HHS Is Asking for Public Comment on Addiction Policy. Harm Reduction Needs to Show Up.

A major HHS Request for Information has been published, and people working in harm reduction, treatment, recovery, housing, public health, peer support and drug policy should pay attention.

This is not a normal proposed rule.

There is no regulation text to mark up. There is no clean “support” or “oppose” box to check. Nobody is asking the public to comment on a specific sentence in the Code of Federal Regulations.

This is a Request for Information, often called an RFI. That means HHS is asking the public what research, programs, policies and ideas should guide future federal addiction, mental health, treatment and recovery policy.

That may sound like ordinary federal process. It is not.

An RFI does not usually change the law by itself. But it can shape what comes next. Agencies use RFIs to build a record before changing grant priorities, funding conditions, technical assistance, program guidance, reporting expectations and future policy.

That is why this matters.

HHS is not just asking a generic question about what works. This RFI comes at a moment when federal support for harm reduction is being narrowed, challenged and reframed.

The document discusses ending support for some SAMHSA funded harm reduction activities. It discusses moving homelessness systems away from harm reduction and Housing First. It highlights funding for sober and recovery housing models. It supports increased faith based provider involvement. It also points toward expanded Assisted Outpatient Treatment and civil commitment pathways.

The document does not create a new rule by itself. But it clearly points toward a federal funding strategy that favors more traditional treatment and recovery models while pushing harm reduction and Housing First to the margins.

So this is not just another comment opportunity.

This is an opportunity to speak directly into the federal record while harm reduction is actively being challenged at the funding and policy level.

That does not mean every comment needs to be angry. It means every comment should be useful, specific and grounded in evidence.

HHS is asking what works.

We should answer.

What HHS is asking about

The RFI is tied to the Great American Recovery Initiative. HHS is asking for public input on substance use prevention, treatment and recovery, mental health, co occurring substance use and mental health conditions, stigma, workforce shortages, data systems, emerging technologies and program evaluation.

Some of that is broad enough to sound harmless. Some of it could be useful.

The RFI points to better access to medications for opioid use disorder, rural behavioral health investments, targeted CCBHC expansion, Hepatitis C elimination, child welfare coordination, crisis system alignment and improved behavioral health data systems.

Those are not bad goals.

The problem is what sits beside them.

The same document that talks about Hepatitis C elimination also signals restrictions on harm reduction. The same document that talks about recovery also treats some lifesaving services as if they are obstacles to recovery. The same document that asks about stigma is connected to a policy framework that often describes people who use drugs through the language of crime, disorder and illegality.

That contradiction needs to be named.

You cannot seriously pursue Hepatitis C elimination while weakening the programs that reach people at highest risk.

You cannot seriously reduce overdose deaths while separating naloxone from the broader harm reduction infrastructure that gets naloxone into people’s hands.

You cannot seriously expand recovery while cutting off the low barrier services that keep people alive long enough to reach it.

And you cannot seriously reduce stigma while treating people who use drugs as a problem to be managed rather than people to be served.

Harm reduction and recovery are not enemies

One of the most dangerous ideas in addiction policy is the belief that harm reduction and recovery sit on opposite sides of the field.

They do not.

Syringe services, naloxone, drug checking, wound care, Hepatitis C prevention, low barrier outreach, peer support, medications for opioid use disorder, treatment, recovery housing, supportive housing and voluntary care all belong in the same continuum.

Not every person needs the same service at the same time.

That is not a flaw. That is reality.

Some people are ready for treatment today. Some are not. Some are using drugs and trying to stay alive. Some are using medications for opioid use disorder. Some are in abstinence based recovery. Some need housing before anything else can stabilize. Some need a peer before they will ever trust a clinic. Some need ten points of contact before they accept one referral.

Good policy understands that.

Bad policy picks one model, calls it morality and then acts surprised when people die outside the door.

Recovery is not protected by cutting people off from the services that keep them alive long enough to reach it.

Why this RFI matters

This RFI matters because HHS is asking the public what should count as effective addiction, mental health, treatment and recovery policy at the same time the Department is signaling a move away from federally supported harm reduction.

That creates risk. But it also creates an opening.

If the record is filled only with comments supporting narrow, compliance based, abstinence only or treatment first models, then future grant conditions and funding priorities may reflect that narrow record.

If the record includes strong comments from people who use drugs, people in recovery, families, syringe service programs, treatment providers, peer workers, housing advocates, researchers, public health leaders and community organizations, then HHS will have to confront the evidence that harm reduction is not the enemy of recovery.

It is often the bridge to it.

This is the moment to explain what happens when syringe services are restricted.

This is the moment to explain why naloxone, drug checking, wound care, Hepatitis C prevention, low barrier MOUD, outreach and housing are not fringe services.

This is the moment to explain why people do not enter care because systems shame them hard enough. They enter care when systems stay close enough to be useful.

And this is the moment to make clear that recovery is not defended by cutting people off from the services that keep them alive long enough to reach it.

HHS opened the record.

Now harm reduction needs to be in it.

Who should comment

People who use drugs should comment.

People in recovery should comment.

Families should comment.

Syringe service programs should comment.

Treatment providers should comment.

Peer workers should comment.

Housing advocates should comment.

Researchers should comment.

Public health workers should comment.

Community based organizations should comment.

Faith leaders who support evidence based care should comment.

Rural providers should comment.

Anyone who has seen what happens when systems wait for people to become “ready” before offering help should comment.

You do not have to answer every question. You do not have to be a lawyer. You do not have to write a dissertation. Thankfully, federal cosplay is not mandatory.

But you should be specific.

Tell HHS what works.

Tell HHS what happens when harm reduction is defunded.

Tell HHS how people actually enter care.

Tell HHS why low barrier services matter.

Tell HHS why MOUD is recovery.

Tell HHS why Housing First, recovery housing and supportive housing should be treated as parts of a continuum instead of forced into a fake competition.

Tell HHS why Hepatitis C prevention cannot be separated from syringe access, outreach and trust based engagement.

Tell HHS why people with lived and living experience need to be involved in program design, implementation and evaluation.

Tell HHS why stigma is not reduced by describing people who use drugs primarily through the language of crime, disorder and illegality.

And tell HHS what you want it to do.

What to recommend

Preserve federal support for evidence based harm reduction, including syringe services, naloxone, drug checking, wound care, infectious disease prevention and low barrier outreach.

Protect access to all FDA approved medications for opioid use disorder and make clear that MOUD is recovery.

Support Housing First, recovery housing and supportive housing as part of a full housing continuum instead of forcing communities into one model.

Ensure any Assisted Outpatient Treatment or civil commitment funding includes due process, voluntary care first, access to counsel, peer support and strong civil rights protections.

Include people with lived and living experience, including people who use drugs, in program design, implementation and evaluation.

Use data and artificial intelligence to improve care and accountability, not to create surveillance systems that punish people for being poor, sick or hard to reach.

Align Hepatitis C elimination efforts with the harm reduction programs that actually reach people at highest risk.

Require federally funded recovery housing programs to comply with nondiscrimination protections for people taking prescribed medications for opioid use disorder.

Support the peer workforce without excluding people who have lived experience outside traditional abstinence based recovery pathways.

Measure outcomes that matter, including survival, housing stability, treatment access, patient experience, reduced infectious disease transmission, reduced overdose and voluntary engagement in care.

HHS Request for Comment on Chronic Disease of Addiction

How to submit comments

Email comments to:

REPORTSCLEARANCEOFFICER@ahrq.hhs.gov

Use this subject line:

Great American Recovery

Deadline:

July 5, 2026

What to include

1. Your name and organization, if you are submitting on behalf of one.

2. A short explanation of your experience with addiction, mental health, recovery, harm reduction, treatment, housing, peer support, public health or related services.

3. Your main recommendations.

4. Evidence, examples, research links or data, if you have them.

5. A clear request for what HHS should do.

Do not include protected health information, private client information or anything confidential that you would not want made public.

A simple comment structure

Opening:

I am submitting comments in response to the HHS Request for Information on Chronic Disease of Addiction and the Great American Recovery Initiative.

Experience:

Briefly explain who you are and why this issue matters to you.

Main point:

HHS should support the full continuum of evidence based prevention, treatment, recovery and harm reduction services.

Recommendations:

List two to five specific recommendations. Keep them clear. Tie them to your experience, your data or the people your organization serves.

Closing:

HHS should fund what works, measure what matters and avoid using federal grant policy to separate treatment, recovery and harm reduction when communities need all three.

The bottom line

This RFI is not the final battle over federal addiction policy.

It is not a proposed rule.

It does not immediately change the law.

But it matters because it helps shape the policy record.

And if HHS is going to build a record, then the record needs to include the truth.

Harm reduction keeps people alive.

MOUD is recovery.

Housing saves lives.

Voluntary care works better when it is actually available.

People with lived and living experience are not decorative.

Data should improve care, not punish people for needing it.

And recovery is not strengthened by cutting off the very services that help people survive long enough to find it.

This is not the time for the harm reduction field to sit back and hope someone else explains the work.

The RFI gives us a public record, a deadline and a direct invitation to answer.

We should use it.