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The Minnesota Department of Human Services (DHS) invites public comments on the implementation of Minnesota’s 1115 SUD System Reform Demonstration submitted via email and at a virtual public event.
More information about this event is available in the e-memo.
The state of Minnesota requires DHS to submit an extension request of the Substance Use Disorder (SUD) 1115 waiver with Centers for Medicare and Medicaid Services (CMS) in order to receive enhanced federal financial participation for services delivered in Institutions for Mental Disease (IMD). Details about the requirements of this extension request can be found at this page on the CMS website.
Dates for public comment events (virtual and in person) will be announced in the near future. More specifics and information about the extension request and the events can be found on the “Extension Request” section of this webpage.
State legislation enacted in 2022 updated language used in relation to substance use treatment. This language change aligns with national movement away from the terminology of Medication Assisted Treatment (MAT) toward a less stigmatizing and more accurate naming convention, Medications for Opioid Use Disorder (MOUD). While reports and documents linked to this website may still use the terminology of MAT due to the date they were published, DHS will refer to this treatment as MOUD going forward.
The following substance use disorder (SUD) providers are required to enroll in the 1115 Demonstration by January 1, 2024:
See the 1115 Substance Use Disorder System Reform Demonstration 2021 Legislative Changes bulletin (21-51-01) for more information.
Effective July 1, 2023, the following substance use disorder (SUD) providers are required to enroll in the 1115 Demonstration by January 1, 2025:
Tribally licensed providers may elect to participate. Outpatient SUD providers may elect to participate any time before the January 1, 2025 deadline. The above timelines are in accordance with Minnesota Statute 256B.0759 Subd. 2. More enrollment guidance is located in the “How to Enroll” tab of this webpage.
Virtual Office Hours are once a week on Thursdays 2:00 - 3:00 p.m. Virtual Office Hours are drop-in question and answer time with the 1115 Team. The focus is on enrollment and clinical questions. No registration is required. Attendees will be admitted after joining meeting.
Because there are other methods by which providers can contact the 1115 team (such as office hours and one on one consultation), the listening sessions and 1115 Provider Forums are cancelled until further notice.
Send your questions about the 1115 Substance Use Disorder System Reform Demonstration to 1115demonstration.dhs@state.mn.us.
Minnesota is piloting a new approach to strengthen the state’s behavioral health care system by improving access to substance use disorder treatment across the state for Medicaid recipients. The state is doing this under the 1115 Substance Use Disorder (SUD) System Reform Demonstration. The Centers for Medicare and Medicaid Services (CMS) uses 1115 SUD Demonstrations to expand access to high quality, clinically appropriate SUD treatment using American Society for Addiction Medicine (ASAM) levels of care. Providers enrolled in the Demonstration comply with the ASAM Criteria and are eligible for funding incentives.
Minnesota’s 1115 Demonstration (“the Demonstration”) breaks down into two main areas:
SUD providers licensed under Minnesota Statute 245G or 245F and enrolled in MHCP are eligible to enroll in the Demonstration. Out-of-state providers who are enrolled in MHCP are also able to enroll in the 1115 Demonstration.
By expanding the use of the ASAM Criteria and expanding MA coverage to IMDs, Minnesota’s goal is to address the six federal goals and objectives:
The ASAM Criteria is the nation’s most widely used set of guidelines for people with SUD and co-occurring disorders. The Demonstration is implementing the ASAM Criteria to create a long-term chronic disease model that uses the evidence-based treatment methods. The Demonstration’s Level of Care Requirements incorporate ASAM Criteria.
SUD providers must implement the Level of Care Requirements into their policies and procedures in order to participate in the 1115 Demonstration. The Level of Care Requirements include patient referral arrangement agreements (PRAAs) for ASAM Levels of Care that providers don’t offer, medications for opioid use disorder (MOUD) access for residential providers, as well as medical, psychiatric, psychological and toxicology consultation and referrals. Overall, the goal is for people receive the right level of care at the right time.
MOUD is an important component of person-centered and evidence-based treatment and in meeting the six CMS goals and objectives of the Demonstration. Minnesota DHS supports and encourages the use of all FDA-approved MOUD as part of an evidence-based, person-centered approach to treating OUD. DHS is dedicated to providing high-quality, effective individualized care to all Minnesotans seeking treatment.
Access to all forms of MOUD is an essential component for equitable access and success of treatment. In order to increase access to evidence-based treatment and promote equitable treatment, DHS encourages providers to accept clients receiving any FDA-approved MOUD.
Residential and outpatient providers who enroll in the Demonstration are eligible for rate enhancements for services delivered to Medical Assistance (MA) fee-for-service (FFS) and Managed Care Organizations (MCOs) recipients. CMS approved rate enhancements from the 2021 1st Special Session as follows:
These rate enhancements are effective for dates of service on or after Jan. 1, 2022. There are no rate enhancements for withdrawal management providers or hospitals. The MHCP SUD Provider Manual contains more information on rates and billing.
CMS requires Minnesota to implement utilization management processes to assure beneficiaries receive SUD treatment at the appropriate level of care, interventions are appropriate for the diagnosis and include an independent process for reviewing residential treatment placements, in particular, the types of services, hours of clinical care and credentials of staff.
SUD providers enrolled in the Demonstration are required to follow the utilization management process. DHS has collaborated with Kepro for the FFS utilization management process. MCOs are required to align with the FFS UM process and ASAM Criteria.
Section 1115 of the Social Security Act allows the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) to approve demonstration projects that are likely to improve state Medicaid programs (“Medical Assistance” in Minnesota). CMS waives certain federal requirements in 1115 Demonstrations in order to test new or existing ways to deliver and pay for health care services. States must apply to CMS to implement 1115 Demonstrations. After approval, CMS monitors the implementation progress and impacts on clients, providers, health plans and state agencies.
In 2015, CMS announced an opportunity for state Medicaid agencies to apply for 1115 Demonstrations to address the opioid crisis. In 2017, they announced a revision that streamlined the process for states to implement a SUD-focused 1115 Demonstration.
States were instructed to improve access to high quality, clinically appropriate treatment for SUD. Specifically, improvements were to be made through the implementation of evidence-based treatment guidelines, such as the American Society of Addiction Medicine (ASAM) Criteria and by covering critical levels of care, Medication for Opioid Use Disorder (MOUD) and withdrawal management. States are able to receive federal financial participation (FFP) for services provided in Institutions for Mental Diseases (IMDs), defined as residential facilities with more than 16 beds. Federal laws typically exclude IMDs from Medicaid reimbursement.
CMS established six goals and objectives for all 1115 SUD Demonstrations:
Minnesota has been moving towards an SUD treatment system aligned with a chronic disease model for SUD for 20 years. DHS’ 1993-99 The challenges and benefits of chemical dependency treatment study’s key recommendation was to create an SUD continuum of care consistent with chronic disease management. In 2013 Minnesota’s Model of Care for SUD Legislative Report (DHS-6708) recommended updating Minnesota’s treatment system from an acute episodic model, to a chronic, longitudinal model of health care.
In 2016, the Minnesota Legislature directed the Department of Human Services (DHS) to design an SUD system with a full continuum of services available to all Minnesotans (MN Section 254B.15). The streamlined 1115 SUD Demonstrations gave Minnesota the opportunity to implement the recommended changes. In March 2018, DHS submitted an SUD demonstration request to CMS.
Legislation enacted in 2019 provided DHS the resources to implement the demonstration (MN Section 256B.0759). Minnesota’s Demonstration application was approved by CMS in June 2019. Minnesota couldn’t receive FFP or begin implementation until CMS approved the Implementation Plan. On July 22, 2020, CMS approved the state’s original Implementation Plan and Special Terms & Conditions (STCs) , marking the official start of Minnesota’s 1115 Demonstration (“the Demonstration”). The STCs are the state’s contract with CMS during the Demonstration.
Updates to the Implementation Plan as a result of the 2021 legislation, as well as the state’s evaluation design plan completed by DHS’ independent evaluator, NORC at the University of Chicago, were approved by CMS on July 28, 2021.
The Implementation Plan provides the details necessary to operationalize the Demonstration’s in six federal-required milestones:
The Demonstration is scheduled to run until June 30, 2024; however, Minnesota state statute requires DHS to apply for an extension. The extension request is due to be submitted to CMS by June 30, 2023.
The following SUD) providers are required to enroll in the 1115 Demonstration by January 1, 2024:
Outpatient SUD providers and tribally licensed providers may elect to participate. This in accordance with Minnesota Statute 256B.0759 Subd. 2. See the 1115 Substance Use Disorder System Reform Demonstration 2021 Legislative Changes bulletin (21-51-01) for more information.
Attend virtual office hours before filling out the 1115 Demonstration enrollment application. Virtual office hours are drop-in based and focus on enrollment and clinical questions. The Reform and Redesign Team who helps facilitate the Demonstration for DHS, encourages providers at all stages of enrollment to attend and will tailor each session to the attendee(s)’ questions.
Obtain all necessary Patient Referral Arrangement Agreements (PRAAs). Providers participating in the 1115 Demonstration are required to have PRAAs for the American Society of Addiction Medicine (ASAM) Levels of Care not offered at participating location(s).
The “Approved Locations” tab lists all approved providers by level of care, name, and address with contact information to assist providers in arranging PRAAs.
SUD providers must have all necessary licensure before beginning the 1115 Demonstration enrollment application.
If one of the licenses is missing, work with DHS Licensing to obtain necessary licensing requirements
Out-of-state and tribal nation providers with applicable licensure and enrolled in MCHP may also participate in the 1115 Demonstration. Email 1115demonstration.dhs@state.mn.us for technical assistance with the enrollment application.
Choose the “Level(s) of Care at this Location” in the 1115 Enrollment Application (DHS-7325-ENG) to show the relevant requirements for each Level of Care.
Update relevant policies and procedures to incorporate the 1115 Level of Care Requirements. Add the program policy and procedure page number to the column of the 1115 enrollment application requesting a brief description.
Providers must have all the requirements implemented in their policies and procedures before enrolling in the 1115 Demonstration. The Reform and Redesign Team cannot approve providers to enroll until all Level of Care Requirements are implemented.
Submit signed and dated 1115 Enrollment Application, updated relevant policies and procedures, PRAAs, and MOUD Policy (residential providers only) to 1115demonstration.dhs@state.mn.us.
Reviewing request for more information (RFMI) submissions will take priority over first time submissions (see Step 7).
The Reform and Redesign Team reviews application and sends the necessary follow-up communication.
If the Reform and Redesign Team does not hear back from providers after sending a RFMI Letter, they will follow up to check in on the progress. If there’s no response, the Team will move the application to “inactive” status. Inactive status means the application is no longer prioritized over new submissions.
The Reform and Redesign Team will send an “Approval to Enroll” letter via email once all requirements are met. Providers are not enrolled until they:
Providers will be eligible for rate enhancements beginning on the date identified on their approval to enroll letter from the Behavioral Health Division.
ADDENDUM: To add an additional program and/or a level of care after enrollment:
The 1115 Demonstration must have an updated and signed application that includes the information of the program and/or level of care they want to add.
Providers may create a new application document or edit and update a previous version of the 1115 Demonstration Enrollment Application. To do this, follow these steps:
If documentation for your other enrolled programs providing the same levels of care has already been submitted, you do not need to resubmit, as long as there are no updates.
NOTE: clicking on the link below will download the file. You may need to open your downloaded files to view the list.
The substance use disorder (SUD) treatment locations listed in the 1115 Demonstration Approved Locations have been approved to participate in the 1115 SUD System Reform Demonstration. You can use the contact information to make Patient Referral Arrangement Agreements as needed.
Policy and operations experts will offer support to demonstration providers through the use of presentations and special training events that are specific to the 1115 SUD System Reform Demonstration.
Questions sent to 1115demonstration.dhs@state.mn.us will be reviewed and presentations will be designed around themes whenever provider feedback supports a training session.
Questions? Contact 1115demonstration.dhs@state.mn.us.
The Behavioral Health Division is collaborating with Great Lakes Addiction Technology Transfer Center Network (ATTC), the University of Nevada, Reno Center for the Application of Substance Abuse Technologies (UNR-CASAT) and the National Frontier and Rural Telehealth Education Center (NFARtec) to offer ASAM training:
SUD providers interested or planning to enroll in the 1115 SUD System Reform Demonstration are encouraged to participate in ASAM trainings.
ASAM - American Society of Addiction Medicine
The Behavioral Health Division is partnering with Kepro to implement the federally required utilization management and review process for participating 1115 Demonstration providers. This is a required component for participation and a part of the approved Implementation Plan.
For more information, visit Kepro’s Minnesota Health Care Programs website.
Review previous presentations and scripts for detailed information on different components of the 1115 Demonstration.
Reporting is an important component of the Demonstration. Federal authority gives Minnesota additional flexibility to design and improve their SUD Medicaid program. Due to the added flexibility, the Centers for Medicare and Medicaid Services (CMS) has specific reporting and evaluation requirements. In addition to federal requirements, DHS is conducting ongoing stakeholder engagement.
Federally required reports are published on DHS’ Federal health care waivers webpage within 30 days of CMS approval.
DHS submits three quarterly reports and one annual report to CMS each year of the Demonstration. These reports include operational updates, performance metrics, financial reporting, evaluation activities and interim findings and SUD Health IT updates. Performance Metrics incorporate 35 claims-based measures to track trends related to the six goals and objectives of the Demonstration.
As part of the Special Terms and Conditions to CMS, DHS is required to work with an independent evaluator to evaluate the Demonstration’s implementation and impact on the six goals and objectives. DHS has partnered with the National Opinion Research Center (NORC) to conduct the independent evaluation. The evaluation process includes the following:
DHS is required to host annual public comment forums throughout the Demonstration. Public comment forums offer the public an opportunity to give feedback on the progress of the Demonstration.
In this report NORC assess the baseline provider capacity and availability of provider organizations for SUD treatment for Medical Assistance enrollees. This study used information from Jul. 1, 2018 to Jun. 30, 2019.
Provider Capacity Assessment: Baseline Assessment (DHS-8278)
Access to MAT, now referred to as Medication for Opioid Use Disorder (MOUD), is an important component of the ASAM Criteria. Although not federally required, NORC conducted an analysis of MOUD access across Minnesota to assess for potential disparities among different communities.
Examining Potential Disparities in Medication-Assisted Treatment (DHS-8267)
DHS worked with eight different SUD providers to gather feedback on the Demonstration implementation. Topics of discussion include strengths, barriers, areas for improvement, as well as recommendations for SUD system alignments.
1115 Substance Use Disorder System Reform Demonstration Early Adopters Report (DHS-8234-ENG)
A condition of participation in 1115 SUD demonstrations is that DHS arrange with an independent party to conduct an evaluation of the demonstration to ensure that the necessary data is collected at the level of detail needed to research the intended outcomes of the demonstration. The state must require the independent party to sign an agreement that the independent party will conduct the evaluation in an independent manner and according to CMS’ Special Terms and Conditions and Evaluation Design Plan Template. DHS contracted with NORC at the University of Chicago (NORC) to serve as the independent evaluator for the demonstration. CMS approved NORC’s Evaluation Design Plan on Jul. 28, 2021.
The current 1115 SUD Demonstration continues through Jun. 30, 2024. DHS is required by law to request an extension from CMS of the 1115 Demonstration (Minnesota Statutes, Chapter 256B.0759 Subd. 8). That extension request will be submitted to CMS by Jun. 30, 2023 and, if approved, will move the Demonstration end date out five years.
DHS is dedicated to transparency and will share the extension request with its partners and the public. There will be two public hearings with an opportunity for providers and the public to provide feedback. Feedback from these hearings will be incorporated into the extension request before final submission.
The details of these two hearings will be announced on this page in the near future.
