First 1115 SUD IMD Waiver Evaluations Show Mixed Progress on State Milestones
Early summative evaluations of Section 1115 waivers allowing Medicaid payment for substance use disorder treatment in institutions for mental disease reveal uneven state performance on required milestones. The brief analyzes evaluation findings as states navigate waiver renewals amid evolving federal Medicaid policy. States must demonstrate progress on access to evidence-based treatment, use of opioid use disorder medications, and improved care transitions. The findings come as CMS continues to refine expectations for SUD IMD waiver demonstrations and states prepare renewal applications.
Managed care organizations in states with SUD IMD waivers face heightened scrutiny on network adequacy for residential treatment, care coordination for high-acuity members, and reporting on milestone achievement as CMS tightens waiver oversight.
Behavioral Health · Managed Care
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