Today, the Centers for Medicare & Medicaid Services (CMS) released two State Plan Amendment (SPA) templates designed to streamline state submissions: the mandatory Medication Assisted Treatment (MAT) benefit at 1905(a)(29) of the Social Security Act (the Act) and the state plan option to cover Medical Assistance for Eligible Individuals Who are Patients in Eligible Institutions for Mental Diseases (IMD) at 1915(l) of the Act.
On March 9, 2024, section 201 of the Consolidated Appropriations Act, 2024 (CAA, 2024, Pub. L. 118-42) made the mandatory MAT benefit permanent by amending 1905(a)(29) of the Act to remove the end date of “September 30, 2025.”
Section 204 of the CAA, 2024 amended section 1915(l) to remove the end date of “September 30, 2023”, making this optional Medicaid coverage for certain individuals with a substance use disorder who are patients in certain IMDs a permanent state plan option. Section 204 of the CAA, 2024 also made additional changes to the requirements for maintenance of effort (MOE), review process for eligible IMDs, patient placement, utilization management, and provider assessments.
On November 19, 2024, CMS issued State Medicaid Director Letter (SMD) # 24-004 titled “Extension of Medicaid Coverage of Substance Use Disorder Treatment and Managed Care Medical Loss Ratio Provisions in the Consolidated Appropriations Act, 2024”, providing additional information regarding these requirements. CMS also made changes to the existing MAT template and created a new 1915(l) SPA template to comport with these amendments to the Act as a result of the passage of sections 201 and 204 of the CAA, 2024.
States should use the updated templates to replace their current state plan Supplement to Attachment 3.1 pages, for the MAT benefit at 1905(a)(29). States adding or updating state plan pages for the optional 1915(l) benefit will be required to utilize the template. States should submit state plan pages effective October 1, 2025, when all of the updated requirements are in effect. States must submit their SPA to CMS no later than the end of the quarter in which the effective date occurs (December 31, 2025). States should be sure to follow the current process for public notice and tribal consultation for state plan updates to these or related pages to ensure there are no gaps in coverage or payment.
These templates are available on the Medicaid SPA Toolkit page of Medicaid.gov.
