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U.S. Department of Health and Human ServicesAssistant Secretary for Planning and EvaluationDisability, Aging and Long-Term Care PolicyCREDENTIALING, LICENSING, ANDREIMBURSEMENT OF THESUD WORKFORCE:A REVIEW OF POLICIES ANDPRACTICES ACROSS THE NATIONNovember 2019

Office of the Assistant Secretary for Planning and EvaluationThe Assistant Secretary for Planning and Evaluation (ASPE) advises the Secretary of the U.S.Department of Health and Human Services (HHS) on policy development in health, disability,human services, data, and science; and provides advice and analysis on economic policy. ASPEleads special initiatives; coordinates the Department's evaluation, research, and demonstrationactivities; and manages cross-Department planning activities such as strategic planning,legislative planning, and review of regulations. Integral to this role, ASPE conducts research andevaluation studies; develops policy analyses; and estimates the cost and benefits of policyalternatives under consideration by the Department or Congress.Office of Disability, Aging and Long-Term Care PolicyThe Office of Disability, Aging and Long-Term Care Policy (DALTCP), within ASPE, is responsible for thedevelopment, coordination, analysis, research, and evaluation of HHS policies and programs.Specifically, DALTCP addresses policies and programs that support the independence, health, and longterm care of people of all ages with disabilities; that promote the health and wellbeing of older adults;and, that prevent, treat, and support recovery from mental and substance use disorders.This report was prepared under contract #HHSP233201600015 between HHS’s ASPE/DALTCPand the Human Services Research Institute. For additional information about this subject, youcan visit the DALTCP home page at ong-termcare-policy-daltcp or contact the ASPE Project Officers, Judith Dey and Kristina West, atHHS/ASPE/DALTCP, Room 424E, H.H. Humphrey Building, 200 Independence Avenue, S.W.,Washington, D.C. 20201;,

CREDENTIALING, LICENSING, ANDREIMBURSEMENT OF THE SUD WORKFORCE:A Review of Policies and Practices Across the NationNilufer IsvanRachael GerberDavid HughesKristin BattisEvan AndersonHuman Services Research InstituteJohn O’BrienTechnical Assistance CollaborativeNovember 2019Prepared forOffice of Disability, Aging and Long-Term Care PolicyOffice of the Assistant Secretary for Planning and EvaluationU.S. Department of Health and Human ServicesContract # HHSP233201600015The opinions and views expressed in this report are those of the authors. They do not reflect theviews of the Department of Health and Human Services, the contractor or any other fundingorganization. This report was completed and submitted on February 2019.

TABLE OF CONTENTSACRONYMS . ivEXECUTIVE SUMMARY .viiINTRODUCTION . 1Background . 1Study Overview . 2Research Questions. 2Organization of the Report . 3METHODOLOGY .5Environmental Scan .5Review of State Approaches to Licensing and Credentialing Substance UseDisorder Treatment Providers . 6Review of Billing Eligibility and Reimbursement. 6Case Studies . 8STATE APPROACHES TO LICENSING AND CREDENTIALINGSUBSTANCE USE DISORDER TREATMENT PROVIDERS. 10Career Ladder for the Substance Use Disorder Treatment Workforce . 10Licensure vs. Certification . 13State and National Credentialing Bodies . 14State Variation in Licensing/Credentialing Requirements . 15Discussion of Credentialing Policies: Barriers and Facilitators . 17BILLING ELIGIBILITY AND REIMBURSEMENT .25The Reimbursement Process .25Billing Eligibility Under Medicare .25Billing Eligibility Under Commercial Insurance Plans . 26Billing Eligibility and Reimbursement Under Medicaid . 27Alignment of Licensure and Independent Billing Eligibility . 30Discussion of Billing Eligibility and Reimbursement: Barriers and Facilitators . 31CHALLENGES AND LIMITATIONS . 38CONCLUSIONS AND IMPLICATIONS . 39REFERENCES. 42APPENDICESAPPENDIX A.APPENDIX B.APPENDIX C.APPENDIX D.APPENDIX E.APPENDIX F.APPENDIX G.Licensing and Credentialing Detailed Tables . A-1Reimbursement Detailed Table . A-40Sources Consulted for the Environmental Scan .A-42Detailed Methodology: Licensing/Credentialing Review .A-44Detailed Methodology: Billing Eligibility and Reimbursement .A-46Case Study Selection Methodology . A-48Case Studies .A-49i

LIST OF EXHIBITSEXHIBIT ES1. States Offering Licensure for SUD Counseling. viiiEXHIBIT 1.Billing Codes used in Review of Reimbursement Policies. 7EXHIBIT 2.SAMHSA’s Model Career Ladder and SOPs for the SUD TreatmentWorkforce . 10EXHIBIT 3.Number of States with at Least 1 SUD Treatment Credential, byCategory . 11EXHIBIT 4.Number of SUD Treatment Credentials by SAMHSA Category andTotal SUD Treatment Credentials, by State . 12EXHIBIT 5.States Offering Licensure for SUD Counseling. 13EXHIBIT 6.Variation across States in the Number of Credentialing Boards . 14EXHIBIT 7.Credentials Offered by the 2 National Certification Bodies . 14EXHIBIT 8.Variation across States in Affiliation with National CredentialingBodies. 15EXHIBIT 9.Minimum Degree Required to Attain the Highest Level of the SUDCounseling Career Ladder . 16EXHIBIT 10. Minimum Practice Hours Required to Attain the Highest Level ofthe SUD Counseling Career Ladder . 16EXHIBIT 11. SUD Counselors’ Eligibility for Independent Billing Status underUnitedHealth/Optum Commercial Plans . 27EXHIBIT 12. SUD Counselors’ Eligibility for Independent Billing Status underMedicaid . 28EXHIBIT 13. Number of States using Exact or Alternate Billing Codes among the8 Billing Codes Examined in this Study . 29EXHIBIT 14. Licensure Availability and Eligibility for Independent Billing Statusfor SUD Counselors under Medicaid and Optum, by State . 30EXHIBIT 15. Interconnected Barriers Experienced by the SUD CounselingWorkforce . 39EXHIBIT A1. SUD Treatment Career Ladder, by State . A-2ii

EXHIBIT A2. Requirements: SAMHSA’s Category 4--Independent SUDCounselor/Supervisor .A-8EXHIBIT A3. Requirements: SAMHSA’s Category 3--Clinical SUD Counselor .A-11EXHIBIT A4. Requirements: SAMHSA’s Category 2--SUD Counselor . A-16EXHIBIT A5. Requirements: SAMHSA’s Category 1--Associate SUD Counselor . A-20EXHIBIT A6. Requirements: SAMHSA’s SUD Technician Category .A-23EXHIBIT A7. Requirements: Clinical Supervisor . A-25EXHIBIT A8. Requirements: Peer Recovery Specialist . A-31EXHIBIT A9. Requirements: Prevention Specialist.A-34EXHIBIT B1. Exact and Alternative Reimbursement Codes by State . A-40EXHIBIT F1. Characteristics of Case Study States in Relation to National Levels . A-48iii

ACRONYMSThe following acronyms are mentioned in this report and/or appendices.AADCADCASAMASPEAdvanced Alcohol and Drug CounselorAlcohol and Drug CounselorAmerican Society of Addiction MedicineHHS Office of the Assistant Secretary for Planning and EvaluationBHCBHWRCBehavioral Health CollaborativeUniversity of Michigan Behavioral Health Workforce Research SCODCORCPSCPTCRPACSCSATCTACCouncil for Accreditation of Counseling and Related EducationalProgramsCertified Alcohol and Drug CounselorCalifornia Association of DUI Treatment ProgramsCredentialed Alcoholism and Substance Abuse CounselorCalifornia Consortium of Addiction Programs and ProfessionalsCertified Community Behavioral Health ClinicCertified Clinical SupervisorChildren’s Health Insurance ProgramCalifornia Institute for Behavioral Health SolutionsHHS Centers for Medicare & Medicaid ServicesCo-Occurring DisorderContracting Office’s RepresentativeCertified Prevention SpecialistCurrent Procedural TerminologyCertified Recovery Peer AdvocateClinical SupervisorSAMHSA Center for Substance Abuse TreatmentNew York Community Technical Assistance CenterD.C.DALTCPDEADHCSDHHSDMC-ODSDSRIPDUIDistrict of Columbia (also known as Washington, D.C.)ASPE Office of Disability, Aging and Long-Term Care PolicyDrug Enforcement Administration, U.S. Department of JusticeCalifornia Department of Health Care ServicesNorth Carolina Department of Health and Human ServicesDrug Medi-Cal Organized Delivery SystemDelivery System Reform Incentive PaymentDriving Under the InfluenceFFSFTEFYFee-For-ServiceFull-Time EquivalentFiscal YearHCPCSHHSHHSCHRSAHealthcare Common Procedure Coding SystemU.S. Department of Health and Human ServicesTexas Health and Human Services CommissionHHS Health Resources Services Administrationiv

IC&RCIMDIOMInternational Certification and Reciprocity ConsortiumInstitution for Mental DiseasesInstitute of OCADTRLPCLicensed Addiction CounselorLicensed Alcohol and Drug CounselorLicensed Alcohol and Drug Counselor--Mental HealthLicensed Chemical Dependency CounselorLicensed Chemical Dependency ProfessionalLicensed Chemical Dependency SupervisorLicensed Clinical Social WorkerLicensed Independent Chemical Dependency Counselor--ClinicalSupervisorLocal Management EntityLevel of Care for Alcohol and Drug Treatment ReferralLicensed Professional TMaster Addiction CounselorMedicaid and CHIP Payment and Access CommissionMedication-Assisted TreatmentManaged Care OrganizationNew York Managed Care Technical Assistance CenterMarriage and Family TherapistMental HealthMental Health Parity and Addiction Equity ActMaster Licensed Addiction and Drug CounselorMedicaid Managed CareMedicaid Redesign TeamN-SSATSNAADACNational Survey of Substance Abuse Treatment ServicesNational Association for Alcoholism and Drug Abuse Counselors (nowthe Association for Addiction Professionals)National Board for Certified CounselorsNational Certified Addiction CounselorNorth Carolina Substance Abuse Professional Practice BoardNational Clinical Supervision EndorsementNew Hampshire Bureau of Drug and Alcohol ServicesNational Survey on Drug Use and ew York Office of Alcoholism and Substance Abuse ServicesNew York Office of Mental HealthOffice of National Drug Control Policy, Executive Office of thePresident of the United StatesPLADCProvisional Licensed Alcohol and Drug CounselorRHPRSSRegional Healthcare PartnershipRecovery Support Servicesv

SAMHSASBIRTSNPSOPSPASTRSUDSUPPORTHHS Substance Abuse and Mental Health Services AdministrationScreening, Brief Intervention, and Referral to TreatmentSpecial Needs PlanScore of PracticeState Plan AmendmentState Targeted Response to the Opioid CrisisSubstance Use DisorderSubstance Use Disorder Prevention that Promotes Opioid Recoveryand Treatment (also known as SUPPORT for Patients andCommunities Act of 2019)TAP 21SAMHSA Technical Assistance Publication #21UCLAUniversity of California, Los AngelesVAU.S. Department of Veterans Affairsvi

EXECUTIVE SUMMARYIntroductionThe United States is experiencing a workforce shortage in the substance use disorder (SUD)treatment field, an issue that has received increased attention from policymakers and healthcare professionals due to its centrality in addressing the nationwide opioid epidemic. Multiplefactors--including limited insurance coverage for SUD services, low reimbursement rates, andlow salaries for treatment professionals--have made the SUD treatment field a relativelyunattractive specialization. And despite an expansion in insurance coverage for SUD services inrecent years, barriers presented by insurance-based payment often limit providers’ eligibility ordiscourage them from joining insurance networks, thereby preventing providers from usingtheir full capacity to appropriately treat people.In September 2018, the U.S. Department of Health and Human Services Office of the AssistantSecretary for Planning and Evaluation (ASPE) contracted with the Human Services ResearchInstitute to conduct a study of licensing and credentialing policies for SUD treatment providersacross the 50 states and the District of Columbia (D.C.) and to examine billing eligibility andreimbursement for SUD treatment services across Medicaid, Medicare, and commercialinsurance plans. The purpose of the project is to examine state variation in policies and toinvestigate the barriers to and facilitators of increased treatment capacity and insurancereimbursement for SUD providers across the nation.SUD treatment services are provided by a broad range of practitioners, including physicians,nurses, behavioral health counselors, social workers, psychologists, and many others. This studyfocuses on the SUD counselor segment of the workforce, as this segment is particularly impactedby licensing, credentialing, and reimbursement barriers due to the lack of standardization onqualifications and credentials.MethodsThe first phase of the project was an environmental scan to gather information about existingknowledge on this issue and to uncover knowledge gaps. The scan, which was conductedthrough a literature review and interviews with experts in the field, laid the foundation for areview of the various policies that regulate SUD provider credentialing, licensing, andreimbursement across the nation. Parallel to that review, we conducted in-depth case studies offour states that served as informative examples of innovative SUD workforce developmentstrategies and efforts to incentivize provider participation in insurance networks.vii

Key FindingsLicensing and Credentialing Substance Use Disorder CounselorsThere are multiple credentialing bodies for the SUD counseling profession, both at the nationallevel and within individual states. Nineteen (19) states (37%) have a single board that overseeslicensure and/or certification for all SUD credentials within the state, and the rest (63%) havemultiple boards offering different credentials, often with no state-level standards for minimumrequirements.Thirty-one (31) states (61%) offer licensure for SUD counseling; the remaining 20 states (39%)offer certification only (Exhibit ES1).EXHIBIT ES1. States Offering Licensure for SUD CounselingThere is wide variation in states’ respective career ladders for SUD counselors and ineducational and practice requirements for these credentials. To obtain the highest SUDcounseling credential available within the state, 37 states (73%) require a master’s degree, sixstates (12%) require a bachelor’s degree, four states (8%) require an associate degree, and threestates (6%) require only a high school diploma or equivalent. One state currently has nominimum degree requirement. The minimum number of required practice hours ranges from1,000 hours (equivalent to half a year) to 12,000 (6 years) for the states’ highest SUD counselingcredential.Based on the environmental scan, state review, and case studies, we identified the followingcredentialing-related barriers to entering the field and examples of initiatives to facilitate entry:viii

Barrier#1. Lack of standard credentials andinaccessibility of qualification informationFacilitator Efforts to establish national credentialsfor SUD counseling Within-state consolidation of certificationboards Centralized information disseminationand technical assistance to providers State licensure statutes and title/practiceprotections Efforts to establish core competencies andlink SUD credentials to academicprograms Student loan repayment programs#2. Low and non-standard training andeducation requirements for practiceBilling Eligibility and ReimbursementThe availability of state licensure regulations for SUD counselors facilitates their billingeligibility across public and private insurance plans. Our review identified only 11 states wherean SUD counselor is eligible for direct reimbursement from the state’s Medicaid plan as anindependent billing provider; all of them offer licensure for SUD counseling. In states wherethey are not eligible to enroll as independent providers, SUD counselors must work in afacility/program that is reimbursed on their behalf. UnitedHealth/Optum, the nation’s largestcommercial health insurer, requires a license as a prerequisite for independent billing status. AnSUD counselor is eligible in only 13 states (out of 50 states and D.C.) among Optum’scommercial plans, all states with licensure. While licensure is a facilitator, it by no meansguarantees billing eligibility across insurance plans.The following are key barriers and facilitators related to billing eligibility and directreimbursement of SUD counselors:Barrier#1. Lack of insurance coverage for SUDservices and low reimbursement ratesFacilitator Medicaid waivers to redesign servicedelivery and reimbursement systems Medicaid health homes and bundledservices Legislative efforts to enact state licensurestatutes Burden-sharing through pooling resources State supports for providers in contractingwith managed care organizations#2. Uneven availability of state-regulatedlicensure across the nation#3. Legislative, administrative, and financialburdens of joining insurance networks andfiling claimsConclusionsThis study revealed that the SUD counseling profession faces multiple interconnected challengesassociated with complex training, credentialing, and payment structures. Compared to othercounseling professions like clinical social work and marriage/family therapy, addictioncounseling is a less desirable specialty due to the difficulty in obtaining a credential or a license,low portability of credentials across state lines, relatively low earning potential, and multiplebarriers to establishing an independent practice, joining insurance networks, and filing claims.ix

The absence of a clearly defined career ladder specific to SUD counseling, often vague andinconsistent requirements for advancing within the profession, low reimbursement, andrelatively low earning potential have combined to make this an undesirable area ofconcentration in comparison to other behavioral health specialties. Despite the innovativeinitiatives to address these challenges and to facilitate entry into and advancement in the fielddescribed in this report, workforce shortages remain one of the key barriers to addressing thenational opioid crisis.Promising measures for addressing the workforce shortage include: The adoption of common addiction education standards as a condition of providing SUDcounseling. Increased availability of degree programs offering standard curricula in SUD treatment. Financial incentives including increased reimbursement, scholarships, and student loanrepayment programs that incentivize students to pursue advanced degrees in SUDtreatment.An additional approach to enhancing the workforce would be to introduce addiction as aspecialization track in behavioral health degree programs, with standards that address therequired core competencies of addiction counseling. This would incentivize students in theseprograms to enter the SUD field, building on the education and internships they completedduring their academic training. Such efforts would necessitate the collaboration of multiplecredentialing bodies, state agencies, and institutions of higher education.Systemic reform efforts that simultaneously address several interlinked barriers withparticipation from multiple state and national stakeholders hold the highest promise for thefuture of the workforce.x

INTRODUCTIONBackgroundSubstance use disorder (SUD) services have traditionally been underfunded, especially incomparison to other behavioral health services such as mental health treatment and family andmarriage therapy. For example, spending on SUD treatment services constituted only 1.0% oftotal health care expenditures in 2014, less than one-fifth of the share of mental healthexpenditures (5.9%). Moreover, no substantial change is projected in these shares through 2020(SAMHSA, 2014). In line with this difference in overall expenditures, earning potential of SUDcounselors is also lower than counselors in other behavioral health professions: In 2017, themedian salary for an SUD counselor was 41,070, compared to 46,890 for social workers and 49,170 for marriage and family therapists (MFTs) (U.S. Bureau of Labor Statistics, 2018). Lowand spotty coverage by public and commercial insurance plans and comparatively lower salarieshave made the SUD field a relatively unattractive specialization for counseling professionals,leading to a nationwide workforce shortage in the field (Ryan, Murphy, & Krom, 2012). Thisissue has received increasing attention from policymakers and health care professionals inrecent years due to its centrality in addressing the nationwide opioid epidemic (Commission onCombating Drug Addiction & the Opioid Crisis, 2017; Beck, Manderscheid, & Buerhaus, 2018).State and federal legislation during the past few decades, such as state parity rules, the 2008Mental Health Parity and Addiction Equity Act (MHPAEA), and several health market reforms,have considerably expanded insurance coverage for SUD services. More recent policy initiativesby the Centers for Medicare & Medicaid Services (CMS)--most notably Medicaid Section 1115waivers, which allow states to expand coverage for SUD services and to better integrate theseservices into their overall health care system--have further increased reimbursement options forthese services.To some extent, these policy changes encouraged SUD providers to join insurance networks.Data from the National Survey of Substance Abuse Treatment Services (N-SSATS) indicate thatthe proportion of SUD facilities that accept Medicaid payments increased by 16.4% between2010 and 2017. Acceptance of private insurance and Medicare payments also showed modestincreases during this period--by 11.1% and 9.4%, respectively. However, a substantial number ofSUD providers continue to operate outside of insurance networks. 2017 N-SSATS data show that30% of provider facilities do not accept private insurance payments, 36% do not acceptMedicaid, and 65% do not accept Medicare (SAMHSA, 2011; 2018a). The unmet need fortreatment continues to be of concern: According to the National Survey on Drug Use and Health(NSDUH), an estimated 19.7 million people aged 12 or older in 2017 met the clinical criteria foran SUD, whereas only 2.5 million received treatment at a specialty facility. Inability to pay fortreatment was a commonly reported reason for needing but not receiving treatment (SAMHSA,2018b). These numbers indicate an urgent need to increase the number of providers that acceptpublic and private insurance payments for SUD services.Increased coverage of SUD services in recent years has been accompanied by sweeping changesin the SUD treatment delivery environment, driven by factors such as increased emphasis onquality metrics and service integration as requirements for joining insurance networks (Buck,2011). Recent advances in SUD treatment approaches have contributed to this changingenvironment, adding new competency requirements for practitioners. Additionally, public and1

private insurance plans are increasingly requiring certification--and in many cases, statelicensure--as a condition for joining their networks (Hagedorn, Culbreth, & Cashwell, 2012). Onthe other hand, certification requirements and related education programs in the addiction fieldhave been falling behind emerging competency requirements for the past two decades(Mustaine, West, & Wyrick, 2003), resulting in an underqualified workforce facing barriers tojoining insurance networks.Although states are beginning to revise their certification and licensing policies for SUDproviders to address these barriers in the long run (Boozang, Bachrach, & Detty, 2014), theshort-term impact of these system redesign efforts has been an increase in SUD workforceshortages and continued barriers to joining insurance networks as the existing practitioners andnew professionals catch up with network requirements (Andrews et al., 2015). The initial step inaddressing these issues is to understand the barriers to developing an adequate SUD workforceand the credentialing, licensing, and reimbursement policies that prevent or discourage SUDservice providers from joining insurance networks.Study OverviewThe main purpose of this study is to investigate the barriers to and facilitators of increasedtreatment capacity and insurance reimbursement for SUD providers across the nation. SUDtreatment services are provided by a broad range of practitioners, including behavioral healthcounselors, recovery specialists, social workers, psychiatrists, psychologists, primary care andemergency physicians, nurse practitioners, pediatricians, and obstetricians. This study focuseson the sector of this workforce most impacted by the certification, licensing, and reimbursementbarriers mentioned above: addiction counselors. In the rest of this report, we refer to thisworkforce segment as the “SUD treatment” or “SUD counselor” workforce, while acknowledgingthat it is a specific sector of the broader group of professionals who provide addiction-relatedtreatment services. Although substance use prevention workers constitute a separate careerladder, there are points of intersection between the two such that it is possible to move to thetreatment ladder from some rungs of the prevention ladder. We therefore included theprevention workforce in our state review of credentialing and licensing policies.The first phase of the project involved an environmental scan, which consisted of a literaturereview and interviews with experts in the field, to gather information about existing knowledgeon this issue and to uncover knowledge gaps. The environmental scan laid the foundations for areview of the policies that regulate SUD-specific

LCDC Licensed Chemical Dependency Counselor LCDP Licensed Chemical Dependency Professional LCDS Licensed Chemical Dependency Supervisor LCSW Licensed Clinical Social Worker LICDC-CS Licensed Independent Chemical Dependency Counselor--Clinical Supervisor LME Local Management Enti

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