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In accordance with House Bill 18-1136, the Department of Health Care Policy and Financing (Department) will be working to provide the full continuum of Substance Use Disorder (SUD) benefits to Health First Colorado (Colorado’s Medicaid program) members. The Department will be adding the inpatient and residential components, including withdrawal management, to the continuum of outpatient SUD services currently available. The Department’s objective is to make these services available for individuals who meet nationally-recognized evidence-based level of care criteria without shifting care from outpatient settings when they are more appropriate.
SUD Implementation Plan update
Program staff continue to collaborate with the Centers for Medicaid and Medicare Services (CMS) on the SUD waiver Implementation Plan. The Department submitted the draft Implementation Plan per CMS requirements and is currently awaiting additional guidance on the document from CMS. Program staff are also focusing efforts on creating and developing other waiver application components, such as the Health IT Plan and Monitoring Protocol.
Capacity Assessment and Expansion Plan
The Department and Capacity Expansion Plan Work Group is concluding its analysis of SUD treatment provider capacity across the state. In addition, plans for expanding capacity where needed are in development. This plan will highlight how available resources can be utilized to support and incentivize expansion where needed. While expansion of the provider network will be necessary to meet the expected demand for SUD services, the workgroup acknowledges that the current COVID-19 crisis presents a number of challenges to that process. The Department continues to assess the changing landscape for treatment providers.
Coming soon: MAT information for treatment providers, partners and stakeholders
Medicaid coverage for residential and inpatient services requires that providers facilitate access to MAT for its patients. In order to support providers in arranging for access, the Department’s program staff are developing a Medication Assisted Treatment (MAT) Toolkit. Stay tuned to future SUD Updates for this information.
Information for Providers
Now available: Frequently Asked Questions about new SUD benefit expansion
A list of frequently asked questions (FAQ) regarding the Department’s SUD benefit expansion is now available.
Update on ASAM training for providers
In previous Substance Use Disorder (SUD) Updates, treatment providers were encouraged to acquaint, or reacquaint, their staff with the American Society of Addiction Medicine (ASAM) criteria, which will be utilized as the basis for the management of SUD benefits covered by Health First Colorado. As of this month, 260 individuals registered for the ASAM training. About one-half of registrants have completed the first training component. Components #2 and 3 will be offered in June. The Colorado Department of Health Care Policy & Financing gratefully acknowledges the cooperation and assistance from the Colorado Office of Behavioral Health and Signal Behavioral Health Network in making this free, one-time ASAM training available to providers.
In upcoming newsletters, we will be highlighting information relevant to SUD providers that plan to offer residential and inpatient SUD services in Colorado through Medicaid funding. Information on enrollment with the Department and billing and coding information will be featured along with other important information about the new service coverage. Please look for this feature in upcoming SUD updates and newsletters.
RAE CommunicationAt this time, we encourage providers interested in receiving Medicaid reimbursement for residential and inpatient SUD treatment and withdrawal management services to reach out to the Regional Accountable Entities (RAEs) and Managed Service Organizations (MSOs) to discuss the credentialing and contracting process. Contact information for each RAE can be found on the Department’s Accountable Care Collaborative Phase II webpage. Providers may choose to contact their local RAE or other RAEs throughout the state if they plan to serve populations state-wide. Please visit this webpage for MSO contact information. The MSOs contract with providers to serve the non-Medicaid, indigent population in Colorado. Providers receiving Medicaid funding for residential SUD services will need to contract with RAEs to receive payment for treatment services and MSOs to receive payment for room and board cost associated with those stays.
ASAM alignment and trainingProviders are also encouraged to acquaint, or reacquaint, their staff with the American Society of Addiction Medicine (ASAM) criteria. ASAM criteria will be utilized as the basis for the management of SUD benefits covered by Health First Colorado. Additionally, it is the foundation for the state’s SUD treatment program licensure rules. The Colorado Office of Behavioral Health (OBH) is in the process of aligning its licensure rules more closely with the ASAM criteria. Residential and inpatient providers are encouraged to review the ASAM criteria and consider how their programs are aligned with the criteria in anticipation of licensure changes. Provider agencies should also ensure that relevant staff are trained in the ASAM criteria. OBH partnered with Signal Behavioral Health to make ASAM training available at no cost for a limited number of staff in provider agencies. As of February, over 150 participants across the state have been registered in trainings. Training components #2 and #3 are scheduled to be offered in March. Providers are encouraged to enact plans to ensure that all staff needing ASAM training have completed relevant training by July 2020.
Prior to the opening of coverage for SUD residential and inpatient services, the state must receive approval from the Centers for Medicare and Medicaid Services (CMS) for three components that will authorize coverage for SUD services in residential and inpatient settings. Those authorities include the State Plan, 1115 waiver and 1915(b) waiver. Each item authorizes a component of the services or service delivery system. The State is engaged with CMS in discussion of each of those components and is working toward obtaining approval for all components in advance of the target benefit opening date of July 2020.
To date, the Department has completed 9 of 11 Regional SUD Capacity Stakeholder Meetings, scheduled through March 2020. At these public meetings, the Department is presenting information on SUD treatment capacity, hearing from community members about the needs in the local area, as well as collecting input from the public regarding the new benefits for residential and inpatient SUD treatment and withdrawal management services. The Department’s data analytics unit also continues to develop maps to reflect supply and demand of SUD services across the state. After capacity assessment activities are concluded, a capacity expansion plan will be developed in conjunction with the Office of Behavioral Health, RAEs, MSOs and external consultants. This plan will document gaps in the SUD service continuum and propose plans for the use of existing resources to address deficiencies. Presentation slides for these meetings are available here. Meeting minutes including participant input and feedback will be made available in the near future.
Section 1115 Substance Use Disorder (SUD) Waiver Demonstration Application
The Colorado Department of Health Care Policy and Financing is engaged with the Centers for Medicare and Medicaid Services (CMS) in discussion about the content of the State’s proposed Section 1115 Substance Use Disorder (SUD) waiver demonstration application. The Department is also in the process of amending the Colorado State Plan to include residential and inpatient SUD treatment and withdrawal management services. Tribal notice for the State Plan modifications concluded on January 15, 2020. The Department will submit the draft amendments during January.
Regional Capacity Stakeholder Meetings
The Department continues its series of Regional Capacity Meetings during January and February 2020. At these public meetings, the Department will be presenting information on SUD treatment capacity and hearing from community members about the needs in that local area. The regional meetings serve as opportunities for the public to provide input and ask questions about the implementation of coverage for residential and inpatient SUD treatment and withdrawal management services. Attendees may register for the regional meeting of their choice via the RSVP links provided on this webpage.
SUD Implementation Workgroup
The Department convened the SUD Implementation Workgroup on January 15, 2020. The Implementation Workgroup, comprised of representatives from Regional Accountable Entities (RAEs), Managed Services Organizations (MSOs), Colorado Office of Behavioral Health, and Department staff, will address various issues (utilization management, care coordination, provider enrollment/billing, capacity development, provider training and support, etc.) that need to be addressed prior to the introduction in July 2020 of Medicaid coverage for new SUD treatment benefits.
1115 Substance Use Disorder (SUD) Waiver Demonstration Application
The Department is actively engaged with the Centers for Medicare and Medicaid Services (CMS) regarding comments received during the 30-day federal public comment period regarding the State’s Section 1115 waiver application. The Department anticipates continued conversation with CMS about the contents of the application during the month of January.
State Plan Amendments
The Department is also required to amend the State Plan to include residential and inpatient SUD treatment and withdrawal management services. The Department has engaged the CMS regional office to begin that review and approval process. The Department is drafting the amendments and anticipates submitting drafts to CMS in January 2020. Tribal notice of the state plan changes occurred on December 13, 2019.
Interchange system changes
The Department has drafted billing rules which were presented to the Coding Committee on November 14, 2019 for feedback. The billing rules have been developed into policy that is informing the design of changes to the claims processing system. The Department continues to move the system changes forward that will be necessary for billing of the new SUD residential and inpatient services.
Regional Stakeholder Meetings
The Colorado Department of Health Care Policy and Financing continues its series of Regional Stakeholder Meetings in January and February 2020. At these public meetings, the Department will be presenting information on SUD treatment capacity and hearing from community members about the needs in that local area. The regional meetings serve as opportunities for the public to provide input and ask questions about the implementation of coverage for residential and inpatient SUD treatment and withdrawal management services. Treatment providers, local government officials, partner agencies, and interested members of the public are invited to attend. A call-in option will be available for some of the meetings. Please see information on this webpage to register for the meeting of your choice.
Coming Soon: Information on ASAM Criteria Training
The Department thanks all treatment providers who responded to the announcement of American Society of Addiction Medicine (ASAM) Criteria training. Providers expressed strong interest in the training and many made requests for additional training spots. The training is being coordinated by Signal Behavioral Health Network and additional information about registration will be provided soon. Please contact Heather Dolan at email@example.com if you have questions regarding the ASAM trainings.
Regional Meetings: Meet with Department staff to discuss new residential/inpatient Substance Use Disorder (SUD) benefits and capacity needs in your areaThe Colorado Department of Health Care Policy and Financing began its series of Regional Meetings on December 3 in Aurora/Centennial. At these public meetings, the Department is presenting data on SUD treatment capacity. The Department would also like to hear from community members about the needs in that local area. In addition, the regional meetings are an excellent opportunity for the public to provide input or ask questions around the new benefits for residential and inpatient SUD treatment and withdrawal management services. The Department invites all of its stakeholders, partner agencies, treatment providers, local government officials and members of the public to attend. Please freely share this announcement with others who may be interested in the new SUD benefits. Attendees may register for the regional meeting of their choice via the RSVP links provided below.
Option to participate in Regional Meetings by phoneAt some meetings, we are able to offer a call-in option for those who cannot attend in person. The following meetings will be accessible by phone: Denver, Alamosa, Pueblo, Colorado Springs, Durango, Fort Morgan and Fort Collins. If you plan to participate by phone, please follow along with the slides and call-in information that will be posted on the Department SUD webpage prior to the meetings.
Section 1115 Substance Use Disorder (SUD) Waiver ApplicationThe Centers for Medicare and Medicaid Services’ (CMS) 30-day federal public comment period for Colorado’s Section 1115 waiver application will end on December 8, 2019. After that date, the Department will engage in regular calls with CMS to discuss the application and implementation.Providers seeking Medicaid reimbursement for residential and inpatient SUD treatment and withdrawal management services will be required to align their programs with ASAM criteria. To support treatment providers in increasing their understanding of the ASAM criteria, a one-time initial offering of free ASAM training will be offered jointly by the Colorado Office of Behavioral Health, Signal Behavioral Health Network, and the Colorado Department of Health Care Policy and Financing. This training is a first step for agencies to ensure that staff are trained on the ASAM criteria. Following this training, providers will be expected to develop sustainable plans for ensuring that all clinical staff have training in ASAM that is appropriate to their role in the organization. Please contact Heather Dolan at firstname.lastname@example.org if you have any questions regarding the ASAM trainings.
Section 1115 Substance Use Disorder (SUD) Waiver ApplicationThe Department of Health Care Policy and Financing has submitted its Section 1115 waiver application to the Centers for Medicare and Medicaid Services (CMS). CMS will review the waiver application for completeness and then post it for 30 days to receive public comments.
SUD Capacity Planning The Department is mapping SUD treatment capacity across the state according to American Society of Addiction Medicine (ASAM) levels, as well as demand for services. The SUD Capacity Building Workgroup continues to examine the network of SUD treatment providers and analyze capacity for SUD services across Colorado. The workgroup will next convene in November.
Regional Capacity MeetingsThe Department will host a series of Regional Capacity Meetings from December 2019 through February 2020. These meetings will focus on the state’s SUD treatment capacity, demand for services, as well as strategies to identify and address needs or gaps in service. The Department invites stakeholders, partner agencies, treatment providers, local government officials and members of the public to participate, ask questions and provide input. Participants are encouraged to register for meetings in advance via the RSVP link provided below. RSVPs will be received until two weeks before the date of each meeting.
Public Comment PeriodThe 1115 SUD waiver public comment period began on August 25, 2019 and closes on September 27, 2019. Two public hearings were held during September. Stakeholders submitted comments by mail and email. The Department appreciates the feedback received on the waiver. Staff are engaged in next steps to move forward with waiver submission:
Review and document responses to all comments received
Revise waiver application as necessary
Submit revised waiver to the Centers for Medicare and Medicaid Services (CMS) during the month of October
CMS to post waiver for 30-day federal public comment period
SUD Capacity Building WorkgroupDuring September, the Department began the SUD Capacity Building Workgroup. Members of the workgroup include staff from the Department, the Office of Behavioral Health, the Regional Accountable Entities (RAEs) and the Managed Service Organizations (MSOs). This workgroup will examine the capacity for SUD treatment services across the continuum in the state. The group will identify areas where there is insufficient capacity for services and develop a plan to address deficiencies. Once the plan has been drafted, it will be shared with stakeholders who will be invited to provide comment and suggestions.
Benefit ImplementationThe Department continues to work on other issues, such as provider licensure and training, to prepare for covering new SUD services. The Department will conduct regular stakeholder meetings to prepare for offering the new benefit. Those meetings will be announced on this webpage and through the waiver initiative newsletter.
If you have not signed up to receive the newsletter, please do so through the link below.
The Department has finalized the draft waiver application and aligned it with federal transparency requirements. The Department invites the public to provide comments regarding the proposed waiver application. The public notice period begins on August 25, 2019 at 8:00am MDT and ends on September 27, 2019 at 5:00pm MDT. The Notice of Public Comment Process is available at the link on this webpage. Following the public comment period, the Department may amend the waiver application as appropriate, based on the comments received.
The Department invites the public to attend public hearings in person or join by teleconference/webinar to learn more about Colorado’s waiver application and provide comments.
Public Hearing #1Date: Friday, August 30, 2019
Time: 10:00 a.m. - 12:00 p.m.
Location: Colorado Department of Health Care Policy & Financing 303 East 17th Avenue, 7th Floor, Conference Room 7ABC
Denver, CO 80203
Call-In Number: 1-877-820-7831, Participant Code 946029#
Webinar: https://cohcpf.adobeconnect.com/sud1115waiver/Presentation SlidesWebinar Recording (Presentation begins at the 7:00 minute mark)
Public Hearing #2
Date: Friday, September 6, 2019
Time: 10:00 a.m. - 12:00 p.m.
Location: DoubleTree Hotel Grand Junction - Aspen Room
743 Horizon Drive
Grand Junction, CO 81506
Reasonable accommodations will be provided upon request for persons with disabilities. Please notify the Department 504/ADA Coordinator at email@example.com or Shingo Ishida at Shingo.Ishida@state.co.us at least one week before the public notice period to make arrangements.
Waiver ApplicationThe Department is in the process of finalizing the waiver application and is in regular communication with the Centers for Medicare and Medicaid Services (CMS) to obtain feedback on program design and ensure the waiver submission aligns with federal requirements The Department plans to submit the waiver application to CMS in October, following the public notice and comment period in August and September.
Public Comment Period [Updated]The Department invites the public to provide comments on the waiver application during the upcoming public comment period, which is scheduled to begin on August 25, 2019 and end on September 27, 2019. Following the public comment period and prior to submission, the Department will review and assess all public comments, and amend the waiver application, if appropriate. Please bookmark and return to this Department SUD Benefits webpage for additional information coming soon regarding the public comment submission process, public hearings, and the proposed Section 1115 Waiver Demonstration Application for public review and comment.
Substance Use Disorder System and Benefit Implementation PlanningDepartment staff have begun working on system changes that, when introduced in 2020, will allow for billing of services. The Department met with state criminal justice partners to discuss the intersection of the newly covered services and the population involved in criminal justice. Staff also continue to work with the Colorado Office of Behavioral Health on matters related to implementation, including assessment requirements and licensure alignment with American Society of Addiction Medicine (ASAM) treatment criteria.
The Department hosted a series of three meetings on June 19th and 20th. During the meetings, staff presented the basic elements of the waiver application. Staff announced the services which will be covered under the waiver, if approved by the Centers for Medicare and Medicaid Services (CMS). These services include ASAM levels 3.1, 3.3, 3.5, 3.7 and 3.7 Withdrawal Management. Meeting slides and a summary of the waiver components are available below:
Two meetings are planned for the public notice period in August. The meetings will take place in Grand Junction and the Denver metro area. The dates and locations of those meetings will be announced in July. The Department is also developing a plan for further stakeholder engagement to take place after the public notice period. Those meetings will focus on the implementation of waiver services.
A first draft of the waiver application is complete. The Department is currently focused on the budget neutrality calculations that are included in the application. The waiver is planned for submission to CMS during the month of October.
SUD system and benefit implementation planning
Departmental staff have begun to identify billing codes for the new services and are planning for the changes that will be necessary in the Interchange system when the services are introduced. The Department is exploring requirements that will pertain to assessment practices for determining appropriate levels of care. Staff are also working with OBH to align licensure requirements with ASAM criteria. Statewide training needs for partners involved in providing the services are also being assessed.
The Department held its second stakeholder meeting on May 28, 2019. Slides and a meeting summary can be found on this page under the additional information tab. A series of meetings are planned for June 18th and 19th. These meetings will focus on the most current thinking on the benefit. Stakeholders will be invited to provide input on the proposed benefit and other general issues that relate to the waiver. The content presented in the June meetings will be the same at each location.
Meeting dates and locations are as follows:
Wednesday June 19, 2019, 3:30 pm - 5:30 pm, Colorado SpringsOld Colorado City Library - Old Colorado City Meeting Room2418 West Pikes Peak AvenueColorado Springs, CO 80904
Thursday June 20, 2019, 8:00 am - 10:00 am, Greeley/Fort Collins areaWeld County Department of Public Health and Environment1555 North 17th Avenue, Room 103Greeley, CO 80631
Thursday June 20, 2019, 3:30 pm - 5:30 pm, Web-based Zoom meeting Zoom Meeting: https://zoom.us/j/285815659?pwd=WmprUDVIdWpoMFhaTDk5SVFrQSsrQT09Phone:1-669-900-6833Meeting ID: 285 815 659
1115 Waiver Application
The Department continues to work toward developing the residential and inpatient benefit and drafting the waiver application. A framework for the benefit will be complete during June. Departmental staff and contractors will also have an early draft of the waiver application by May 31st. The Department has begun to build a project plan for the monitoring and evaluation requirements and is keeping an eye to those requirements while designing the benefit. Departmental staff is also receiving technical assistance from the National Governor’s Association to develop the monitoring and evaluation plans.
The Department continues to examine capacity of SUD treatment providers, including MAT, withdrawal management and residential treatment through the state. The Department is considering ways to meet CMS requirements related to assessment and level of care decision making. Department staff have met with state criminal justice partners to consider how the benefit will intersect with services that are required by those entities.
The Department will host a series of stakeholder meetings during May and June. During the May meeting, staff will discuss waiver requirements that relate to the implementation of the benefit. These issues influence decision making about the benefit and will have the potential to impact the delivery of SUD services beyond the proposed Health First Colorado benefit. In June, there will be three meetings which will focus on the benefit as it has been conceptualized at that time. Stakeholders will be invited to provide feedback on the proposed benefit and other general issues that relate to the waiver. The content of the three June meetings will be identical to one another; two meetings will be held in different Front Range locations and one meeting will be conducted as a Zoom meeting.
May In-Person MeetingDate: Tuesday, May 28, 2019
Time: 3:30 - 5:30 p.m.
Location: Colorado Health Institute 303 East 17th Avenue, 9th Floor, Suite 930
Denver, CO 80203
The Department concluded the procurement process and is now working with a contractor that is assisting with the waiver application process. The contractor has experience assisting other states with SUD waiver applications and is providing key support and expertise to the Department on this task.
Research on SUD Services
The Department continues to work closely with the Colorado Office of Behavioral Health (OBH) to map the availability of treatment providers at all care levels as well as Medication Assisted Treatment (MAT) providers. The Department is also examining how the existing network of SUD care in Colorado compares with CMS requirements, as well as to the American Society of Addiction Medicine (ASAM) criteria. Departmental staff have conducted research on how other states are managing a variety of waiver requirements including patient placement decision making and utilization management. The Department has gathered information about existing practices related to these issues from a variety of Colorado stakeholders.
The Department continues to work toward providing the full continuum of substance use disorder benefits to Health First Colorado enrollees. To support these efforts, HCPF has hired two staff members who are focused on pursuing the 1115 waiver that will allow the Department to offer an inpatient and residential Substance Use Disorder (SUD) benefit. The Department currently has an open solicitation for a contractor to assist with the development of the waiver application. Numerous states have engaged contractors with expertise in the SUD waiver to ensure that the application is consistent with CMS requirements and to avoid unnecessary delays once the application is submitted.
The Department has also developed contracts with two experts who have familiarity with the SUD services in the State of Colorado. These contractors will be assisting with system mapping and capacity issues. Finally, HCPF has engaged a contractor who will assist with developing a robust plan for stakeholder communication and engagement. A series of stakeholder meetings are being planned for Spring 2019. Please stay tuned for more updates that will announce the dates and locations of those events. In those meetings, we will be updating stakeholders on the work discussed above and inviting feedback from the community.
The Department is also engaged in biweekly calls with the Centers for Medicare & Medicaid Services (CMS). The meetings are currently focused on the development of the 1115 waiver demonstration application. The Department is working with CMS to prepare for the implementation, monitoring and evaluation components of the waiver process. Additional information about CMS requirements and guidance is available here.
In addition to its engagement with CMS, the Department is working with the State of Colorado Office of Behavioral Health to map the current system of SUD treatment providers and to assess the capacity of those providers. While the 1115 waiver provides a funding opportunity for inpatient and residential treatment services, the focus of the initiative is broader in that it asks states to examine their existing SUD services across the continuum. The waiver process requires that states demonstrate that provider qualifications, patient placement criteria and use of evidence-based practices in treatment programs meet nationally recognized standards. Additionally, the Department will be examining the availability of care coordination and transition services throughout the state.
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QuestionsIf you have questions regarding the 1115 SUD Waiver, Substance Use Disorder benefits for inpatient/residential treatment, or any other topic relating to the SUD Waiver, please complete our SUD Waiver Question Form.