Healthy Louisiana Substance Use Disorder 1115 Demonstration Waiver
To maintain access to care for beneficiaries in need of Opioid Use Disorder and Substance Use Disorder (OUD/SUD) services in residential facilities, Louisiana applied for and received approval of an 1115 Demonstration Waiver, effective February 1, 2018 through December 31, 2022. The waiver is necessary to provide services to beneficiaries residing in Institutions for Mental Disease (IMDs) for stays with durations longer than 15 days. An IMD is a hospital, nursing facility, or other institution of more than 16 beds that is primarily engaged in providing diagnosis, treatment or care of persons with mental diseases. CMS allowed the traditionally excluded use of IMDs but placed a day limit of 15 days on its usage. This waiver “waived” the cap of 15 days for Louisiana. As a result of waiver approval, Louisiana is able to receive federal financial participation (FFP), i.e. the Medicaid match, for the continuum of services to treat addictions to opioids and other substances.
1115 Approval and Special Terms and Conditions (STCs)
CMS approval of the demonstration waiver is conditioned on compliance with set Special Terms and Conditions (STCs). These STCs include an Implementation Protocol, SUD Monitoring Protocol, Mid-Point Assessment, and Evaluation Design and Reports. The Louisiana 1115 Approval letter contains the full list of STCs and the approved Implementation Protocol. In addition, CMS approved the SUD HIT Plan; which is the 1115 SUD Waiver Demonstration Milestone 5.0: Implementation of Strategies to Increase Utilization and Improve Functionality of PDMP.
The Louisiana Department of Health worked with Tulane University’s Department of Health Policy and Management to develop an evaluation design, to be used as a roadmap for conducting an evaluation of the 1115 waiver. On July 16, 2019, Louisiana received approval of the 1115 SUD Demonstration Waiver Evaluation Design.
1115 SUD Approved Monitoring Protocol
The OBH and BHSF teams worked to align Louisiana’s 1115 SUD Monitoring Protocol with the updated versions of the CMS section 1115 SUD demonstration technical specifications manual v2.0, monitoring reporting tools, monitoring protocol tools, and other feedback received from CMS. Louisiana’s 1115 SUD Approved Monitoring Protocol encompasses: required metrics supporting the Implementation Plan milestones; various Health Information Technology (HIT) measures; certain HEDIS and other quality measures; and baseline, annual goals, and overall demonstration targets. Louisiana received the approved monitoring protocol on June 3, 2020.
In accordance with the STCs, Louisiana must submit three (3) quarterly monitoring reports and one (1) compiled annual report for each Demonstration Year (DY). These reports include operational updates, performance metrics, budget neutrality and financial reporting requirements, evaluation activities and interim findings, and SUD health IT measures. All monitoring reports will be posted after CMS approval.