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Illinois Releases Draft 1115 Waiver for Behavioral Health Redesign

This week, we reviewed the draft Section 1115 Research and Demonstration waiver, released on August 26, 2016, by the Illinois Department of Healthcare and Family Services (DHFS). The 1115 waiver is proposed as part of the state’s broader initiatives around the State Innovation Model (SIM) design grant awards, the State Health Assessment (SHA), and the State Health Improvement Plan (SHIP), with goals of strengthening the state’s behavioral health care system, reducing silos in behavioral health care, and promoting greater integration of physical and behavioral health. The waiver specifically proposes the inclusion of a package of new benefits for individuals with severe mental illness (SMI) and substance use disorders (SUD), as well individuals nearing release from the Illinois Department of Corrections (IDOC) and Cook County Jail systems. DHFS estimates $1.2 billion in federal savings over the five-year waiver term, equaling a 2 percent spending reduction across all Medicaid spending compared to without-waiver spending estimates. DHFS is accepting comments on the draft 1115 waiver through September 26, 2016.

Proposed Benefits, Target Populations

The 1115 waiver requests Medicaid funding for six categories of new benefits, and proposes making these benefits available only for select target populations. The pilot target populations were selected based on stakeholder comments and other information, with the intention to match benefits with those most in need, and where they would be most likely to decrease total cost of care.

Benefit Target Populations
Supportive Housing Individuals with SMI, at risk of institutionalization or homelessness, or currently in permanent supportive housing
Supported Employment Services Individuals 14 or older with SUD, serious and persistent mental illness (SPMI), or serious emotional disturbance (SED) needing ongoing support to obtain and maintain a job
Services to ensure successful transitions from IDOC and Cook County Jail Medicaid-eligible IDOC-justice involved individuals within 30 days of release; Cook County detainees eligible for Medicaid managed care (and not previously enrolled in CountyCare, the Cook County Health and Hospital System’s managed care plan)
Extended-release injectable naltrexone; medication assisted treatment (MAT) services Medicaid-eligible individuals incarcerated at IDOC facility within 30 days of release
Lifting IMD exclusion for short-term residential SUD treatment Individuals with SUD needing short-term residential treatment
SUD case management Individuals with SUD receiving any ASAM (American Society of Addiction Medicine) treatment level of care but not receiving case management from other sources
Withdrawal management Individuals with SUD meeting ASAM criteria for withdrawal management
Recovery coaching for SUD Individuals with SUD seeking support for long-term recovery
Lifting IMD exclusion for short-term mental health treatment Individuals with mental health disorders needing short-term residential treatment
Crisis beds Individuals requiring psychiatric treatment but do not require inpatient stay
Intensive in-home services;
Respite care
Families and children (ages 5-21) with high behavioral health needs and/or SED at risk of transition to higher level of care

Additional Waiver Initiatives

In addition to the targeted benefit expansion, DHFS is proposing four initiatives aimed at increasing physical and behavioral health integration and expanding value-based payments in Medicaid.

  1. Behavioral and physical health integration activities: providing managed care organizations and providers with resources to pursue development of integrated health homes (IHHs). Illinois intends to design and implement IHHs, authorized through a Medicaid state plan amendment, and is requesting support around workforce integration, provider readiness assessment, encouraging partnerships and integration between physical and behavioral providers, the launching of disease-specific pilot projects, and data collection and reporting.
  2. Prevention services to address infant and early childhood mental health interventions: The waiver seeks to expand the Infant/Early Childhood Mental Health Consultation (I/ECMHC) program, targeting high-need areas initially, as well as rural Illinois.
  3. Behavioral health workforce-strengthening initiatives: developing and retaining a larger behavioral health care workforce and training providers around cultural and linguistic competency, promoting whole-person care.
  4. Medicaid funding to implement first episode psychosis (FEP) programs: creation of teams to respond to individuals experiencing initial onset of a Schizophrenias Spectrum Disorder. Illinois is currently developing a FEP program, and is requesting Medicaid funding to expand.

Public Comment, Public Hearings

As mentioned above, DHFS will be accepting public comment on the draft 1115 waiver through September 26, 2016. Additionally, the state will hold two public hearings – on September 8, 2016, in Springfield, Illinois; and on September 9, 2016, in Chicago, Illinois – to present the waiver proposal to and take comments and questions from interested stakeholders.

Link to Waiver Documents

Link to Draft 1115 Waiver
Link to Notice of Public Information

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