Download Reform Concepts Under Consideration

Alcohol and Drug Abuse Division
Reform Concepts Under Consideration
Based on Stakeholder Input
Short
Description of
the Change
CD Treatment
Program
Standards
Statute or Rule #
being changed
What would the change do?
Budget and/or
Policy
Repeal Rule
31/Create new
chapter in
statute
Add peer recovery support services and care coordination as treatment
services in a CD program. Define the new services and identify training
and qualification requirements for individuals who will be providing the
services.
§Both
Add to the list of
vendors in MN
§254B (direct
reimbursement?
RCOs? add care
coordination
and peer
support as
CCDTF
services/fix
culturally
specific
language
1
Look at potential for permitting publically funded treatment services to
be provided outside of a licensed program, such as via direct
reimbursement, and increase opportunities for services to be provided
outside of a CD facility to increase access to the services.
Look at opportunities for Counties to provide Care Coordination and/or
case management, and possibly the comprehensive assessments for
placement purposes under a direct access model (when done by an
appropriately credentialed professional.) Consider what eligible vendors
for the new services would be.
Will have to clarify language delineating “care coordination” and “case
management”. Vendors/providers must have some minimum standards to be
determined. (Keep in mind a major effort going on now to “Redesign Case
Management” by our administration)
Short
Description of
the Change
Statute or Rule #
being changed
What would the change do?
Modify “updating” treatment plan and progress notes. Consider that updating
the treatment plan should focus on the active issues being addressed by the plan, and
not need to cover everything (all 6 dimensions) if nothing is happening in the
Treatment plan in 3 of the 6 dimensions. Also, consider that treatment plan review
and progress notes could be the same thing. Plans should continue to be prioritized
according to client need and focus, i.e. client driven/centered.
Modify language for comprehensive assessment to align with direct access
process, (might be phased in) and the language relating to “initial service plan”
as it become more a part of the direct access and comprehensive assessment.
Modify “termination” language, if needed.
Update language related to licensure, temporary permit, etc. Review individuals
with an exception to license requirements in response to stakeholder concerns.
Consider whether the identified licensees have a scope of practice that includes
the work Rule 31 permits them to do (if they meet additional education and
internship requirements of Rule 31.)? What is permitted role of other
professionals- can they do a comprehensive assessment? Or an assessment
summary? Will also need to update the language on co-occurring mental health
and substance use disorder training needed.
Will need to consider whether program treatment services can be
provided off-site. (Will align with policy behind direct reimbursement)
Can a comprehensive assessment be provided off site?
Client education as a reimbursable service would benefit from further
clarification of the parameters of the service, with description and controls for
staff credentials, and also a corresponding consideration of whether a rate
adjustment is appropriate (CMS approval?).
2
Budget and/or
Policy
Short
Description of
the Change
Statute or Rule #
being changed
What would the change do?
Client records language will need modification because of Electronic Health
records and telehealth.
Language will also need modification regarding percentage of “indirect services”
tracking as it is not useful and onerous as it is written, and does not protect the
public, the patient, or the provider’s staff.
There will also need to be updated language regarding photos or other recorded
images in this age of cell phones.
Early implementers group: the tribal pilot sites are currently testing the model
of care services. Reform conversations should include whether additional early
implementation efforts should be undertaken.
Placeholder: if changes due to IMDs
Direct Access
Repeal Rules
24 and
25/amend
254B to create
new
service/eligible
vendor
Permit direct access to treatment services via a treating provider and
remove counties from the placement process.
Can care coordination meet medical necessity even if severity levels for
placement in formal treatment are not noted? Would permit secondary
prevention and motivational interviewing, which could prevent an escalation of
a client’s severity of symptoms, which would correspond with preventing future
needs for higher intensity services, or perhaps even prevent the need for any
formal treatment in the future, if the services are provided early enough in the
client’s disease progression.
Who can be a vendor? Must it be CD program or could a direct reimbursement
professional do this?
Will need to address CHATS/MMIS systems requirements.
3
Budget and/or
Policy
Short
Description of
the Change
Direct
Reimbursement
Statute or Rule #
being changed
254B
Opioid Omnibus Rule 31, Rule 25
Bill
4
What would the change do?
Can a provider refer to itself? Parity would suggest yes, with behavioral health
and medical services. What is it for MH and medical? What would appropriate
controls and utilization review look like?
Permit third-party reimbursement for individual providers of treatment
services for providers who meet heightened (advanced degree) credentialing
requirements.
Permit provision of CCDTF services at a site other than a treatment facility and
provide Medicaid reimbursement for these services. Will need to establish
controls.
Potential legislation related to opioids, in collaboration with other DHS work
areas including:

Modify CD program standards to prevent programs from declining to
admit an individual who is prescribed any sort of medication as part of a
medication assisted treatment service.

Modify the placement matrix to support referral to office-based opioid
treatment, such as a primary care clinic.

Expand definition of Opioid treatment programs to include both agonist
and antagonist medications, and to serve those whose route of
administration was not only intravenous.

Eliminate the per diem reimbursement methodology of Opioid
Treatment Programs, but retain the basic per diem for the medications,
and allow OTPs to bill for non-residential services hourly. The
reimbursement method would need to support additional staffing
requirements for providing the services in order to sustain this new
methodology.
Budget and/or
Policy
Short
Description of
the Change
Statute or Rule #
being changed
What would the change do?

Withdrawal
Management
Funding
Medical
assistance
statute/ County
Mandate statute
Workforce
development
254B, 148F
Background
studies
245C
Adolescents/
Recovery
Schools
?
Repeal
Gambling
Report
Housing
5
Language will need modification if naloxone is stocked on site of a
licensed 31 program as it is a prescription medication being kept “in
case of need” and not specifically prescribed to anyone.
Non-federal share?
Placeholder: if changes due to IMDs
Will Rule 32 continue to exist during the phasing in of withdrawal management?
What is end game re: Rule 32?
Incentives to increase rural capacity/capacity within cultural groups.
Work with stakeholders to define heightened credentials permitting direct
reimbursement for the individual provider, not just the program.
Work with the Office of Inspector General (OIG) to consider changes that are
specific to CD, for counselors and recovery coaches. Also, for people reentering
employment subject to DHS background study after having criminal activity
related to CD. Is there room for movement with disqualifications (DQs), setasides, and permanent DQs?
Use direct reimbursement with CCDTF funds to support provision of CD
counseling in schools without requirement of program license. Work with OIG
to develop controls.
Identify unique needs of adolescents and identify system changes necessary to
address those needs.
Repeal Gambling report that requires annual report that identifies the
proportion of gambling revenue that comes from problem gamblers.
256I
Look at group residential housing language to see if additional safe sober
housing can be made available; examine other options for creating and
supporting safe affordable housing options
Budget and/or
Policy
Short
Description of
the Change
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6
Statute or Rule #
being changed
What would the change do?
Budget and/or
Policy