ASAM Submits Comments Regarding 2025 Regulatory Policy Changes to Medicare Advantage Plans

On January 5th, ASAM submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding its recent rules proposing policy changes in 2025 Medicare Advantage (MA) plans. ASAM welcomed CMS' proposals addressing network adequacy requirements for mental health (MH) and substance use disorder (SUD) services that further bolster Medicare enrollees' access to quality MA plans and services, including changes that limit medical necessity determinations and define the appropriate use of prior authorization. ASAM also specifically recommended changes related to CMS' proposals regarding 1) the expansion of network adequacy requirements for SUD services and 2) time and distance standards for SUD. For the former, ASAM recommended that at a minimum, CMS separate its proposed 'Outpatient Behavioral Health' category into 'Outpatient MH' and 'Outpatient SUD' categories, to better elucidate critical MH and SUD provider shortages; that CMS better specify the skills, training, and expertise of individual professionals included in an 'Outpatient SUD/Behavioral Health' "facility-specialty type" category; and that CMS separately track a "provider-specialty type" category of "Addiction Specialists" or "Addiction Medicine." For the latter, ASAM recommended that CMS shorten the time and distance standards for SUD to better align with CMS' corresponding standards for "Outpatient Clinical Behavioral Health (Licensed, accredited, or certified professionals)" in qualified health plans (QHP) that it established last year, and thus, better align with the chronicity of addiction. ASAM further urged CMS to ensure consistent time and distance standards apply across financing systems.

Read the letter here.