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News
Substance Use Disorder (SUD) ASAM level of care 2.5 - partial hospitalization provider requirements
Enrolled Minnesota Health Care Programs (MHCP) providers offering substance use disorder outpatient services can apply to offer ASAM level of care 2.5 - partial hospitalization starting Jan. 1, 2025. The Centers for Medicare & Medicaid Services approved the ASAM level of care 2.5 - partial hospitalization for MHCP. Complete the following steps to comply with Minnesota Department of Human Services (DHS) requirements to provide ASAM level of care 2.5:
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ASAM level of care 2.5 provides intensive, multidisciplinary care of 20 or more hours of skilled treatment services for individuals with substance use and co-occurring disorders. ASAM level of care 2.5 emphasizes evidence-based practices such as comprehensive assessments, individualized treatment plans, integrated care, and participation in utilization management reviews. Refer to the ASAM Criteria, 3rd Edition for level of care placement criteria for ASAM level of care 2.5.
The Behavioral Health Administration (BHA) at DHS may contact providers after enrollment to ensure that ASAM level of care 2.5 criteria are appropriately reflected in your provider policies and procedures.
BHA will communicate plans to provide technical assistance and training to support implementation over the coming months. Email sud.direct.access.dhs@state.mn.us with questions about this message.
Substance Use Disorder (SUD) facilities required to certify an ASAM level of care
American Society of Addiction Medicine (ASAM) levels of care become effective in Minnesota state law on Jan. 1, 2025. Minnesota nonresidential SUD treatment providers licensed by the Department of Human Services (DHS) and enrolled in Minnesota Health Care Programs (MHCP) must certify their ASAM level of care by Jan. 1, 2025, under Minnesota Statutes 256B.0759, subd. 2.
If you have not certified your level(s) of care by the Jan. 1, 2025, deadline, your program will become ineligible for payment for services provided under Minnesota Health Care Programs (MHCP).
Follow the certification instructions under the “How to Enroll” tab on the 1115 Substance Use Disorder (SUD) System Reform Demonstration webpage.
You must have the 245G.20 designation for Serving Persons with Co-Occurring Disorders. If you do not currently hold this designation, contact your DHS licensor or email SUD licensing at dhs.mhcdlicensing@state.mn.us.
Tribally licensed providers may elect to participate in the demonstration.
ASSISTANCE AVAILABLE:
We are available to schedule meetings with providers via Webex outside of Virtual Office Hours as needed.
Substance use disorder providers invited to attend ASAM trainings
The Department of Human Services invites Minnesota substance use disorder treatment providers to participate in ongoing trainings offered by Acentra Health. The trainings will help improve clinical documentation, explain the utilization management ANG (Atrezzo) Provider Portal and increase ASAM knowledge and effective implementation. Follow links below for upcoming trainings.
Monthly Portal Training & Office Hours
Friday, Oct. 11 at 11 a.m. CST
Friday, Nov. 8 at 11 a.m. CST
ASAM Monthly Lunch & Learn Training Meeting
1115 substance use disorder (SUD) System Reform Demonstration Enrollment and Clinical virtual office hours available on Thursdays
1115 SUD System Reform Demonstration Certification and Clinical virtual office hours are being held Thursdays from 2 to 3 p.m. Office hours focus on American Society of Addiction Medicine (ASAM) criteria, level of care certification and clinical questions. Behavioral Health staff members are available to answer drop-in questions.
Thursday office hours meeting link
Additional office hours will be held on the following dates:
- Mondays starting Aug. 12 thru Sept. 30, 3 p.m. - 4 p.m.
- Wednesdays starting Aug. 21 thru Oct. 2, 11 a.m. - 12 p.m.
Contact
Send your questions about the 1115 Substance Use Disorder System Reform Demonstration to 1115demonstration.dhs@state.mn.us.
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1115 Substance Use Disorder (SUD) System Reform federal demonstration project
Minnesota is piloting a new approach to strengthen the state’s behavioral health care system by improving access to substance use disorder treatment across the state for Medicaid recipients. The state is doing this under the 1115 Substance Use Disorder (SUD) System Reform Demonstration. The Centers for Medicare and Medicaid Services (CMS) uses 1115 SUD Demonstrations to expand access to high quality, clinically appropriate SUD treatment using American Society for Addiction Medicine (ASAM) levels of care. Providers enrolled in the Demonstration comply with the ASAM Criteria and are eligible for funding incentives.
Minnesota’s 1115 Demonstration (“the Demonstration”) breaks down into two main areas:
- Increase the use of the American Society of Addiction Medicine’s (ASAM) Criteria in SUD treatment and placement.
- Expand state Medical Assistance (MA) coverage to Institutions for Mental Disease (IMDs), residential facilities with more than 16 beds.
SUD providers licensed under Minnesota Statute 245G or 245F and enrolled in MHCP are eligible to enroll in the Demonstration. Out-of-state providers who are enrolled in MHCP are also able to enroll in the 1115 Demonstration.
By expanding the use of the ASAM Criteria and expanding MA coverage to IMDs, Minnesota’s goal is to address the six federal goals and objectives:
- Increased rates of identification, initiation and engagement in treatment for Opioid Use Disorders (OUD) and other SUDs
- Increased adherence to, and retention in, treatment for OUD and other SUDs
- Reductions in overdose deaths, particularly those due to opioids
- Reduced utilization of emergency departments and inpatient hospital settings for OUD and other SUD treatment when the utilization is preventable or medically inappropriate, through improved access to more appropriate services available through the continuum of care
- Fewer readmissions to the same or higher level of care for readmissions that are preventable or medically inappropriate
- Improved access to care for physical health conditions among beneficiaries with SUDs
Components of the 1115 Demonstration
ASAM Criteria/Level of Care Requirements
The ASAM Criteria is the nation’s most widely used set of guidelines for people with SUD and co-occurring disorders. The Demonstration is implementing the ASAM Criteria to create a long-term chronic disease model that uses the evidence-based treatment methods. The Demonstration’s Level of Care Requirements incorporate ASAM Criteria.
SUD providers must implement the Level of Care Requirements into their policies and procedures in order to participate in the 1115 Demonstration. The Level of Care Requirements include patient referral arrangement agreements (PRAAs) for ASAM Levels of Care that providers don’t offer, medications for opioid use disorder (MOUD) access for residential providers, as well as medical, psychiatric, psychological and toxicology consultation and referrals. Overall, the goal is for people receive the right level of care at the right time.
Medications for Opioid Use Disorder
MOUD is an important component of person-centered and evidence-based treatment and in meeting the six CMS goals and objectives of the Demonstration. Minnesota DHS supports and encourages the use of all FDA-approved MOUD as part of an evidence-based, person-centered approach to treating OUD. DHS is dedicated to providing high-quality, effective individualized care to all Minnesotans seeking treatment.
Access to all forms of MOUD is an essential component for equitable access and success of treatment. In order to increase access to evidence-based treatment and promote equitable treatment, DHS encourages providers to accept clients receiving any FDA-approved MOUD.
Rate Enhancements
Residential and outpatient providers who enroll in the Demonstration are eligible for rate enhancements for services delivered to Medical Assistance (MA) fee-for-service (FFS) and Managed Care Organizations (MCOs) recipients. CMS approved rate enhancements from the 2021 1st Special Session as follows:
- 20% rate enhancement over the base rate for outpatient SUD providers
- 25% rate enhancement over the base rate for residential SUD providers
These rate enhancements are effective for dates of service on or after Jan. 1, 2022. There are no rate enhancements for withdrawal management providers or hospitals. The MHCP SUD Provider Manual contains more information on rates and billing.
Utilization Management
CMS requires Minnesota to implement utilization management processes to assure beneficiaries receive SUD treatment at the appropriate level of care, interventions are appropriate for the diagnosis and include an independent process for reviewing residential treatment placements, in particular, the types of services, hours of clinical care and credentials of staff.
SUD providers enrolled in the Demonstration are required to follow the utilization management process. DHS has collaborated with Kepro for the FFS utilization management process. MCOs are required to align with the FFS UM process and ASAM Criteria.
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Federal Background
What are 1115 Demonstrations/Waivers?
Section 1115 of the Social Security Act allows the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) to approve demonstration projects that are likely to improve state Medicaid programs (“Medical Assistance” in Minnesota). CMS waives certain federal requirements in 1115 Demonstrations in order to test new or existing ways to deliver and pay for health care services. States must apply to CMS to implement 1115 Demonstrations. After approval, CMS monitors the implementation progress and impacts on clients, providers, health plans and state agencies.
1115 SUD Demonstrations
In 2015, CMS announced an opportunity for state Medicaid agencies to apply for 1115 Demonstrations to address the opioid crisis. In 2017, they announced a revision that streamlined the process for states to implement a SUD-focused 1115 Demonstration.
States were instructed to improve access to high quality, clinically appropriate treatment for SUD. Specifically, improvements were to be made through the implementation of evidence-based treatment guidelines, such as the American Society of Addiction Medicine (ASAM) Criteria and by covering critical levels of care, Medication for Opioid Use Disorder (MOUD) and withdrawal management. States are able to receive federal financial participation (FFP) for services provided in Institutions for Mental Diseases (IMDs), defined as residential facilities with more than 16 beds. Federal laws typically exclude IMDs from Medicaid reimbursement.
CMS Goals and Objectives
CMS established six goals and objectives for all 1115 SUD Demonstrations:
- Increased rates of identification, initiation and engagement in treatment for Opioid Use Disorders (OUD) and other SUDs
- Increased adherence to, and retention in, treatment for OUD and other SUDs
- Reductions in overdose deaths, particularly those due to opioids
- Reduced utilization of emergency departments and inpatient hospital settings for OUD and other SUD treatment when the utilization is preventable or medically inappropriate, through improved access to more appropriate services available through the continuum of care
- Fewer readmissions to the same or higher level of care for readmissions that are preventable or medically inappropriate
- Improved access to care for physical health conditions among beneficiaries with SUDs
State Implementation
Minnesota has been moving towards an SUD treatment system aligned with a chronic disease model for SUD for 20 years. DHS’ 1993-99 The challenges and benefits of chemical dependency treatment study’s key recommendation was to create an SUD continuum of care consistent with chronic disease management. In 2013 Minnesota’s Model of Care for SUD Legislative Report (DHS-6708) recommended updating Minnesota’s treatment system from an acute episodic model, to a chronic, longitudinal model of health care.
In 2016, the Minnesota Legislature directed the Department of Human Services (DHS) to design an SUD system with a full continuum of services available to all Minnesotans (MN Section 254B.15). The streamlined 1115 SUD Demonstrations gave Minnesota the opportunity to implement the recommended changes. In March 2018, DHS submitted an SUD demonstration request to CMS.
Legislation enacted in 2019 provided DHS the resources to implement the demonstration (MN Section 256B.0759). Minnesota’s Demonstration application was approved by CMS in June 2019. Minnesota couldn’t receive FFP or begin implementation until CMS approved the Implementation Plan. On July 22, 2020, CMS approved the state’s original Implementation Plan and Special Terms & Conditions (STCs) , marking the official start of Minnesota’s 1115 Demonstration (“the Demonstration”). The STCs are the state’s contract with CMS during the Demonstration.
Updates to the Implementation Plan as a result of the 2021 legislation, as well as the state’s evaluation design plan completed by DHS’ independent evaluator, NORC at the University of Chicago, were approved by CMS on July 28, 2021.
The Implementation Plan provides the details necessary to operationalize the Demonstration’s in six federal-required milestones:
- Access to critical levels of care for SUDs
- Widespread use of evidence-based, SUD-specific patient placement criteria
- Use of nationally recognized, evidence-based SUD program standards to set residential treatment provider qualifications
- Sufficient provider capacity at each level of care, including medication assisted treatment (MAT)
- Implementation of comprehensive treatment and prevention strategies to address opioid abuse and OUD
- Improved care coordination and transitions between levels of care
The Demonstration is scheduled to run until June 30, 2024; however, Minnesota state statute requires DHS to apply for an extension. The extension request is due to be submitted to CMS by June 30, 2023.
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How to Enroll
The following SUD providers are required to enroll in the 1115 Demonstration by January 1, 2024:
- Minnesota residential treatment programs licensed by the Department of Human Services (DHS) and enrolled in Minnesota Health Care Programs (MHCP)
- Minnesota Withdrawal management programs licensed by DHS and enrolled in MHCP
- Out-of-state residential SUD providers enrolled in MHCP
Outpatient SUD providers and tribally licensed providers may elect to participate. This in accordance with Minnesota Statute 256B.0759 Subd. 2.
Step 1— Office Hours
Attend virtual office hours before filling out the 1115 Demonstration enrollment application. Virtual office hours are drop-in based and focus on enrollment and clinical questions. The Reform and Redesign Team who helps facilitate the Demonstration for DHS, encourages providers at all stages of enrollment to attend and will tailor each session to the attendee(s)’ questions.
- Virtual office hours are hosted weekly via WebEx on Thursday’s 2-3 p.m. Updated times, dates and meeting links are available on the “News” tab.
Step 2 — PRAAs
Obtain all necessary Patient Referral Arrangement Agreements (PRAAs). Providers participating in the 1115 Demonstration are required to have PRAAs for the American Society of Addiction Medicine (ASAM) Levels of Care not offered at participating location(s).
- Providers must use the Patient Referral Arrangement Agreements (DHS-7308-ENG) form and submit the form via email with the completed 1115 Demonstration enrollment application and other documentation (Step 3).
- PRAAs must be with enrolled providers or providers in the process of enrolling.
The “Approved Locations” tab lists all approved providers by level of care, name, and address with contact information to assist providers in arranging PRAAs.
- Note: Vinland National Center is the only Level 3.3 Clinically Managed Population-Specific High-Intensity Residential program in Minnesota.
Step 3 — Licensure
SUD providers must have all necessary licensure before beginning the 1115 Demonstration enrollment application.
- Minnesota providers must have 245G or 245F licensure and be enrolled as a Minnesota Health Care Program (MHCP) provider.
- Minnesota providers with 245G licensure must obtain 245G.20 “Specializing in the Treatment of Persons with a Substance Use Disorder and Mental Health Disorder.”
If one of the licenses is missing, work with DHS Licensing to obtain necessary licensing requirements
Out-of-state and tribal nation providers with applicable licensure and enrolled in MCHP may also participate in the 1115 Demonstration. Email 1115demonstration.dhs@state.mn.us for technical assistance with the enrollment application.
Step 4 – Levels of Care
Open the ASAM Certification Checklist (DHS-7325-ENG) from your downloads folder.
For additional programs, additional levels of care or secondary locations:
- The 1115 Demonstration must have an updated and signed ASAM Certification Checklist that includes the program, ASAM level of care or secondary location
- Providers may create a new ASAM Certification Checklist or edit and update a previously submitted ASAM Certification Checklist. Please follow these steps:
1.) On page two of the checklist, click on gray box reading “Add location” on the right side of the screen
2.) Complete the required fields for the location and/or level of care being added
3.) Update the signature and date fields at bottom of page
4.) Submit completed ASAM Certification Checklist to 1115demonstration.dhs@state.mn.us
Choose the “Level(s) of Care at this Location” in the 1115 Enrollment Application (DHS-7325-ENG) to show the relevant requirements for each Level of Care.
The 1115 Level of Care Requirements (DHS-7326-ENG) are the federally approved requirements for enrolling in the 1115 Demonstration.
Step 5 – Update Policies & Procedures
Update relevant policies and procedures to incorporate the 1115 Level of Care Requirements. Add the program policy and procedure page number to the column of the 1115 enrollment application requesting a brief description.
- Residential providers are also required to submit their Medications for Opioid Use Disorder (MOUDs) policies or other evidence describing how MAT is offered either on-site or referrals to facilitate access off-site. See the 1115 Demonstration Medication-Assisted Treatment (MAT) Policy for more information.
Providers must have all the requirements implemented in their policies and procedures before enrolling in the 1115 Demonstration. The Reform and Redesign Team cannot approve providers to enroll until all Level of Care Requirements are implemented.
Step 6 – Submit Application & Supporting Materials
Submit signed and dated 1115 Enrollment Application, updated relevant policies and procedures, PRAAs, and MOUD Policy (residential providers only) to 1115demonstration.dhs@state.mn.us.
- The Reform and Redesign Team will reply once the application has been received.
- If the Reform and Redesign Team hasn’t replied within 5 business days, please follow up in a separate email with no attachment.
Reviewing request for more information (RFMI) submissions will take priority over first time submissions (see Step 7).
Step 7 – Application Review
The Reform and Redesign Team reviews application and sends the necessary follow-up communication.
- Incomplete letter: missing at least one item from Steps 1-5
- Request for meeting with Reform and Redesign Team: missing 4 or more items the application
- Request for More Information (RFMI) Letter: less than 4 items are missing from the application
If the Reform and Redesign Team does not hear back from providers after sending a RFMI Letter, they will follow up to check in on the progress. If there’s no response, the Team will move the application to “inactive” status. Inactive status means the application is no longer prioritized over new submissions.
Step 8 – Assurance Statement and Final Approval
The Reform and Redesign Team will send an “Approval to Enroll” letter via email once all requirements are met. Providers are not enrolled until they:
- Submit their Assurance Statement (DHS-7323-ENG) and “Approval to Enroll” letter to PEC through the Minnesota Provider and Screening Enrollment (MPSE) portal or via fax, 651-431-7504.
- NOTE: Providers will not receive the 1115 Demonstration rate enhancements until their Assurance Statement is processed.
- Open an Atrezzo portal account through Kepro, the 1115 Demonstration’s utilization management partner, for utilization management.
- Email the 1115 Kepro email, kepro1115sud@kepro.com, to open an Atrezzo Portal for utilization management submission. Utilization management is a federal requirement for the 1115 Demonstration.
- Kepro, hosts monthly trainings on the Atrezzo Portal and utilization management in the 1115 Demonstration. See Kepro’s MHCP website for more information.
Providers will be eligible for rate enhancements beginning on the date identified on their approval to enroll letter from the Behavioral Health Division.
ADDENDUM: To add an additional program and/or a level of care after enrollment:
The 1115 Demonstration must have an updated and signed application that includes the information of the program and/or level of care they want to add.
Providers may create a new application document or edit and update a previous version of the 1115 Demonstration Enrollment Application. To do this, follow these steps:
- On page 2 of the application, click on gray box reading “Add location” on the right side of the screen.
- Complete the required fields for the location and/or level of care being added.
- Update the signature and date fields at bottom of page.
If documentation for your other enrolled programs providing the same levels of care has already been submitted, you do not need to resubmit, as long as there are no updates.
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Locations approved to enroll in the 1115 Demonstration
NOTE: clicking on the link below will download the file. You may need to open your downloaded files to view the list.
The substance use disorder (SUD) treatment locations listed in the 1115 Demonstration Approved Locations have been approved to participate in the 1115 SUD System Reform Demonstration. You can use the contact information to make Patient Referral Arrangement Agreements as needed.
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Trainings
Policy and operations experts will offer support to demonstration providers through the use of presentations and special training events that are specific to the 1115 SUD System Reform Demonstration.
Questions sent to 1115demonstration.dhs@state.mn.us will be reviewed and presentations will be designed around themes whenever provider feedback supports a training session.
Questions? Contact 1115demonstration.dhs@state.mn.us.
American Society of Addiction Medicine (ASAM) training
The Behavioral Health Administration is collaborating with Great Lakes Addiction Technology Transfer Center Network (ATTC), the University of Nevada, Reno Center for the Application of Substance Abuse Technologies (UNR-CASAT) and the National Frontier and Rural Telehealth Education Center (NFARtec) to offer ASAM training:
- American Society of Addiction Medicine: Navigating Levels of Care
SUD providers interested or planning to enroll in the 1115 SUD System Reform Demonstration are encouraged to participate in ASAM trainings.
Additional ASAM resources
On-the-Spot: ASAM Integration and Application – Am I doing this right? | Addiction Technology Transfer Center (ATTC) Network (attcnetwork.org)
ASAM - American Society of Addiction Medicine
Utilization Management training
The Behavioral Health Administration is partnering with Kepro to implement the federally required utilization management and review process for participating 1115 Demonstration providers. This is a required component for participation and a part of the approved Implementation Plan.
For more information, visit Kepro’s Minnesota Health Care Programs website.
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Reports
Reporting is an important component of the Demonstration. Federal authority gives Minnesota additional flexibility to design and improve their SUD Medicaid program. Due to the added flexibility, the Centers for Medicare and Medicaid Services (CMS) has specific reporting and evaluation requirements. In addition to federal requirements, DHS is conducting ongoing stakeholder engagement.
Federal Deliverables
Federally required reports are published on DHS’ Federal health care waivers webpage within 30 days of CMS approval.
Quarterly Annual Monitoring Reports
DHS submits three quarterly reports and one annual report to CMS each year of the Demonstration. These reports include operational updates, performance metrics, financial reporting, evaluation activities and interim findings and SUD Health IT updates. Performance Metrics incorporate 35 claims-based measures to track trends related to the six goals and objectives of the Demonstration.
Independent Evaluation
As part of the Special Terms and Conditions to CMS, DHS is required to work with an independent evaluator to evaluate the Demonstration’s implementation and impact on the six goals and objectives. DHS has partnered with the National Opinion Research Center (NORC) to conduct the independent evaluation. The evaluation process includes the following:
Annual Public Comment Forum
DHS is required to host annual public comment forums throughout the Demonstration. Public comment forums offer the public an opportunity to give feedback on the progress of the Demonstration.
Provider Capacity Assessment (PCA)
In this report NORC assess the baseline provider capacity and availability of provider organizations for SUD treatment for Medical Assistance enrollees. This study used information from Jul. 1, 2018 to Jun. 30, 2019.
Provider Capacity Assessment: Baseline Assessment (DHS-8278)
Medication-assisted treatment (MAT) Access Report
Access to MAT, now referred to as Medication for Opioid Use Disorder (MOUD), is an important component of the ASAM Criteria. Although not federally required, NORC conducted an analysis of MOUD access across Minnesota to assess for potential disparities among different communities.
Examining Potential Disparities in Medication-Assisted Treatment (DHS-8267)
Early Adopters Report
DHS worked with eight different SUD providers to gather feedback on the Demonstration implementation. Topics of discussion include strengths, barriers, areas for improvement, as well as recommendations for SUD system alignments.
1115 Substance Use Disorder System Reform Demonstration Early Adopters Report (DHS-8234-ENG)
Evaluation Design Plan
A condition of participation in 1115 SUD demonstrations is that DHS arrange with an independent party to conduct an evaluation of the demonstration to ensure that the necessary data is collected at the level of detail needed to research the intended outcomes of the demonstration. The state must require the independent party to sign an agreement that the independent party will conduct the evaluation in an independent manner and according to CMS’ Special Terms and Conditions and Evaluation Design Plan Template. DHS contracted with NORC at the University of Chicago (NORC) to serve as the independent evaluator for the demonstration. CMS approved NORC’s Evaluation Design Plan on Jul. 28, 2021.
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Resources
State Legislation Statute
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Extension Request
The current 1115 SUD Demonstration continues through Jun. 30, 2024. DHS is required by law to request an extension from CMS of the 1115 Demonstration (Minnesota Statutes, Chapter 256B.0759 Subd. 8). That extension request will be submitted to CMS by Jun. 30, 2023 and, if approved, will move the Demonstration end date out five years.
DHS is dedicated to transparency and will share the extension request with its partners and the public. There will be two public hearings with an opportunity for providers and the public to provide feedback. Feedback from these hearings will be incorporated into the extension request before final submission.
The details of these two hearings will be announced on this page in the near future.
