On August 23, ASAM submitted comments responding to Centers for Medicare and Medicaid Services’ (CMS) request for information on the Medicare Advantage (MA) program, requesting CMS strengthen network adequacy requirements to further support enrollee access to addiction care, and ensure health plans’ utilization management does not adversely affect enrollees’ access to medically necessary addiction care. To strengthen network adequacy requirements, ASAM strongly urged CMS to add a new provider-specialty type for Addiction Specialist Physicians, update MA plan network adequacy requirements to address SUD-specific facilities, identify incentives for MA plans to cover the full range of SUD providers and facilities as supplemental benefits and require that MA plans establish adequate reimbursement rates for SUD providers and services, and require additional criteria to ensure sufficient availability of SUD services and providers. To ensure that utilization management does not adversely affect enrollees’ access to medically necessary addiction care, ASAM recommended that CMS require MA plans to use policies, procedures, and tools that are fully consistent with The ASAM Criteria for medical necessity determinations, utilization management, and to appeal decisions concerning service type, service, intensity, level of care, continued stay, and transfer for SUD. 

Read the comments here.