National Capital Treatment and Recovery (NCTR) wants to support the Department of Medical Assistance in their CMS request for an extension to continue to provide residential substance abuse treatment through the Addiction Recovery Treatment Services (ARTS) program.  NCTR has been providing substance use disorder treatment since 1962 and have a long history of leading the way in evidence base care for all people who are having trouble with alcohol and other drugs. 

Prior to ARTS and Medicaid expansion most individuals, who receive their benefits under the 1115 waiver, did not have options for appropriate services to treat substance use disorders.  We would have to refer individuals to their local community services boards who often had very little to offer them in terms of services.  Patients would end up in emergency rooms, jail or the morgue. 

When DMAS established the ARTS program, there was a significant increase in services available to those who need it.  As a provider of these services, we appreciate the opportunity to work with Medicaid members and have seen lives transformed as a result of these expanded benefits.  We commend DMAS recognition that treating this disorder not only saves money but saves lives. 

We want to bring some of our experience working with ARTS these past years to your attention to consider when finalizing your request to CMS.  Below are some points we hope you consider in your response.

• The cost of providing treatment continues to rise as the cost of resources (office supplies, food etc.), rents, and most importantly staff rise.  Capping reimbursement rates to rates that are at, or below current rates will discourage providers from accepting members. This will, as we know from pre-1115 waiver days, result in Emergency Room overcrowding
• Approved Length of Stays for members are short and often not sufficient to provide ample time for the member to regain health and participate in Outpatient (OP) services effectively.  So extended LOS and/or more utilization of ASAM Level 3.1 programs will be beneficial.
• Most Medicaid members have multiple co-occurring issues which increases the cost of treatment.  Finding OP psychiatric providers who accept Medicaid has been a challenge. 
• Providers are often at a disadvantage when working with members who do not function well.  Members often miss appointments due to the lack of dependable transportation.  Transportation has increased our cost of doing business and although transportation is not part of this request, the reality is that providers who serve Medicaid members have covered transportation expenses for members out of their revenues which negatively impacts our ability to improve quality programming.