On February 20, the Oregon Society of Addiction Medicine (ORSAM) submitted comments on Oregon's proposed Section 1115 waiver application, which would waive the Institutions for Mental Diseases (IMDs) exclusion for those residential treatment providers that deliver services consistent with the ASAM Criteria and provide evidence-based substance use disorder (SUD) treatment. The proposed 1115 waiver would also certify peer run organizations (PROs) as a separate entity for the purposes of reimbursement, and require that the Oregon Health Authority (OHA) explore alternative payment models for reimbursement of treatment for SUD. ORSAM also commented on Oregon's proposed State Plan Amendment, which would expand coverage to ASAM Level of Care 0.5 among other changes.

ORSAM's comments praised the proposed waiver for including an expansion of coverage by requesting an exemption from the IMD exclusion. ORSAM furthermore urged OHA to consider ASAM's alternative payment model, P-COAT, when exploring alternative payment models for the reimbursement of SUD treatment. Additionally, ORSAM cautioned against allowing PROs to bill separately under Medicaid, noting that it is vital that patients receive care from a treatment team led by an appropriately trained physician. The comments concluded by praising the proposed State Plan Amendment for expanding coverage to ASAM Level of Care 0.5. 

Read the Oregon proposed Section 1115 waiver application here.

Read ORSAM's comments here. 

Read more about P-COAT here.