Maryland Medicaid moving forward with expansion of residential drug treatment reimbursement 

Maryland’s battle to end the opioid epidemic, and the often-fatal overdoses that have marked the epidemic, has included a years-long push to expand residential drug treatment options for affected communities. Maryland Medicaid, in turn, has sought to expand its reimbursement of residential drug treatment provided by Institutions for Mental Diseases. 

That reimbursement request was approved by the federal government last year. On December 22, 2016, Maryland Medicaid was the third state in the nation to be granted a  waiver from the federal Centers for Medicare and Medicaid Services to provide residential substance use treatment with federal Medicaid dollars. Implementation will begin July 1, and preparations for the transition are under way. 

Since receiving this waiver, the state has been actively engaging with the provider community about the implementation of this effort through several public forums including the Medicaid Advisory Committee, Engagement with local health officers and their substance use partners, legislative hearings, and the Behavioral  Health Advisory Council.  After extensive engagement with providers and revisions in response to stakeholder suggestions, Medicaid sent advanced guidance to drug treatment services providers last week. Today, the program has filed regulations governing the drug treatment with the Joint Committee on Administrative, Executive and Legislative Review. 

The expansion, solidified in the program’s federally approved waiver, will enable providers to receive previously denied federal Medicaid  reimbursement, an obstacle that contributed to the opioid crisis here. Maryland Medicaid -- backed by Maryland Gov. Larry Hogan -- applied for a waiver (or an exception)​ from that federal restriction, to be able to win treatment options for more Marylanders. 
Medicaid’s expansion of treatment reimbursement and similar policies coincide with Governor Hogan declaring a state of emergency in Maryland and forming the Opioid Operational Command Center, which works to improve state and local agencies’ collaborations to raise awareness and to save lives.
The IMD Waiver will expand Medicaid reimbursement to include adult residential substance use disorder treatment July 1, 2017. The Department is phasing in such additional services as residential substance-use disorder services for pregnant women with children, drug-exposed newborns, individuals involved with the child welfare system and 8-507 treatment services January 2018; it will incorporate halfway houses in January 2019. 

By expanding services to the adult population, residential substance use disorder treatment providers will no longer face the 16 bed restriction and will be able to expand their capacity to serve more individuals as well as include more residential levels of care.  The federal IMD exclusion had prohibited Medicaid reimbursement for adults between the ages of 21 and 64 who are receiving services provided in an institution of more than 16 beds that is primarily engaged in providing diagnosis, treatment, or care of persons with mental diseases, however under this waiver, Medicaid is able to reimburse for this much needed service for adults. 
Two administrations within the Department of Health and Mental Hygiene -- Health Care Financing, which governs Maryland Medicaid, and Behavioral Health -- are working with local health departments and with treatment services providers to assist in the transition. 

“This service expansion enhances the continuum of services offered in Maryland to address the opioid epidemic available in a community-based setting,” said  Shannon McMahon, deputy secretary of the Health Care Financing Administration. “It will create opportunities for an enhanced referral process between levels of care.” 

The Department -- in conjunction with its Administrative Service Organization (ASO), Beacon Health Options -- has developed the workflow, which includes adding a new Medicaid provider type, drafting regulations, developing guidelines and finalizing a training schedule for this new service to go into effect on July 1, 2017. BHA has been meeting with the local jurisdictions for several months to introduce this service and review the existing services that are grant-funded and help prepare for the expected changes when the service is eligible for Medicaid reimbursement.  

The Department will hold a provider interest meeting on June 5 at the Behavioral Health Administration.  As part of this meeting, BHA will clarify staffing and clinical quality questions and Medicaid will walk providers through the application process for enrolling with Medicaid.  Beacon will also be on hand to give a brief outline of their system, particularly for new providers. Details will be sent through the local jurisdictions (local behavioral health authorities, core service agencies, and local addictions authorities)..  Also beginning in June, Beacon Health Options -- which is a vendor of the Department of Health and Mental Hygiene’s Behavioral Health Administration -- will offer training to providers on how to obtain authorizations and submit claims into its system.  Information for providers will continue to be disseminated through provider alerts, as well as across stakeholder meetings including monthly Provider Council, BHA meetings with the local addiction authorities and provider stakeholder groups bi-weekly as well as updates through the Maryland Medicaid Advisory Council. The department will also provide technical assistance to help providers comply with federal Medicaid requirements.

The regulatory process
Once the proposed regulations are published in the Maryland Register (ETA June 23), there will be a 30-day comment period -- during which the department will receive, review, consider and respond to comments from business owners, patient advocates and other concerned stakeholders. 

“It’s teamwork -- plain and simple,” said Health and Mental Hygiene Secretary Dennis R. Schrader. “The Governor is leading with his vision of Maryland beating the opioid epidemic. Maryland Medicaid got federal approval to secure more treatment reimbursement for people. The Department is working with our local health departments and treatment providers to make sure they’re compliant with federal regulations. We just want fewer of our loved ones dying from drugs and substance use disorder. We’re in this together.”