust location and governing law.]
5. ATTORNEYS' A separate fund will be established for attorneys' fees and litigation costs
FEES AND COSTS in the final bankruptcy plan. Agreement by the parties to this Abatement
FUND Plan Term Sheet is contingent upon the establishment of this fund and the
details of the fund, which are subject to further negotiation, including
without limitation the participants, amount, jurisdiction, oversight, and
administration. Participation in an abatement program, receipt of
abatement services or benefits will not affect, and specific percentages in
the abatement structure received by various parties will not determine, the
amount of fees and costs that may be recovered.
6. TRIBAL a. [X%] of the Abatement Funds will be allocated to a Tribal
ABATEMENT Abatement Fund and these funds will not be a part of the structure
FUNDING involving abatement programs funded by state and local
governments.
b. The Tribes are working on their proposal for allocation among
Tribes, which would be included as part of the overall abatement
plan.
c. The Tribes will use the tribal allocation of Abatement Funds for
programs on the approved list of abatement strategies (see
Schedule B)and also for culturally appropriate activities,practices,
' teachings or ceremonies that are,in the judgment of a tribe or tribal
` health organization, aimed at or supportive of remediation and
abatement of the opioid crisis within a tribal community.' The
Tribes will have a list of representative examples of such culturally
appropriate abatement strategies, practices and programs which is
attached as Schedule [ 1. The separate allocation of abatement
funding and illustrative list of culturally appropriate abatement
strategies recognizes that American Indian and Alaska Native
Tribes and the communities they serve possess unique cultural
histories, practices, wisdom, and needs that are highly relevant to
the health and well-being of American Indian and Alaska Native
s [NTD:Discuss how private claimants will be treated under Tribal Allocation,if at all.]
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people and that may play an important role in both individual and
public health efforts and responses in Native communities.
7. DIVISION OF Public Funds are allocated among the States,the District of Columbia and
PUBLIC FUNDS Territories in the percentages set forth on Schedule C.
Except as set forth below in section 7(C) for the District of Columbia and
Territories, each State's Schedule C share shall then be allocated within the
State in accordance with the following:
1. Statewide Agreement. Each State and its Local Governments
will have until [the later of 60 days from entry of an order
confirming the Chapter 11 Plan or the Effective Date of the
Chapter 11 Plan]6 (the "Agreement Date") to file with the
Bankruptcy Court an agreed-upon allocation or method for
allocating the Public Funds for that State dedicated only to
Approved Uses (each a "Statewide Abatement Agreement" or
"SAA"). Any State and its Local Governments that have reached
agreement before the Effective Date of the Chapter 11 Plan that
satisfies the metric for approval as described in the immediately
following paragraph shall file a notice with the Bankruptcy Court
that it has adopted a binding SAA and either include the SAA
with its filing or indicate where the SAA is publicly available for
the SAA to be effective for the Purdue Bankruptcy. Any dispute
regarding allocation within a State will be resolved as provided
by the Statewide Abatement Agreement.
A Statewide Abatement Agreement shall be agreed when it has
been approved by the State and either (a) representatives' of its
Local Governments whose aggregate Population Percentages,
determined as set forth below, total more than Sixty Percent
(60%), or (b) representatives of its Local Governments whose
aggregate Population Percentages total more than fifty percent
(50%) provided that these Local Governments also represent
15% or more of the State's counties or parishes(or, in the case of
States whose counties and parishes that do not function as Local
Governments, 15% of or more of the State's incorporated cities
or towns), by number.'
6 Should there be provision for extension of the date for filing Statewide Abatement Agreement?
An authorized"representative"of local,or even State,government can differ in this Tenn Sheet depending on the
context.
a All references to population in this Term Sheet shall refer to published U.S.Census Bureau population estimates
as of July 1,2019,released March 2020,and shall remain unchanged during the term of this agreement.These
estimates can currently be found at haps://www.census.gov/data/datasets/time-series/demo/popest/2010s-counties-
total.html
5
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Population Percentages shall be determined as follows:
For States with counties or parishes that function as Local
Governments,9 the Population Percentage of each county or
parish shall be deemed to be equal to (a) (1) 200% of the
population of such county or parish, minus (2) the aggregate
population of all Primary Incorporated Municipalities located in
such county or parish,10 divided by (b) 200% of the State's
population. A "Primary Incorporated Municipality" means a
city, town, village or other municipality incorporated under
applicable state law with a population of at least 25,000 that is
not located within another incorporated municipality The
Population Percentage of each primary incorporated municipality
shall be equal to its population (including the population of any
incorporated or unincorporated municipality located therein)
divided by 200% of the State's population; provided that the
Population Percentage of a primary incorporated municipality
that is not located within a county shall be equal to 200% of its
population (including the population of any incorporated or
unincorporated municipality located therein)divided by 200% of
the State's population. For all States that do not have counties or
parishes that function as Local Governments, the Population
Percentage of each incorporated municipality (including any
incorporated or unincorporated municipality located therein),
shall be equal to its population divided by the State's population.
The Statewide Abatement Agreement will become effective
within fourteen (14) days of filing, unless otherwise ordered by
the Bankruptcy Court.
A State and its Local Governments may revise, supplement, or
refine a Statewide Abatement Agreement by filing an amended
Statewide Abatement Agreement that has been approved by the
State and sufficient Local Governments to satisfy the approval
standards set forth above with the Bankruptcy Court,which shall
become effective within fourteen (14) days of filing, unless
otherwise ordered by the Bankruptcy Court.
2. Default Allocation Mechanism (excluding Territories and
DC addressed below). The Public Funds allocable to a State
that is not party to a Statewide Abatement Agreement as
defined in 7(1) above (each a "Non-SAA State") shall be
allocated as between the State and its Local Governments to be
9 The following states do not have counties or parishes that function as Local Governments: Alaska,Connecticut,
Massachusetts,Rhode Island,and Vermont[INSERT OTHERS]. All other States have counties or parishes that
function as Local Governments.
10 Discuss how to deal with cities and towns that straddle counties.
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used only for Approved Uses, in accordance with this Section
(B) (the"Default Allocation Mechanism").
a. Regions. Except as provided in the final sentence of this
paragraph, each Non-SAA State shall be divided into
"Regions" as follows: (a) each Qualifying Block
Grantee (as defined below) shall constitute a Region;
and (b) the balance of the State shall be divided into
Regions (such Regions to be designated by the State
agency with primary responsibility for substance abuse
disorder services employing to the maximum extent
practical, existing regions established in that State for
opioid abuse treatment or similar public health purposes);
such non-Qualifying Block Grantee Regions are
referred to herein as "Standard Regions"). The Non-
SAA States which have populations under 4 million and
do not have existing regions described in the foregoing
clause (b) shall not be required to establish Regions;"
such a State that does not establish Regions but which
does contain one or more Qualifying Block Grantees
shall be deemed to consist of one Region for each
Qualifying Block Grantee and one Standard Region
for the balance of the State.
b. Regional Apportionment. Public Funds shall be
allocated to each Non-SAA State, as defined in 7(1)
above, as (a) a Regional Apportionment or(b) a Non-
Regional Apportionment based on the amount of Public
Funds dispersed under a confirmed Chapter 11 Plan as
follows:
i. First$1 billion—70% Regional
Apportionment/30%Non-Regional
Apportionment
ii. $142.5 billion—64% Regional Apportionment
/36%Non-Regional Apportionment
iii. $2.5-$3.5 billion—60% Regional
Apportionment/40%Non-Regional
Apportionment
iv. Above $3.5 billion—50% Regional
Apportionment/50%Non-Regional
Apportionment
"To the extent they are not parties to a Statewide Abatement Agreement,the following States will qualify as a Non-
SAA State that does not have to establish Regions:Connecticut, Delaware,Hawai'i,Iowa,Maine,Nevada,New
Hampshire,New Mexico,Rhode Island,Vermont[INSERT OTHERS].
7
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c. Qualifying Block Grantee. A "Qualifying Local
Government" means a county or parish (or in the cases
of States that do not have counties or parishes that
function as political subdivision, a city), that(a) either(i)
has a population of 400,000 or more or(ii)in the case of
California has a population of 750,000 or more and (b)
has funded or otherwise manages an established, health
care and/or treatment infrastructure (e.g., health
department or similar agency)to evaluate,award,manage
and administer a Local Government Block Grant.12 A
Qualifying Local Government that elects to receive
Public Funds through Local Government Block Grants
is referred to herein as a Qualifying Block Grantee.13
d. Proportionate Shares of Regional Apportionment. As
used herein, the "Proportionate Share" of each Region
in each Non-SAA State shall be (a) for States in which
counties or parishes function as Local Governments, the
aggregate shares of the counties or parishes located in
such Region under the allocation model employed in
connection with the Purdue Bankruptcy (the "Allocation
Model"),14 divided by the aggregate shares for all
counties or parishes in the State under the Allocation
Model; and (b) for all other States, the aggregate shares
of the cities and towns in that Region under the
Allocation Model's intra-county allocation formula,
divided by the aggregate shares for all cities and towns 15
in the State under the Allocation Model.
e. Expenditure or Disbursement of Regional
Apportionment. Subject to 7(2)(i) below regarding
Allowed Administrative Expenses, all Regional
Apportionments shall be disbursed or expended in the
form of Local Government Block Grants or otherwise
for Approved Opioids Abatement Uses in the Standard
Regions of each Non-SAA State.
12 As noted in footnote 8,the population for each State shall refer to published U. S.Census Bureau population
estimates as of July 1,2019,released March 2020,and shall remain unchanged during the term of this agreement.
These estimates can currently be found at haps://www.census.gov/data/datasets/time-series/demo/popest/2010s-
counties-total.html
13 [NTD:Perhaps provide for a Qualifying Political Subdivision to expand to include neighboring areas that are part
of its metro area?]
14 Need to address whether to use the Negotiation Class Allocation Model or other metric to determine Proportionate
Share.
1s Should this be all cities and towns or only primary incorporated municipalities?
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f. Qualifying Block Grantees. Each Qualifying Block
Grantee shall receive its Regional Apportionment as a
block grant(a"Local Government Block Grant").
Local Government Block Grants shall be used only for
Approved Opioid Abatement Uses by the Qualifying
Block Grantee or for grants to organizations within its
jurisdiction for Approved Opioid Abatement Uses and
for Allowed Administrative Expenses in accordance
with 7(2)(i)below. Where a municipality located wholly
within a Qualifying Block Grantee would independently
qualify as a block grant recipient ("Independently
Qualifying Municipality"), the Qualifying Block
Grantee and Independently Qualifying Municipality
must make a substantial and good faith effort to reach
agreement on use of Abatement Funds as between the
qualifying jurisdictions. If the Independently
Qualifying Municipality and the Qualifying Block
Grantee cannot reach such an agreement on or before the
Agreement Date [or some later specified date], the
Qualifying Block Grantee will receive the Local
Government Block Grant for its full Proportionate
Share and commit programming expenditures to the
benefit of the Independently Qualifying Municipality
in general proportion to Proportionate Shares
(determined as provided in 7(2)(d) above) of the
municipalities within the Qualifying Block Grantee.
Notwithstanding the allocation of the Proportionate Share
of each Regional Apportionment to the Qualifying Block
Grantee, a Qualifying Block Grantee may choose to
contribute a portion of its Proportionate Share towards a
Statewide program.
" g. Standard Regions. The portions of each Regional
Apportionment not disbursed in the form of Local
Government Block Grants shall be expended
throughout the Standard Regions of each Non-SAA
State in accordance with 95%-105% of the respective
Proportionate Shares of such Standard Regions. Such
expenditures will be in a manner that will best address
Opioid abatement within the State as determined by the
State with the input, advice and recommendations of the
Government Participation Mechanism described in
Section 8 below. This regional spending requirement
may be met by delivering Approved Opioid Abatement
Use services or programs to a Standard Region or its
residents. Delivery of such services or programs can be
9
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accomplished directly or indirectly through many
different infrastructures and approaches, including
without limitation the following:
i. State agencies, including local offices;
ii. Local governments, including local government
health departments;
iii. State public hospital or health systems;
iv. Health care delivery districts;
v. Contracting with abatement service providers,
including nonprofit and commercial entities; or
vi. Awarding grants to local programs.
h. Expenditure or Disbursement of Public Funds Other
Than Regional Apportionment. All Public Funds
allocable to a Non-SAA State that are not included in the
State's Regional Apportionment shall be expended only
on Approved Uses. The expenditure of such funds shall
be at the direction of the State's lead agency (or other
point of contact designated by the State) and may be
expended on a statewide and/or localized manner,
including in the manners described in herein. Qualifying
Block Grantees will be eligible to participate in or
receive the benefits of any such expenditures on the same
basis as other Regions.
i. Allowed Administrative Expenses. Qualifying Block
Grantees States may use up to 5% of their Non-
Regional Apportionments plus 5% of the Regional
Apportionment not used to fund Local Government
Block Grants, for Allowed Administrative Expenses.
Qualifying Block Grantees may use up to 5% of their
Local Government Block Grants to fund their Allowed
Administrative Expenses.
3. Records. The State shall maintain records of abatement
expenditures and its required reporting will include data on
regional expenditures so it can be verified that the Regional
Distribution mechanism guarantees are being met.16 Qualifying
Block Grantees shall maintain records of abatement
expenditures and shall provide those records periodically to their
State for inclusion in the State's required periodic reporting, and
shall be subject to audit consistent with State law applicable to
the granting of State funds.
16 Additional records and reporting requirements?
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