Last week, the Centers for Medicare and Medicaid Services (CMS) issued new guidance to State Medicaid Directors on section 1115(a) demonstrations designed to improve quality of and access to treatment for addiction. This new direction supersedes previous guidance and is intended to streamline the review of section 1115(a) demonstrations. It also encourages states to engage in demonstrations that provide the full continuum of care for people with addiction, including in residential and inpatient treatment centers where Medicaid reimbursement is limited or nonexistent.

The American Society of Addiction Medicine (ASAM) commends CMS for issuing this new guidance which expands access to care and requires states to align their section 1115(a) demonstrations with certain goals and milestones. Milestones include using evidence-based guides, such as The ASAM Criteria, for patient placement; maintaining adequate provider capacity at each level of care; utilizing nationally recognized program standards, such as those in The ASAM Criteria, to set residential treatment provider qualifications; and improving care coordination. This new policy is a step in the right direction and aligns with some of the previous recommendations made by ASAM and the President’s Commission on Combating Drug Addiction and the Opioid Crisis.  

ASAM, however, also urges CMS to ensure that treatment provider assessments for all addiction treatment services, levels of care, and length-of-stay recommendations, as well as methods of residential treatment provider qualification, are performed by an independent third party that has the necessary competencies to use The ASAM Criteria (or such other evidence-based patient placement assessment tools and nationally-recognized program standards, as applicable). More than 30 states already use The ASAM Criteria, and with this combination of steps, our country can further improve the quality of care so that only evidence-based treatment is covered by Medicaid. Specifically, ASAM has several ways to assist states in implementing section 1115(a) waiver requirements, including a suite of ASAM Criteria assessment tools called CONTINUUM, The ASAM Criteria Decision Engine™. Dr. Kelly Clark, president of ASAM, had this to say about the new guidance from CMS:

“ASAM welcomes this move by CMS which advances evidence-based care and accountability in treatment. It’s important that people get the right care, in the right place, and at the right time by using evidence-based criteria such as The ASAM Criteria. This new policy goes a long way toward ensuring that patients can feel confident that the kind of treatment recommended and being received is consistent with good medical care standards. We look forward to working with Congress, the administration, and our partners at the state and local levels to ensure that funding is utilized in the most efficient and effective way to combat this epidemic.”

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