Ensuring a Full Continuum of SUD Benefits

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.

February 2020 Update

Information for PROVIDERS

OBH Licensure Rule Changes
The Office of Behavioral Health is revising its rules that apply to substance use disorder treatment programs.  Providers are encouraged to review the proposed rules and consider their potential implications for service provision in the future.  It will be helpful for providers to think about where their services fall relative to the proposed rules.  Providers should consider whether they will continue to provide services at the level at which they are currently licensed, which will require that they meet new licensure requirements for that level of care, or consider relicensing at a different level of care.  Providers should begin to plan for any adjustments to their program offerings to meet new requirements or develop a plan to seek licensure at a different level.  Please note that these rules are not approved at this time, so providers are also encouraged to provide feedback to the Office of Behavioral Health and stay abreast of changes to the rule as feedback in incorporated prior to approval.

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 Communication
At 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 training
Providers 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.

Federal Approval Process Update

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.

SUD Capacity Assessment and Planning

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.

Note: Please be advised that the Department may cancel a meeting due to adverse weather, if anticipated attendance is less than five people, or other factors. Any meeting updates and information will be posted on this webpage.

Regional Capacity Stakeholder Meeting Summaries

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Colorado Springs
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Fort Collins
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Fort Morgan
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Steamboat Springs
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If 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.