
November 29, 2023
Proposed Changes to Opioid Treatment: What They Will Mean for Providers, Payers, and Regulators
HMA Insights – including our new podcast – puts the vast depth of HMA’s expertise at your fingertips, helping you stay informed about the latest healthcare trends and topics. Below, you can easily search based on your topic of interest to find useful information from our podcast, blogs, webinars, case studies, reports and more.

Proposed Changes to Opioid Treatment: What They Will Mean for Providers, Payers, and Regulators

Health Management Associates (HMA) collaborates with state and federal agencies, health service providers, and community-based organizations to enhance access to comprehensive reproductive healthcare and address disparities in birth outcomes, particularly in the context of Medicaid. This involves evaluating and supporting the implementation of perinatal care models, addressing health determinants affecting birth outcomes, and overcoming barriers to reproductive health services. In an effort to inform these initiatives, Diana Rodin, an associate principal at HMA interviewed Swedish experts to understand the country’s universal, publicly funded maternity and reproductive healthcare system. The Swedish model emphasizes universal healthcare, generous socioeconomic supports, and collaborative team-based perinatal care led by midwives. Lessons from Sweden, such as the utilization of “kulturdoulas” for culturally aligned support, a consensus-driven decision-making approach, and a centralized perinatal data system, provide valuable insights for improving birth outcomes for Medicaid recipients in the United States.


As we look back at our 2023 Fall Conference on publicly sponsored healthcare held in October, we wanted to highlight a few key takeaways from the event:
The discourse highlighted pervasive issues such as silos that contribute to a lack of accountability within the system. There was a unanimous recognition of the imperative to eliminate barriers to access, accompanied by a resounding call for a pivotal transformation in payer models. Throughout the session, a prevailing theme underscored the critical need for fostering collaborative efforts across different sectors, emphasizing the creation of opportunities for cross-sector groups to work together.
Participants echoed a shared sentiment regarding the urgency of dismantling the current lacking system and replacing it with a more inclusive, patient-centered approach. The session served as a platform for thought-provoking discussions, inspiring innovative solutions to address the challenges in behavioral health, paving the way for a more effective and accessible system.
The three main conference themes – Equitable Access, Digital Innovation, and Value-based Care – were touched upon in many of the panels and plenary sessions.
HMA is committed to bringing together experts from across the healthcare spectrum, and advancing the conversation about ways to improve access, equity, and innovation in healthcare. In early March 2024, we will be offering an HMA Spring Workshop on value-based care in Chicago. Registration will open soon; to receive the invitation, please be sure you are subscribed to the HMA News and Events list.

Minnesota Department of Human Services partnered with HMA to study Minnesota’s home- and community-based services (HCBS) trends; changes in its demographics, including the experiences of diverse communities; and successful local and national HCBS models to inform future efforts to improve access to supports for older Minnesotans and their informal caregivers. The report outlines recommendations to help address several of the challenges outlined in the brief, and identified several areas for DHS to consider for future innovations.
HMA has extensive expertise in HCBS and long-term services and supports (LTSS). If you would like to learn more about what HMA can do for your organization, you can contact the report authors Susan McGeehan, Barry J. Jacobs, Chris Dickerson, Aaron Tripp, Erica Reaves, and Anya Yermishkin.

After more than two decades, SAMHSA and its Center for Substance Abuse Treatment (CSAT) is revisiting regulations governing opioid treatment programs (OTPs), as required by the 2023 Consolidated Appropriations Act passed by Congress. These new federal rules around treatment will change how medications are delivered to persons with opioid use disorder (OUD), offering opioid treatment centers a unique opportunity to advance person-centered care, and can build on the lessons learned from the flexibilities offered during the public health emergency.
This is a real opportunity to change how care is delivered. It will increase access to lifesaving medications, including:
These new changes will help alleviate admission barriers caused by workforce shortages and allow patients better access to medication and treatment. The increase in use of telehealth combined with medications for opioid use disorder (MOUD) will remove time and travel barriers for treatment, allowing persons treated with methadone and buprenorphine, including new persons, to be treated remotely.
What does this mean for the field?
OTPs have historically been reimbursed based on volume, with daily attendance as a steady source of revenue and a “captive” audience for counseling services. For persons with OUD to feel the full benefits of the new rule, changes will need to be made at all levels:
If you want to learn more about the changes ahead, HMA hosted a 3-part webinar series on the effect of proposed regulations on delivery of opioid treatment services. The series New Rules in Treatment of Opioid Addiction was aimed at helping stakeholders prepare for and adapt to these changes to ensure a successful transition for the people they serve. Our series focuses on three areas where changes can help those managing OUD:
Watch here:
Part 1 Opioid Treatment Providers
Part 2 Opioid State Payers – Aligning Incentives for Treatment
Part 3 Opportunities for State Regulators to Shape Policy and Regulation of Treatment
If you are ready to explore these changes in your organization, HMA can help. We have experience in:

Your organization’s success relies on understanding evolving market dynamics and navigating a complex statutory and regulatory environment. Drug, device, and diagnostic firms, from established to start-up, come to HMA when they want experienced partners who can help with regulatory strategy, coding, coverage, and payment solutions, investment strategy, navigating the complexities of federal and state law, or even creating new policy. HMA, working with our partner companies, provides consulting with depth and breadth throughout the life sciences sector and the broader healthcare industry.
We work with drug, device, and diagnostic companies and their trade associations, pharmacies, physician specialty societies, hospitals, health systems, and community health centers, as well as investment firms and their portfolio companies.
Before joining HMA, our team spent years as senior officials in Medicare and Medicaid; cabinet-level health secretaries; and policy advisors to governors and other elected officials. They also served as directors of large nonprofit and social services organizations, top-level advisors, and C-level executives. Our team is expert in federal and state policy, reimbursement, actuarial consulting, medical coding support, public affairs, and corporate development.
We help you navigate the complexities of FDA regulation to help with product development and marketing authorization strategies and regulation throughout the product lifecycle.
Regulatory policy counseling
Product development and target product profile
FDA authorization strategy
Post-approval compliance
Clay Alspach, Principal, Leavitt Partners
Eric Marshall, Principal, Leavitt Partners
We help your organization understand the commercial market for life sciences products and develop strategies to support patient access, product launches and growth, and value.
Market intelligence, including market, customer, and stakeholder analysis
Strategic planning, considering risk-based contracting, value-based care, and population health
Business development and strategy
Formulary and market access insights
Go-to-market and launch strategies
David Kulick, Managing Director, HMA
Spencer Morrison, Associate Principal, Leavitt Partners
Rebecca Nielsen, Managing Director, Leavitt Partners
Alex Rich, Managing Director, HMA
Experts in Medicare, Medicaid, and the commercial market, we help you understand and navigate the complexities of coding, coverage, and payment for approved products and develop and execute strategies to support product access and value.
Code assessment and recommendation
Coverage mapping and guidance
Payment strategy across settings
CMS engagement
Emerging technology strategies
Alternative payment model (APM) development
Payment change impact modeling
Amy Bassano, Managing Director, Medicare, HMA
Mark Desmarais, Principal, HMA
Zach Gaumer, Principal, HMA
Kevin Kirby, Managing Director, HMA
Rachel Kramer, Principal, HMA
Clare Mamerow, Principal, HMA
We help you understand how evolving Federal policy impacts your business and develop strategies for creating and advancing Federal policy that advances value and your business.
Congressional and Administration intelligence and strategy
Policy development and strategy
Multi-sector alliances to create and advance new policy
Policy modeling and CBO scoring projections
Clay Alspach, Principal, Leavitt Partners
Amy Bassano, Managing Director, Medicare, HMA
Mark Desmarais, Principal, HMA
Zach Gaumer, Principal, HMA
Kevin Kirby, Managing Director, HMA
Rachel Kramer, Principal, HMA
Clare Mamerow, Principal, HMA
Eric Marshall, Principal, Leavitt Partners
Sara Singleton, Principal, Leavitt Partners
Josh Trent, CEO, Leavitt Partners
Liz Wroe, Principal, Leavitt Partners
We help you understand how evolving State policy impacts your business and develop strategies to support product access and value in Medicaid programs.
State-related access issues
State policy impact modeling
State research support
Clay Alspach, Principal, Leavitt Partners
Stephen Palmer, Managing Principal, HMA
Matt Powers, Managing Director, HMA
Josh Trent, CEO, Leavitt Partners
We work with investment firms and their portfolio companies to provide insight that helps you invest wisely in the rapidly evolving healthcare marketplace.
Comprehensive due diligence studies
In-depth research projects
Billing and compliance reviews
Identification, analysis, and outlook on federal, state, and local reimbursement/regulatory issues
David Kulick, Managing Director, HMA
Alex Rich, Managing Director, HMA
A large national pharmaceutical manufacturer hired HMA, The Moran Company, and Leavitt Partners, both HMA subsidiaries, to assess the current pipeline of innovative therapies, examine current reimbursement policies to assess long-term compatibility with the adoption of innovative therapies and novel delivery mechanisms, and make policy recommendations to address any challenges identified through the process.

This week, our In Focus section reviews a wide-ranging proposed rule issued by the Centers for Medicare & Medicaid Services (CMS) on November 6, 2023. The rule would update various policies governing Medicare Advantage (MA, or Part C), the Medicare Prescription Drug Benefit (Part D), Medicare cost plans and Programs of All-Inclusive Care for the Elderly. These proposed policy reforms would implement changes related to Star Ratings, marketing and communications, agent/broker compensation, health equity, dual eligible special needs plans (D-SNPs), utilization management, network adequacy, and other programmatic areas. The proposals reflect the agency’s continuing focus on increasing program transparency, improving health equity, reducing the cost of care for Medicare beneficiaries, and expanding access to behavioral health services.
MA and Part D stakeholders are encouraged to provide CMS with feedback and analysis regarding the potential impact of these changes. Comments on the proposed rule are due by January 5, 2024. The final rule would take effect in contract year 2025.
CMS proposes regulatory changes intended to improve access to behavioral healthcare by adding certain provider specialties to the MA network adequacy standards as follows.
In 2018, Congress enacted new authorities pertaining to supplemental benefits for MA members with chronic health conditions. CMS refers to this category of benefits as Special Supplemental Benefits for the Chronically Ill (SSBCI). These services are available only to enrollees with ongoing conditions and who meet certain criteria established in the statute. In contrast to the general policy that MA benefits should be offered uniformly to all plan members, MA plans may offer SSBCI tailored to a qualifying individual’s specific medical diagnosis and needs.
Supplemental benefits, including SSBCI, are generally funded with MA plan rebate dollars. CMS notes that the number of MA plans that offer SSBCI—and the number and scope of SSBCI that individual plans provide—has increased since their introduction in 2019.
Under the proposed rule:
According to CMS, these proposals, if implemented, would better ensure that the benefits offered as SSBCI are reasonably expected to positively affect the health and well-being of chronically ill beneficiaries and guard against the use of MA rebate dollars for SSBCI that unsubstantiated.
In addition, CMS is proposing new policies to improve transparency regarding SSBCI so that beneficiaries are aware that SSBCI are only available to enrollees who meet the eligibility criteria. More specifically, CMS proposes to:
As noted previously, over the past several years, the number of MA plans offering supplemental benefits has increased. The benefits offered are broader in scope and variety, and an increasing amount of MA rebate dollars are being directed toward these benefits. At the same time, plans have reported that the number of enrollees who use many of these benefits is low.
For many years, CMS has set upper limits on the compensation that agents and brokers can receive for enrolling Medicare beneficiaries in MA and Part D plans. CMS believes that many MA and prescription drug payment plans, as well as third-party entities with which they contract, make structured payments to agents and brokers that circumvent these compensation caps.
CMS proposes several regulatory changes to the composition and responsibilities of an MA organization’s utilization management (UM) committee.
Beneficiaries enrolled in traditional Medicare and MA plans have the right to a fast-track appeal by an independent review entity (IRE) when their covered skilled nursing facility (SNF), home health agency (HHA), or comprehensive outpatient rehabilitation facility (CORF) services are being terminated. At present, quality improvement organizations (QIOs) function as IREs and conduct these reviews.
Furthermore, MA enrollees do not have the same access to QIO review of a fast-track appeal as traditional Medicare beneficiaries.
CMS proposes to:
According to CMS, these proposals would align MA regulations with the parallel reviews available to beneficiaries in traditional Medicare and expand the rights of MA beneficiaries to access the fast-track appeals process.
In the proposed rule, CMS expresses concern that a significant number of dually eligible enrollees receive Medicare services through one managed care entity and Medicaid services through another (misaligned enrollment), rather than from one organization (aligned enrollment. The proposed rule states that in the long run, “for dually eligible individuals who are in Medicare and Medicaid managed care, we believe that we should continue to drive toward increasing aligned enrollment until it is the normative, if not only, managed care enrollment scenario…. For dually eligible individuals that elect MA plans, we are focused on increasing enrollment in integrated D-SNPs: fully integrated dual eligible special needs plans (FIDE SNPs), highly integrated dual eligible special needs plans (HIDE SNPs), and applicable integrated plans (AIPs) [pages 286-287].”
To move in this direction, CMS offers several interconnected proposals as follows:
According to CMS, these initiatives would increase the percentage of dually eligible MA enrollees who are in plans that are also contracted to cover Medicaid benefits, thereby expanding access to integrated materials, unified appeal processes across Medicare and Medicaid, and continued Medicare services during an appeal.
Under existing regulations, CMS does not contract with and will not renew the contract of a D-SNP look-alike; that is, an MA plan that is not a SNP but in which dually eligible enrollees account for 80 percent or more of total enrollment. CMS proposes to lower the D-SNP look-alike threshold from 80 percent to 70 percent in 2025 and to 60 percent in 2026. CMS states that this proposal is intended to help address the continued proliferation of MA plans that serve high percentages of dually eligible individuals without meeting D-SNP requirements.
In addition, the proposed rule calls for:
The Health Management Associates Medicare team will continue to analyze these proposed changes. We have the depth and breadth of expertise to assist with tailored analysis, to model policy impacts, and to support the drafting of comment letters to this rule. For more information or questions about the policies described, contact our experts below.

CMS Proposes Significant Changes to Medicare Advantage and Medicare Prescription Drug Benefit Programs for 2025

When Love is Not Enough to Preserve a Forever Family for a Child

Families formed by adoption face unique challenges in their lifelong journey as adoptees, parents, and siblings. Adoption-competent mental health is a necessary resource for adoptive families. This November, we are honoring adoption as a vital permanency strategy and the importance of forever families in the lives of children and youth who need this sense of permanency, security, and wellbeing.
The Children’s Bureau, part of the U.S. Department of Health and Human Services Office of the Administration for Children and Families (ACF) created National Adoption month to increase national awareness of adoption issues, encourage the development of permanent relationships, and bring attention to the need for adoptive families to provide placement for teens in the U.S. foster care system. The theme for 2023, “Empowering Youth: Finding Points of Connection,” focuses on ways to provide opportunities and services that connect youth to their identity—including culture, background, interests, and ambitions – to support meaningful permanent relationships with adults.
Adoption Statistics
The following are key data from the fiscal year 2021 report for the Adoption and Foster Care Analysis and Reporting System.
In the U.S., as of September 30, 2021, there were 114,000 children and youth waiting to be adopted who were at risk of aging out of foster care without permanent family connections.
The National Council for Adoption reports an 18 percent decrease in adoptions from FY19-FY21, with over 19,000 children who aged out of foster care without a permanent family. There has been a 24 percent decrease in domestic adoptions from 2019-2020 and 93 percent decline in intercountry adoptions since peaking in 2004.[1] . These data points reflect the urgency of revitalizing adoption as an important tool for the wellbeing of children who need permanent loving families.
Recognizing that adoption is just the beginning of the family’s journey and the fact that adoptive families need special attention, especially when the children who have been adopted have suffered the trauma of entering the child welfare system, mental health treatment and resources are critical to the wellbeing of these families and the children in them.
Importance of Identity
Research has shown that strong cultural identity can contribute to mental health resilience, higher levels of social well-being, and improved coping skills, greater self-esteem, higher education levels, better psychological adjustment, and improved coping abilities.[2] But many youth in foster care often have lower cultural identity strength than those who did not experience foster care. This can lead to higher levels of loneliness and depression, lower self-esteem, and difficult psychological adjustments that in turn affect coping skills and learning.[3]
In her book You Should be Grateful, Angela Tucker offers many practical insights and tools aimed at nurturing identity and helping transracial families and adoptees to center around the cultural norms and experiences of the adoptees themselves.[4]
A Changing Landscape
Many states now have safe-haven laws where parents can drop off their babies without penalty at hospitals, fire stations or police department if they are not able to care for them knowing their babies will be cared for and placed in families through the child welfare system. At the same time there are many children and youth who languish in foster care waiting for a ‘forever family’ to adopt them. Thousands of teens in foster care are looking for the love, support, and encouragement that families provide throughout their lives—not just until they turn 18. Youth who were adopted from the foster care system when they are 16 or older may be able to access Education and Training Vouchers (ETV) of up to $5,000 per year. Those who were adopted from foster care when they are 13 or older are more likely to qualify for federal financial student aid because they do not have to count family income when applying.[5]
When it comes to medical and mental health benefits, qualifying families may receive federally funded monthly maintenance payments, and other support, often until a child turns 18 or 21, depending on the state where they live, and medical assistance until age 26 if they were in foster care at a certain age depending on the state. Recognizing the need for adoption competent mental health, the Federal Administration for Children and Families has awarded the Center for Adoption Support and Education the grant to build a national Center to Support Mental Health Services in the Child Welfare System.[6]
The recent Biden-Harris regulations strengthen services and supports for children and families in the child welfare system. These regulations require additional support for kinship families, and protections for LGBTQI+ youth and expansion of access to legal services for children and families entering the child welfare system. Congress could use the momentum from these regulations to make the Adoption Tax Credit fully refundable and extend it to legal guardians to assist with the financial resources of raising children.
The recent Supreme Court Dobbs decision will likely impact adoption trends, but that trend is still evolving and will need to be monitored before conclusions can be drawn.
How HMA Can Help
HMA assists organizations working in child welfare and adoption, and grounds our work in human-centered design, lived expertise, and change management and leadership principles in state and county program development. We can help support organizations working with children and youth in foster care or with adoption agencies by:
Visit the ACF website to learn more about National Adoption Month and find tools and resources to educate yourself and your community about how we can achieve better outcomes for youth in foster care.
If you have questions on how HMA can support your efforts in Child and Family Wellbeing, please contact our experts below.
[1] Adoption by the Numbers – National Council for Adoption (adoptioncouncil.org)
[2] Anderson, M., & L.O. Linares. “The Role of Cultural Dissimilarity Factors on Child Adjustment Following Foster Placement.” Children and Youth Services Review 34(4), 2012, 597-601.
[3] Children on AdoptUSKids – AdoptUSKids
[4] “You Should Be Grateful” Stories of Race, Identity and Transracial Adoption — Angela Tucker

The 23rd annual Medicaid Budget Survey conducted by The Kaiser Family Foundation (KFF) and Health Management Associates (HMA) was released on November 14, 2023 in the report: “Amid Unwinding of Pandemic-Era Policies, Medicaid Programs Continue to Focus on Delivery Systems, Benefits, and Reimbursement Rates”.
Survey results show that states expect a sharp increase in Medicaid spending that is a direct result of lower federal spending as Covid relief and enhanced matching declines. This budget pressure is compounded by increasing provider rates, workforce recruitment and compensation challenges, increased spending on behavioral health and maternity care, and spending on programs that improve health related social needs. These budget pressures will create a very challenging environment for state policy makers in the coming years.
The report was prepared by Kathleen Gifford, Aimee Lashbrook, Caprice Knapp, Beth Kidder from HMA and Leavitt Partner’s Bill Snyder; and by Elizabeth Hinton, Elizabeth Williams, Jada Raphael, Anna Mudumala, Robin Rudowitz from the Kaiser Family Foundation. The survey was conducted in collaboration with the National Association of Medicaid Directors (NAMD).

Today is World Diabetes Day, a day created to keep the importance of diabetes prevention and management in the public and political spotlight. One in every four U.S. healthcare dollars is spent on individuals diagnosed with diabetes, and more than half of that expenditure is directly attributable to diabetes. An estimated 37 million people in the U.S. have type 2 diabetes, and another 96 million (more than one out of every three people) have prediabetes, meaning they are at risk of developing type 2 diabetes.[i]
The urgency of preventing and managing type 2 diabetes is as applicable in correctional facilities as it is in populations in the community. Especially as there is an overrepresentation of populations that have a higher burden of prediabetes and type 2 diabetes in correctional facilities including individuals who:
Administrators of correctional facilities are responsible for the healthcare costs for individuals in their custody who have type 2 diabetes, and the cost of managing this condition in these settings is particularly high.
Fortunately, type 2 diabetes is preventable. One evidence-based and effective strategy for preventing type 2 diabetes is the National Diabetes Prevention Program (National DPP) lifestyle change program. This program is a year-long evidence-based program delivered over 22 sessions using a CDC-approved curriculum. Program participants are expected to lose 5−7 percent of their weight and engage in physical activity for 150 minutes each week.[ii] The National DPP lifestyle change program can be offered in person, online, through distance learning, or a combined approach and is led by a trained lifestyle coach.[iii] The program has been proven to reduce the risk of individuals with prediabetes developing type 2 diabetes by 58 percent (71 percent for people older than age 60).[iv] Projections in other settings that compare the cost of the National DPP lifestyle change program to the costs of treating type 2 diabetes show that the program is cost-effective.[v]
HMA recently published a white paper, “Implementing the National Diabetes Prevention Program Lifestyle Change Program in Correctional Settings,” describing how the National DPP lifestyle change program can be used to achieve cost savings and better health for people at risk of developing type 2 diabetes in correctional settings. There have been two successful implementations of the National DPP lifestyle change program to date. The first is described in the study “Prevention in Prison: The Diabetes Prevention Program in a Correctional Setting,” where 47 people from a federal correctional facility participated in a modified version of the National DPP lifestyle change program. Participants who completed the program demonstrated significant reductions in their body mass index and A1C levels. Weight loss in the study was similar to what participants of the National DPP lifestyle change program in the community typically achieve.[vi]
The second successful implementation is with the Wisconsin Department of Corrections (DOC), which has successfully offered the National DPP lifestyle change program in three correctional facilities. To date, 19 Wisconsin DOC staff have trained as lifestyle coaches and 131 individuals across the three facilities have participated in the program. The Wisconsin National DPP state quality specialist shared the following cohort data in 2018−2019:
Overall average weight loss was 8.3 percent during the year-long cohort, well above the National DPP lifestyle change program goal of 5−7 percent weight loss. The response from program participants was positive. Wisconsin DOC plans to scale the National DPP lifestyle change program to all appropriate facilities in the future.
For additional information, consult the white paper “Implementing the National Diabetes Prevention Program Lifestyle Change Program in Correctional Settings.”
If you would like to learn more about how HMA can help your organization implement a DPP program, contact our experts below.
[i] Centers for Disease Control and Prevention. The Facts, Stats, and Impacts of Diabetes. Accessed April 18, 2023.
[ii] Centers for Disease Control and Prevention. Research Behind the National DPP. Accessed on June 15, 2023.
[iii] National DPP Coverage Toolkit. National DPP Coverage Toolkit: Delivery Options. Accessed January 18, 2023.
[iv] Centers for Disease Control and Prevention. National Diabetes Prevention Program. Accessed December 19, 2022.
[v] National DPP Coverage Toolkit. Cost & Value. Accessed June 15, 2023.
[vi] Fine A, Gallaway SM, Dukate A. Prevention in Prison: The Diabetes Prevention Program in a Correctional Setting. Diabetes Spectrum. 2019;32(4):331-337.
