Comments and Questions to ARTS Manual Draft-
Chapter IV Outpatient Services (ASAM Level 1) p. 47-48
“Outpatient services (ASAM Level 1) as defined in 12VAC30-130-5080 shall be provided by a Licensed CATP or a registered nurse or a practical nurse who is licensed by the Commonwealth with at least one year of clinical experience involving medication management
Comments: although the above description includes RNs and LPNs, the outline of the outpatient services that follows it does not identify RNs or LPNs as eligible to perform any of the services. Is this an oversight? Please clarify.
Chapter IV p. 43
“Preferred Office Based Opioid Addiction Treatment (OBAOT) Preferred Office-Based Opioid Treatment (OBAOT services), as defined in 12VAC30-130-5060, shall be provided by a buprenorphine-waivered practitioner in collaboration with co-located licensed mental health professional and may be provided in a variety of practice settings. Opioid Preferred OBAT treatment services are allowable in ASAM Levels 1.0 through 3.7 excluding inpatient services. Please reference the Opioid Treatment Services Preferred OBAT and OTP Supplement to this provider manual for more detailed information.”
Comments: We are unable to find the supplement that defines addiction treatment services in addition to the opioid treatment services. The only supplement available to review is titled: Opioid Treatment Services Supplement. How can we review that important detailed information?
For SUD treated at a preferred OBAT, are we able to provide and be paid for care coordination? (We thought this would be addressed in the OBAT supplement, but although there are a number of changes to the OTS supplement, there is no mention of other substance use disorders.)
Did you intend for case management to be applied for SUD other than opioid? If yes, please consider providing care coordination regardless of primary substance use. This eliminates confusion, and possible additional required licensing and staff. The needs are the same for patients seeking treatment, regardless of their primary drug of choice. Care coordination is appropriate for all. As you know, a majority of SUD patients use multiple substances. OUD does not need to be separated from how we treat all SUD patients.
Supplement p.38
“Substance Use Care Coordination does not include maintaining service waiting lists, scheduling transportation rides or periodically contacting or tracking members to determine potential service needs that do not meet the requirements for the monthly billing.”
Comments: Care Coordination should absolutely include assisting patients with Medicaid transportation because the service is horrible. Patients are stranded for hours and unable to get anyone to help them despite repeated calls from the patient and our staff.