Ensuring a Full Continuum of SUD Benefits

Waiver Application
The 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 Planning
Department 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.

Stakeholder Meetings

The Department hosted a series of three meetings on June 19^th and 20^th.  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:

• June Stakeholder Engagement Meeting Presentation
• Summary of the Waiver Components
• June Stakeholder Engagement Meetings Summary

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. 

Waiver Application

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.

Stakeholder Meetings

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 18^th 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 Springs
Old Colorado City Library - Old Colorado City Meeting Room
2418 West Pikes Peak Avenue
Colorado Springs, CO 80904

Thursday June 20, 2019, 8:00 am - 10:00 am, Greeley/Fort Collins area
Weld County Department of Public Health and Environment
1555 North 17th Avenue, Room 103
Greeley, CO 80631

Thursday June 20, 2019, 3:30 pm - 5:30 pm, Web-based Zoom meeting 
Zoom Meeting: https://zoom.us/j/285815659?pwd=WmprUDVIdWpoMFhaTDk5SVFrQSsrQT09
Phone:1-669-900-6833
Meeting 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 31^st.  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.

SUD system and benefit implementation planning

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.

Stakeholder Meetings

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 Meeting
Date: 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

1115 Waiver Application

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.

• SUD Waiver Public Hearing August 30, 2019
  Presentation Slides
  ​Webinar Recording (Presentation begins at the 7:00 minute mark)
• SUD Waiver Stakeholder Engagement Presentation May 28, 2019
• SUD Waiver Stakeholder Engagement Meeting Summary May 28, 2019
• Inpatient and Residential Benefit for SUD Concept Paper
• SUD Stakeholder Meeting Summary October 26, 2018
• SUD Stakeholder Meeting Presentation October 26, 2018
• Letter Signed by Governor John Hickenlooper June 5, 2018
• Colorado Health Institute Report to the General Assembly November 2017
• Legislative Bill
• CMS 115 SUD Demonstrations