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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 Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here Additional Ideas Add Here 6 Statute or Rule # being changed What would the change do? Budget and/or Policy