Minnesota continues to implement nationally recommended standards of care for individuals living with substance use disorder


Hannah Saunders


Under Minnesota’s  1115 Substance Use Disorder (SUD) System Reform Demonstration—approved by the Centers for Medicare and Medicaid Services (CMS) in 2019—the state piloted a new approach to improve access to SUD treatment for Medicaid members. The demonstration requires certain providers to adopt the American Society of Addiction Medicine (ASAM) levels of care. 

ASAM criteria is the nation’s most widely used set of guidelines to treat individuals with SUD and co-occurring disorders. Implementing ASAM criteria into the 1115 SUD demonstration assists with creating a long-term chronic disease model that uses evidence-based treatment methods. 

Kristine Preston, deputy assistant Commissioner of behavioral health at the Department of Human Services, told State of Reform that the state passed laws this year that added ASAM levels of care to Minnesota statutes. 

“Residential levels of care added to statute will be effective January 1, 2024, or upon CMS’ federal state plan approval, whichever is later. Outpatient levels of care will be effective January 1, 2025, or upon CMS state plan approval, whichever is later,” Preston said.

SUD providers required to enroll in the 1115 demonstration by Jan. 1st, 2024 include Minnesota residential treatment programs licensed under 245G.21 by DHS that are enrolled in Minnesota Health Care Programs (MHCP), Minnesota withdrawal management programs licensed under 245F by DHS and enrolled in MHCP, and out-of-state residential SUD providers that are enrolled in MHCP.

The initial 1115 SUD demonstration runs until June 30th, 2024. According to Preston, mandatory provider enrollment tracking efforts began in September of 2022. Minnesota’s DHS is in the process of applying for an 1115 SUD System Reform extension, and is currently in the public comment period.

“Implementing ASAM, which promotes a flexible, person-centered approach, allows programs to modify their service delivery to meet the needs of individuals they serve. The goal of implementing ASAM is to adopt standards that reflect the current state of science and practice for chronic care models that support a client to receive the right services at the right time according to cultural identity and needs, mental health needs, and other individualized clinical and support needs.” 

— Preston

Preston said the ASAM levels of care added to the state statute also require providers to meet the co-occurring capable requirements defined in state law, and residential providers are required to offer SUD treatment services using medications for opioid use disorder on-site, or facilitate access to SUD treatment services off-site. 

The 1115 SUD Reform Demonstration was one component of a broader set of goals relating to SUD system reform, Preston said. When the Minnesota Department of Human Services was implementing the 1115 SUD System Reform Demonstration, it also implemented a treatment initiative called Direct Access

“Direct Access allows an individual to go directly to a provider they choose to receive a comprehensive assessment and access care immediately,” Preston said. “Direct Access removes barriers of timing associated with going through a placing authority, allows for individual choice, and removes duplication of comprehensive assessments.”

A crucial component of the SUD Demonstration is the requirement for DHS to submit quarterly and annual reports to CMS. Preston added that DHS engages with internal and external partners through an evaluation workgroup, which assesses and analyzes outcomes in order to make recommendations for a data-driven response.