Objectives:  To analyze the various provisions of the SUPPORT Act and look for the common threads that guide providers or payers to a cohesive and unified strategy for technology-enabled patient engagement and care collaboration, both to comply with the SUPPORT Act and to advance the larger goals of improving health outcomes while lowering cost. This analysis should be valuable to policy makers as well as providers and managed care organizations that will be affected by the SUPPORT Act.

Methods: First, we searched the Support Act for Sections that pertain to technology-enabled patient engagement and care collaboration. This could include either a direct reference or an indirect reference through evidence-based practice that has a significant technology component.  Then we read those Sections that met the search criteria and, where appropriate, tracked them back to the underlying legislation, regulations or evidence-based practice.  After summarizing the results in a spreadsheet, we evaluated and scored each Section according to the following 5-point scale:

    5              Strong requirements for patient engagement and care collaboration (PECC) including funding

    4              Strong requirements for PECC but does not include funding within the SUPPORT Act

    3              Weak or indirect incentive for PECC with some funding

    2              Could be an incentive, depending on the payer/provider but with limited or no funding

    1              Sounds good but no real substance.

    0              No value

Based on the above, we considered how each Section fits into a larger framework for technology-enabled patient engagement and care collaboration.  From this we made observations and drew conclusions about the impact the SUPPORT Act could have for providers and payers, particularly addressing the extent to which the separate sections of the SUPPORT Act contribute to a unified framework for patient engagement and care collaboration.

Results:  We identified 18 Sections of the SUPPORT Act that met the first criterion pertaining to technology-enabled patient engagement and care collaboration technology.  Of these, 2 scored a 3 with weak or indirect incentives, 4 scored a 4 with strong requirements for PECC but without funding and 0 scored a 5 indicating they had both a requirement and funding for PECC.  We determined that all those that scored a 3 or above should be included for further analysis because they have the potential to individually or collectively contribute to an improvement in opioid treatment and the advancement of a technology-enabled integrated continuum of care.

Following are the 6 Sections that we scored a 3 or above.

Section 1003 Demonstration Project to Increase Substance Use Provider Capacity under the Medicaid Program

The purpose of Section 1003 is “to increase the treatment capacity of providers participating under the State plan (or a waiver of such plan) to provide substance use disorder treatment or recovery services under such plan (or waiver).”  The Section does not expressly define “treatment capacity” but refers to “the number or treatment capacity of providers participating under the State plan (or waiver).”  Thus, a reasonable interpretation of this Section allows that increasing treatment capacity could include measures to improve the efficiency of providers through technology-enabled solutions. 

This demonstration program has two parts:  an 18-month planning grant, followed by a 36-month demonstration program grant.  Ten states will be selected for the planning grants and 5 states will be selected for $10 million each ($50 million total) for the demonstration grants.  Applications for the planning grants were due in April 2019. Because technology is not expressly called out but implied and does include funding, we rank this as a 3.

Section 1006 Medicaid Health Homes for Substance Abuse Disorder Medicaid Enrollees

Extends enhanced federal matching rate for new Medicaid health home activities targeted to beneficiaries with SUD from 8 quarters to 10 quarters for State Plan Amendments (SPAs) approved on or after 10/1/18.

While the section calls for the expansion of health homes, it does not suggest the role that technology should play in Medicaid health homes.  Thus, there may be value for technology-enabled patient engagement and care collaboration in support of health homes, but this is an indirect incentive, not a direct requirement.  We rank this as a 3.

Section 5031-5032 Promoting State Innovations to Ease Transitions Integration to the Community for Certain Individuals

This Section provides guidance for offender reentry, for people following release from incarceration.  It requires the HHS Secretary to issue a state Medicaid director letter within 1 year of enactment regarding Section 1115 demonstrations to improve transitions for individuals moving from incarceration to the community.  The Secretary’s letter must address a range of health topics including systems for assistance and education about Medicaid enrollment and providing health care services 30 days prior to release, based on best practices identified by Secretary-convened stakeholder group.

This Section promotes patient engagement and care coordination between criminal justice, health insurers (Medicaid), behavioral and physical health providers and social service providers. It includes a request for “Innovative Service Delivery Systems Demonstration Project Opportunities” which can include PECC solutions. 

While the SUPPORT Act does not provide additional funding for these demonstration projects, it encourages states to apply for 1115 waivers that would allow communities and agencies to bill Medicaid for these patient engagement and care collaboration services including technology. Because this Section expressly requests innovative service delivery systems demonstration projects that can include technology-enabled patient engagement and care collaboration systems with funding through 1115 waivers, we rank this a 4.

Section 7183 Career Act

This Section provides for employment services for people with substance use disorder.  It requires the HHS secretary to establish a program to support individuals in substance use disorder treatment and recovery to live independently and participate in the workforce. For a period of 5 years, the Secretary will award grants on a competitive basis to assist entities to conduct evidence-based programs to help individuals with substance use disorder to recover and live independently including through participation in the workforce. The term “eligible entity” means an entity that offers treatment or recovery services for individuals with substance use disorders, and partners with one or more local or State stakeholders, which may include local employers, community organizations, the local workforce development board, local and State governments, and Indian Tribes or tribal organizations, to support recovery, independent living, and participation in the workforce. With respect to evidence-based practice, the Department of Labor publishes recommended EBP guidelines that have been translated into technology-enabled patient engagement solutions. Because this Section includes an indirect incentive and includes funding, we rank this Section as a 3.

Section 6032 Action Plan on Recommendations for Changes Under Medicare and Medicaid To Prevent Opioid Addictions and Enhance Access to Medication Assisted Treatment

The main takeaway from this Section is the expansion of access to medication assisted treatment for substance use disorder.  The term “medication-assisted treatment” includes behavioral therapy as well as medications to treat substance abuse disorder. Previous studies have shown that technology can significantly improve treatment for people with substance use disorder and can help increase capacity by improving operating efficiency.  The extension of technology-enabled solutions to include medication assisted treatment is a significant opportunity.  However, because this Section does not expressly suggest a role for technology in support of medication assisted treatment, we rank this Section as a 3.

Section 1018 Technical Assistance and Support for Innovative State Strategies to Provide Housing-Related Supports Under Medicaid

This Section is intended to provide housing-related supports and services and care coordination services under Medicaid to individuals with substance use disorders.  While this Section does not mention either technology or evidence-based practice, both SAMHSA and HUD promote the Housing First model for integrated housing and treatment for SUD.  The Housing First model does not require but strongly encourages clients to participate in a range of supporting services including those for addiction, employment and criminal justice re-entry.  Thus, this Section’s focus on “the development and expansion of innovative State strategies (including through State Medicaid demonstration projects), constitutes a strong, funded incentive for technology-enabled patient engagement and care collaboration.  Because of the strong alignment with SAMHSA and HUD Housing First models, and because funding is provided indirectly through 1115 waivers, we rank this Section as a 4.

Discussion:  While the SUPPORT Act does not explicitly call for technology-enabled patient engagement or care coordination, taken together these six Sections create a strong case for a configurable technology-enabled patient engagement and care collaboration platform.  Nonetheless, the SUPPORT Act by itself is not enough to result in significant innovation and adoption of HIT.  To be successful, the incentives of the SUPPORT Act, must be supported by easy-to-use, cost effective and flexible technology solutions as well as by leadership, particularly by managed care organizations which bear the responsibility of coordinating state policies and programs with providers across the continuum.  Thus, the SUPPORT Act could be a significant step forward–if technology vendors meet the challenges and if MCOs show true leadership.

Recommendation/Conclusion: The SUPPORT Act is intended to be a catalyst to promote technology-enabled care to address the opioid crisis, but by itself it is not enough.  MCOs have the most to gain and the most to lose through their response to the opportunities created by the SUPPORT Act.  For MCOs, the SUPPORT Act creates a rare opportunity to establish a true leadership position for the technology-enabled continuum of care.

The next step is at the state and community level, to conduct a cost benefit analysis of implementing a unified technology platform that addresses the opportunities presented by SUPPORT Act as a whole.