March 28, 2024

Substance Use Disorder Stakeholder Newsletter

This newsletter provides information and updates from HCPF on House Bill (HB) 18-1136 and the Substance Use Disorder (SUD) benefit at Health First Colorado (Colorado's Medicaid program). Share this newsletter with your colleagues. Previous editions are on the SUD webpage: Ensuring Full Continuum SUD Benefits. Your feedback, ideas and questions are welcome and can be shared with us at hcpf_sudbenefits@state.co.us. 

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What’s New 


Transplant Patients with SUD Diagnosis – Protocol for SUD Treatment  


Members who are transplant recipients with an SUD diagnosis should receive comprehensive SUD treatment services in accordance with ASAM continuum of care guidelines. HCPF, in collaboration with Managed Care Entity's (MCEs), has developed an SUD treatment protocol for transplant recipients providing guidance regarding expectations for continuum of care SUD services for these members. The member’s MCE (Regional Accountable Entity (RAE) or Managed Care Organization (MCO)) is responsible to coordinate care when notified by a transplant team of the need for these services. 

Take Note


Sign up for next Quarterly SUD Provider Forum – April 3, 2024 


The Quarterly SUD Provider Forum is open to providers and other stakeholders to learn about policies, changes and expectations of service delivery and billing in the SUD continuum of care. This is a presentation-style meeting held quarterly on the first Wednesday of the month from 2:00 - 3:00 p.m. The next SUD Provider Forum is Wednesday, April 4, 2024. Review the Provider Forum Agenda and register via Zoom. 


Reminder on Updated Standard IA Approval Timeframes 


Effective January 1, 2024, minimum days for initial authorization (IA) for Residential level of care stays have been revised. The new minimums are more closely aligned with average lengths of stay seen for each level of care over the last 2 years. This change is intended to support a reduction in continued authorization (CA) requests. 


ASAM Level of Care (LOC) - Minimum Days Authorized 


3.1 - 30 days  


3.3; 3.5 - 20 days  


3.7 - 10 days 


3.2 WM – 5 (before CA) 


3.7 WM – 4 (before CA)  

Debunking Myths & Misinformation About Health First Colorado


Did you know...


SUD providers can deliver some laboratory testing services through a CLIA Certificate of Waiver.  


CLIA stands for Clinical Laboratory Improvement Amendments, and by the CLIA law, waived tests are those tests that are determined by CDC or FDA to be so simple that there is little risk of error. Some testing methods for glucose and cholesterol are waived along with pregnancy tests, fecal occult blood tests, some urine tests, etc. For more information, please see the How to Obtain a CLIA Certificate of Waiver brochure, as well as the list of CLIA waived CPT codes.  


All claims for laboratory services, including those rendered by non-laboratory providers such as physicians, must have the NPI number of the provider who ordered the items to be indicated on the claim. In the Provider Web Portal, this field is labeled "Referring Provider".  


The provider types who may order these services are physician (05), physician assistant (39), osteopath (26), certified nurse-midwife (22), advanced practice nurse (41), and pharmacist (75). Reference the Laboratory Services Billing Manual for further details. 

Other Things Happening in the SUD Space

 

HHS Makes Virtual Buprenorphine Prescribing Permanent 


A Final Rule by the Health and Human Services Department (HHS), published February 2, 2024, “modifies and updates certain provisions of regulations related to Opioid Treatment Program (OTP) accreditation, certification, and standards for the treatment of Opioid Use Disorder (OUD) with Medications for Opioid Use Disorder (MOUD) in OTPs. This includes making flexibilities put forth during the COVID–19 Public Health Emergency (PHE) permanent, as well as expanding access to care and evidence-based treatment for OUD.” 


At a high level, the new rule includes the following:  


  • Permanently allows buprenorphine to be prescribed through telehealth without an in-person visit. 
  • Allows providers more flexibility to offer take-home doses of methadone. 
  • Removes the one-year requirement for opioid addiction before admission to an OTP. 


HHS Finalizes New Provisions to Enhance Integrated Care and Confidentiality for Patients with Substance Use Disorder  


On February 8, 2024, HHS announced a Final Rule modifying the Confidentiality of Substance Use Disorder (SUD) Patient Records regulations at 42 CFR part 2 (“Part 2”). According to the Substance Abuse and Mental Health Services Administration (SAMHSA), “the final rule increases coordination among providers treating patients for SUDs, strengthens confidentiality protections through civil enforcement, and enhances integration of behavioral health information with other medical records to improve patient health outcomes.” 


For more information, see Fact Sheet 42 CFR Part 2 Final Rule

SUD Stakeholder Webpage