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; however, the state is not eligible for federal funds until approval of an implementation plan required by CMS. The Minnesota Substance Use Disorder Section 1115 Waiver Implementation Plan was submitted to CMS in September 2019 and DHS is awaiting approval from CMS.
Directs DHS to publish standards for participating providers, and
Provides for a rate increase 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 increase.
The 2019 legislation enacted rate increases for residential and outpatient SUD services to enrolled demonstration providers delivering services to medical assistance enrollees. The rate increase 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 increase 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 increase over the FFS base rate for outpatient treatment services effective January 1, 2021.
Uncertain about how to enroll in the demonstration? Unsure about gaps within a specific level of care treatment service?
Policy and operations experts will offer support to demonstration providers through the use of webinars and special training events that are specific to the 1115 SUD System Reform demonstration.
Questions sent to email@example.com will be reviewed and webinars will be designed around themes whenever provider feedback supports a training session. Check this tab frequently for news of upcoming events!
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.