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1115 Substance Use Disorder (SUD) System Reform federal demonstration project
In November, 2017, the U.S. Department of Health and Human Services and the Center for Medicare & Medicaid Services (CMS) issued a letter to announce a new direction in how CMS would like to work with states to improve access to high quality clinically appropriate treatment for opioid use disorder (OUD) and other substance use disorders (SUDs) for Medicaid beneficiaries. Following this new direction, and under the authority of section 1115(a) of the Social Security Act, Minnesota has been approved to implement a Substance Use Disorder (SUD) System Reform (PDF) federal Medicaid demonstration.
In March 2018, DHS submitted a SUD demonstration request to the CMS as part of SUD reforms enacted by the state legislature in 2016. Minnesota’s demonstration request received approval from CMS in late June 2019. On July 22, 2020 the CMS approved the Minnesota Substance Use Disorder Section 1115 Waiver Implementation Plan. The state is now eligible for federal funds for services delivered by providers participating in the demonstration project for eligible Medicaid beneficiaries while residing in institutions for mental diseases (IMD).
Directs DHS to publish standards for participating providers, and
Provides for a rate enhancement to SUD providers meeting state requirements.
CMS requires that states demonstrate how they are implementing evidence-based treatment guidelines, such as those published by the American Society of Addiction Medicine (ASAM). Minnesota will be incorporating ASAM criteria (PDF) into existing rule and statute where possible to establish specific residential and outpatient levels of care. The federal demonstration, through the implementation of ASAM Criteria, also seeks to enhance evidence-based assessment and placement criteria for the purposes of matching individual risk with the appropriate ASAM level of care and increase standards for treatment coordination to ensure care transitions to additional needed services.
Providers who are interested in participating in the project will need to enroll. Enrollment information can be viewed on the “How to Enroll” tab of this webpage. Enrolled providers who provide residential and outpatient SUD services will receive a rate enhancement.
The 2019 legislation enacted rate enhancement for residential and outpatient SUD services to enrolled demonstration providers delivering services to medical assistance enrollees. The rate enhancement for Medicaid fee-for-service residential services is to take effect on July 1, 2020. Legislation enacted in 2020 established a directed payment for Managed Care Organizations (MCOs) to pay at least the fee-for-service rate to enrolled demonstration providers and DHS will be updating MCO contract language to establish this directed payment effective January, 2021. The rate enhancement for treatment services provided to medical assistance enrollees will be 15% over the Fee-for-Service (FFS) per diem base rate for residential SUD providers effective July 1, 2020 and a 10% rate enhancement over the FFS base rate for outpatient treatment services effective January 1, 2021.
Medication-Assisted Treatment in the Demonstration
Minnesota DHS supports and encourages the use of all FDA approved MAT medications as part of an evidence-based person-centered approach to treating opioid use disorder (OUD). DHS is dedicated to providing high quality, effective individualized care to all Minnesotans seeking treatment. Access to all forms of MAT 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 MAT.
Provider completes 1115 Enrollment Checklist (DHS- 7325). Providers can use one form to identify multiple service locations if the description of how the demonstration requirements will be met is the same at each location. A separate checklist must be completed if there is any difference in how listed locations will meet the defined demonstration requirements,
Behavior Health Division (BHD) sends notification of receipt of application and reviews documentation. The review of applications will be prioritized as follows:
Residential levels of care provided in Institutions for Mental Disease (IMDs);
Residential levels of care provided in facilities not designated as IMDs;
Outpatient levels of care
BHD sends “Approval to Enroll” or “Request for More Information” letter to provider with instructions for next steps
If there is a Request for More Information, provider returns to Step 1
Once approved by BHD to enroll, provider submits the 1115 Assurance Statement to Minnesota Provider and Screening Enrollment (MPSE)
Provider Eligibility and Compliance sends enrollment confirmation with the effective date of enrollment.
Locations Enrolled in the 1115 Demonstration
The substance use disorder (SUD) treatment locations below 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.
Federal rules prohibit federal Medicaid funding for people receiving behavioral health care in Institutions for Mental Disease (IMD) which are residential facilities with over 16 beds. Demonstration authority granted by section 1115 of the Social Security Act allows states to waive certain federal requirements in order to test new or existing ways to deliver and pay for health care services in Medicaid to the extent that they are likely to promote the following Medicaid program’s 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; and
Improved access to care for physical health conditions among beneficiaries with SUDs.
Minnesota’s 1115(a) Substance Use Disorder System Reform demonstration project allows the state to receive federal Medicaid funds for people receiving treatment in participating IMDs when incorporating and reporting on metrics demonstrating that these goals and outcomes are in fact improving for Medicaid beneficiaries as the result of the demonstration. DHS is required to submit quarterly and annual reports that incorporate outcomes on 35 claims-based metrics to track trends related to these goals.
To support this commitment, Minnesota will assess for sufficient provider capacity at, and beneficiary access to, ASAM critical levels of care in partnership with the National Opinion Research Center (NORC) through an independent evaluation of the overall demonstration. In partnership with NORC, DHS will submit a Mid-Point Assessment, Interim Evaluation Report, and Summative Evaluation Report to CMS identifying the state’s impact on the Medicaid program’s goals and objectives.
CMS also requires that the state implement utilization management practices, including an independent process for reviewing residential stays, to help the state determine if patients are receiving the appropriate level of care at the appropriate time.