Ensuring a Full Continuum of SUD Benefits

Section 1115 Substance Use Disorder (SUD) Waiver Application
The 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 Meetings
The 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 Period
The 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 Workgroup
During 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 Implementation
The 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.

Waiver application and public comment period

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 #1
Date: 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 Slides
Webinar 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 hcpf504ada@state.co.us or Shingo Ishida at Shingo.Ishida@state.co.us at least one week before the public notice period to make arrangements.

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
• Notice of Public Comment Process