|CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD
The Centers for Medicare & Medicaid Services (CMS) on Wednesday released guidance to state Medicaid directors that clarifies how section 5052 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act permits institutions for mental diseases (IMDs) to provide treatment to Medicaid beneficiaries with at least one substance use disorder (SUD).
NABH was a driving force behind section 5052 becoming law and the NABH team has talked with CMS staff about the law’s implementation.
The guidance from CMS covers five key areas: requirements for beneficiaries, requirements for IMDs, requirements for states, maintenance of effort, and interaction with existing IMD policies. This NABH Issue Brief provides a summary of each of those areas.
Requirements for Beneficiaries
An eligible individual for section 5052 (the new IMD authority) is a person who is:
Requirements for IMDs
Eligible IMDs must follow reliable, evidence-based practices and make available at least two forms of medication as part of medication-assisted treatment (MAT). The two drugs may be offered on site upon request or furnished off site by a qualified provider in the community that has an arrangement with the IMD. IMDs “should also offer behavioral health services alongside MAT,” CMS noted.
Requirements for States
States are required to:
Maintenance of Effort
Interaction with Existing IMD Policies
Section 5052 does not prevent states from pursuing or conducting a section 1115 demonstration to improve access to, and the quality of, SUD treatment for eligible populations.
CMS is developing a state plan amendment and maintenance of effort reporting templates to assist states. Click here for specific guidance related to state plan amendment submission procedures, including guidance on developing comprehensive methodologies and bundled rates.
If you have questions, please contact Scott Dziengelski, NABH’s director of policy and regulatory affairs.
NABH Issue Brief: CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD
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