CMS-10398 #64 Demonstration Characteristics Interview Email Invitation

Attachment 1.b. Demonstration Characteristics Interview Email Invitation and Grid

To: Director State Medicaid Agency

CC: CMCS Project Officer, RTI SUD Team Lead

Subject: RTI International Evaluation of Section 1115 Substance Use Disorder Demonstrations

Dear [Director State Medicaid Agency],

I am writing from RTI International as follow up to an email you received from [STATE CMS PROJECT OFFICER NAME] for your section 1115 substance use disorder (SUD) demonstration on [DATE] regarding the meta-evaluation we are undertaking on behalf of CMS. As part of the evaluation, we are conducting telephone interviews with state Medicaid directors in states implementing SUD demonstrations.

Interviews are intended to improve our understanding of your state’s pre-demonstration SUD treatment, coverage, and service delivery and program features of your demonstration. Information from these conversations will help CMS understand the effectiveness of SUD demonstrations to increase access to substance use treatment. Your participation is important to helping CMS support policy and programmatic development for other demonstration states and future demonstrations.

To prepare for the interview, we request that you review information about your SUD demonstration in the grid below for accuracy (see bottom of email).

The telephone interview will take no more than 60 minutes. Below we provide some potential times for calls. Would any of these times be amenable to you? If not, could you provide a few alternative times? If there is another person at your agency who would be more appropriate for this conversation, please provide us with their contact information. We also understand states are prioritizing COVID-19 response efforts. Please provide the date and time that works best for you and we will ensure our staff is available.

• Day of week m/dd - time

• Day of week m/dd – time

• Day of week m/dd – time

• Day of week m/dd – time

• We greatly appreciate your help in confirming our available information and helping to answer our questions.

If you have questions, please do not hesitate to contact me via email [EMAIL ADDRESS] or telephone [TELEPHONE NUMBER].

Thank you and we look forward to speaking with you.

[NAME OF RTI STAFF MEMBER]

________________________________________________________________________________________________________

SUD services pre- and post-demonstration for District of Columbia

The following table has been populated by the RTI Meta-Evaluation State Team based on your state's 1115 SUD Waiver special terms and conditions [INSERT HYPERLINK] and SUD demonstration Implementation Plan [INSERT HYPERLINK]. Additional sources, if used, are cited.

Instructions: Please review the accuracy of information in this grid. Use red font to make corrections. Where "needs clarification" appears in the cell, the RTI Team explicitly requests clarifying details. We include a clarifying question with the corresponding number (#) below the table. Where policy or benefit changes took place, please enter any known effective dates of the change in the far-right column. Where an exact date is not known, specify if the change occurred before or after the start date of your state’s SUD demonstration.

SUD Services and SUD Provider Requirements		Pre-waiver Status	Changes Made as Part of Section 1115 SUD Demonstration
		Implemented or Covered prior to demonstration (yes/no, areas of clarification)	Added or Updated as a part of the demonstration	Effective date of change
Medication Assisted Treatments
Methadone for OUD		Yes	No
Buprenorphine		Yes	No
Oral naltrexone		Yes	No
Long-acting injectable naltrexone		Yes	No
SUD Treatment Services Covered by Medicaid State Plan or State-only Funds
LOC 0.5:   Early intervention services for SUD		Yes	Yes - new reimbursement methodology for CPEP and the CRT
LOC 1.0: Outpatient		Yes	No changes
LOC 2.1: Intensive outpatient		Yes	No changes
LOC 2.5: Partial hospitalization		Needs clarification (1)	Needs clarification (1)
Any residential SUD treatment, LOC unspecified		Yes - covered under Medicaid through in-lieu of provision. Residential also covered through local funds	Yes
LOC 3.1: Low-intensity residential		No -  Covered by local-only funds	Yes
LOC 3.3: High-intensity, population-specific residential		Needs clarification (2)	Yes
LOC 3.5: High-intensity residential		No -  Covered by local-only funds	Yes
LOC 3.7: Medically monitored intensive inpatient		Needs clarification (3)	Yes
LOC 4.0 Medically managed intensive inpatient		Needs clarification (4)	Yes
Withdrawal Management (WM), LOC unspecified		Yes - covered under Medicaid through in-lieu of provision. Residential also covered through local funds	Yes
LOC 1.0 -WM: Ambulatory without extended on-site monitoring		Yes	No
LOC 2.0 -WM: Ambulatory with extended on-site monitoring		Needs clarification (5)	Yes (IMDs)
LOC 3.2 -WM: Clinically managed		Needs clarification (5)	Yes (IMDs)
LOC 3.7 -WM: Medically monitored		No	Yes (IMDs)
LOC 4.0 -WM: Inpatient detoxification		Needs clarification (5)	Yes (IMDs)
Recovery support services
Peer support services		Yes - DBH-supported Peer-Operated Centers not covered by Medicaid	Yes
SUD case management		Yes - through MCOs, My DC Health Home, My Health GPS	No changes
Recovery housing/supportive housing coverage		No	Yes
Supported employment coverage		No	Yes
Patient Placement Criteria
Widespread use of evidence-based patient placement criteria		Yes-TAP with ASAM	No - will decentralize intake, assessment, and referral system
Use of utilization review and benefits management for SUD treatment		Yes-through QIO and MCOs	No changes
Program Standards for Residential Treatment Providers
Use of widely recognized, evidence-based provider standards for SUD residential treatment		Yes - by DBH using ASAM	No changes
Residential MAT requirements		Yes-onsite or offsite access to MAT required	Yes - updating policies
Care Coordination: Coverage and Policies
Policies supporting care coordination		Yes - through DBH, MCOs, My DC Health Home, My Health GPS, FQHC APM	No policy changes
Policies for transitions in care		Yes - through DBH  and MCOs	Yes - new requirements on psychiatric hospitals and RTCs; adds Medicaid reimbursement for TPS provided by certain BH providers
Policies supporting integration of care		Yes - through My DC Health Home, My Health GPS	Yes - new requirements on psychiatric hospitals and RTCs
My DC Health Home; My Health GPS			These programs are expected to grow
ASAM=American Society of Addiction Medicine. CTCC=Comprehensive Transitional Care Coordination. DBH=Department of Behavioral Health. MCO=Managed Care Organization. TAP=Treatment Assessment Protocol. TPS=Transition Planning Services. QIP=Quality Improvement Program. WM=Withdrawal Management. LOC=Level of Care

The numbered questions below correspond to the numbered table notes appearing in cells needing clarification. Please provide answers in your preferred format. You may write your answer below the question, or enter your answer into the respective cells:

1. Your Implementation Plan indicates that you will be making some changes to coverage and provider requirements related to intensive day treatment. Could you clarify if both ASAM LOC 2.1 and 2.5 were covered by the Medicaid State Plan (or through in-lieu-of MCO provisions) prior to the waiver, and what changes your state has made or plans to make in that regard? 

2. Prior to the waiver, was ASAM LOC 3.3 covered by the State Plan for non-IMD settings? Did the "in-lieu-of" MCO provision apply to this ASAM LOC?

3. Prior to the waiver, was ASAM LOC 3.7 covered by the State Plan for non-IMD settings?  Did the "in-lieu-of" MCO provision apply to this ASAM LOC?

4. Prior to the waiver, was ASAM LOC 4.0 covered by the State Plan for non-IMD settings?  Did the "in-lieu-of" MCO provision apply to this ASAM LOC?

5. We understand that the District covered withdrawal management services in a wide array of settings except for ASAM LOC 3.7-WM. We would like to clarify if WM services covered every LOC as defined by ASAM, including ambulatory, clinically managed, etc.

Other document(s) cited:

Name/source/description: [INSERT HYPERLINK]

Name/source/description: [INSERT HYPERLINK]

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