The Recovery Incentives Program: California's Contingency Management Benefit Frequently Asked Questions
This site includes the Department of Health Care Services' (DHCS) responses to frequently asked questions (FAQs) from Drug Medi-Cal Organized Delivery System (DMC-ODS) county representatives and provider sites participating in the Recovery Incentives Program and offering contingency management (CM) services. Find additional information about the Recovery Incentives Program on the
DHCS website, and submit additional questions to
RecoveryIncentives@dhcs.ca.gov.
Contents
Recovery Incentives Program Overview
County & Provider Participation in the Recovery Incentives Program
Member Eligibility for the Recovery Incentives Program
Recovery Incentives Program Treatment Protocol
Staffing
Reimbursement for CM Services
Provider Outreach
Incentive Payments & the Incentive Manager Portal
Urine Drug Tests (UDTs) & Clinical Laboratory Improvement Amendments (CLIA) Waiver Requirements
Readiness Assessment Process
Acronyms & Abbreviations
The below table is a lost of common acronyms/abbreviations used throughout the FAQ.
AKS
| Anti-Kickback Statute
|
ASAM
| American Society of Addiction Medicine
|
AEVS
| Automated Eligibility Verification System
|
BHIN
| Behavioral Health Information Notice
|
BHQIP
| Behavioral Health Quality Improvement Program
|
CalAIM
| California Advancing and Innovating Medi-Cal program
|
CLIA
| Clinical Laboratory Improvement Amendment Waiver
|
CM
| Contingency Management
|
CMP
| Civil Monetary Penalties Law
|
CMS
| Centers for Medicare and Medicaid
|
DHCS
| Department of Health Care Services
|
DMC-ODS
| Drug Medi-Cal Organized Delivery System
|
EBPs
| Evidence-based treatment practices
|
EHR
| Electronic Health Record
|
IM
| Incentive Manager
|
LOC
| Level of Care
|
MAT
| Medications for Addiction Treatment (also known as medication-assisted treatment)
|
NTP
| Narcotic Treatment Programs
|
ODF
| Outpatient Drug Free
|
POC
| Point-of-care
|
SD/MC
| Short-Doyle Medi-Cal
|
StimUD
| Stimulant Use Disorder
|
SUD
| Substance Use Disorder
|
UDT
| Urine Drug Test
|
UCLA ISAP
| University of California, Los Angeles Integrated Substance Abuse Programs
|
1) How should providers refer to this program?
The Recovery Incentives Program.
2) With so much evidence for the benefits of Contingency Management (CM) going back decades, why has this intervention not been used more?
In general, federal law restricts healthcare providers' ability to offer financial incentives as part of patient therapy or patient recruitment. This is known as the
Anti-Kickback Statute (AKS). However, the federal government has explicitly stated that the AKS does not apply to incentives that are delivered in the Recovery Incentives Program. These federal regulations have prevented an intervention of this kind from being implemented on a large scale until this point.
3) Why does the Recovery Incentives Program focus only on stimulants?
There are good EBPs and medications to treat opioid use disorder, but not for stimulants. Additionally, the biggest body of CM research has focused specifically on stimulant use and most studies have shown that CM is most effective when targeting a single substance.
4) Is there research about the length of time people receiving Contingency Management remain abstinent after completing treatment?
Research indicates that more individuals who have completed CM treatment have maintained improvements (e.g., remained abstinent, reduced frequency of use, increase quality of life) for up to 12 months compared to those receiving other treatments.
5) Is there a plan to increase the incentive amount in the Recovery Incentives Program due to inflation?
This is under consideration, but there are many administrative, legal, and procedural issues to consider. At this time, the incentive amount for the Recovery Incentives Program will remain at a maximum of $599 per calendar year.
6) Is there research that shows rates of client retention in Contingency Management treatment?
Research has shown that CM has higher treatment retention rates than other substance use treatments. In addition, research has shown that engagement in CM leads to higher utilization of other treatments and medical services. During the duration of the Recovery Incentives Program, UCLA will evaluate retention rates, as well as the efficacy of CM on a large-scale, members' experiences, and treatment outcomes.
7) How can providers help address the stigma that members in the Recovery Incentives Program are merely being paid not to use drugs?
Providers can address this stigma by emphasizing that CM is one of the few EBPs that have been shown to be effective for stimulant use; in fact, CM has the strongest evidence base for treating stimulant use disorder. In addition, there are no pharmacological treatments for stimulant use disorder. Providers can frame CM as a positive reinforcement intervention based on the principles of operant conditioning and highlight that the dopamine release from stimulants is extremely powerful and reinforcing; as such, we need a positive reinforcement model powerful enough to compete with it. Finally, providers can specify that CM is a powerful intervention for engaging and retaining members in treatment; we know that the longer individuals remain in treatment the better their outcomes tend to be.
8) Can DMC-ODS counties who participate in the Recovery Incentives Program contract with a provider who practices in a bordering county?
Yes, a DMC-ODS county participating in the Recovery Incentives Program can contract with a DMC-certified provider in a bordering county. The member's DMC-ODS county of responsibility would be required to authorize CM services delivered by the contracted provider. All provider sites must be approved by DHCS during the readiness review period prior to offering CM services. For more information regarding DMC-ODS county of responsibility and county of residence, please refer to
BHIN 24-008.
9) What provider types are eligible to offer CM services? Can non-DMC-ODS providers participate in the Recovery Incentives Program?
DMC-ODS providers offering outpatient, intensive outpatient and/or partial hospitalization services, and NTPs are eligible to offer CM. Non-DMC-ODS providers are not eligible to participate in the Recovery Incentives Program.
10) Is there a minimum number of providers that participating counties need to contract with to offer CM?
There is no minimum number of provider sites a participating county must contract with to offer CM. DHCS recognizes that some counties, particularly smaller counties, will have a limited provider network for CM services.
11) Can counties identify additional providers to participate in the Recovery Incentives Program that are not included in the county's program application? Do new providers need to be approved by DHCS?
Yes, a county may add providers to the Recovery Incentives Program. All providers will need to participate in training and complete a two-step Readiness Assessment process before being approved to offer CM services. Counties should alert UCLA when adding a provider so UCLA can include the provider in their outreach. Please, contact
CAThompson@mednet.ucla.edu when adding a provider.
12) Will DHCS allow counties the local authority to impose financial sanctions on contracted providers to ensure compliance with Recovery Incentives Program requirements?
Counties must administer the Recovery Incentives Program in compliance with DMC-ODS policies. Recoupment should only be performed in the case of fraud, waste, or abuse, in which case, the county shall notify DHCS before taking action. If a county learns that a CM provider site is deviating from state-mandated protocols, counties must require the provider to follow the protocols, and may use enforcement tools such as corrective action plans, increasing the intensity of technical assistance through the county or the DHCS-contracted technical assistance providers and notifying DHCS.
13) What training and technical assistance is available for participating counties and providers?
All participating counties and provider sites will receive training and ongoing technical assistance to support implementation of the Recovery Incentives Program that is coordinated by the UCLA Training and Implementation team. Required training includes an asynchronous CM Overview training (released in May 2022) and a comprehensive live virtual Implementation training. Providers will also receive a Program Manual that details the program protocol. All participating sites will also be required to attend one coaching call per month.
14) Do participating providers need to participate in ongoing fidelity reviews?
Yes, as part of the technical assistance offered by the UCLA Training and Implementation team, participating provider sites and counties will participate in periodic fidelity monitoring reviews to determine adherence to the required protocol. Fidelity monitoring will occur twice within the first 6 months of implementation and then once every 6 months thereafter.
15) Does county participation in the Recovery Incentives Program contribute to a Performance Improvement Project (PIP) as required for DMC-ODS and External Quality Review (EQR)?
Yes, county participation in the Recovery Incentives Program can contribute to a PIP.
16) Will CM become an ongoing DMC-ODS benefit?
DHCS conducted a pilot Medi-Cal coverage of CM in select DMC-ODS counties between the first quarter of 2023 and March 2024 through the federally approved California Advancing and Innovating Medi-Cal (CalAIM) Section 1115(a) Demonstration Waiver (No. 11-W-00193/9).
DHCS will extend the program period through at least the duration of the CalAIM 1115 demonstration period (ending December 31, 2026), allowing approved DMC-ODS counties to continue services beyond the original pilot end date of March 2024.
17) Are participating providers required to update DMC certification to participate in the Recovery Incentives Program?
No. All providers that bill the Short-Doyle Medi-Cal (SD/MC) system must be certified to provide DMC services. For the Recovery Incentives Program, SD will verify that the provider location is DMC-certified for an outpatient level of care (LOC) (NTP, ODF, IOT, or Partial Hospitalization). There is no specific CM certification in the provider database.
18) Where can counties and providers learn more about the Recovery Incentives Program protocol?
Additional information about the Recovery Incentives Program is available in the Behavioral Health Information Notice
BHIN 24-031.
19) Can a county request to provide CM services through the Recovery Incentives Program?
Yes, any DMC-ODS County can submit an Implementation Plan indicating their interest to start providing CM services in their county. Please, visit the
DHCS Recovery Incentives Program:
California's Contingency Management Benefit webpage or email
RecoveryIncentives@dhcs.ca.gov for more information.
20) Are CM services restricted to adults ages 18+?
There is no age restriction for CM services. Medi-Cal members, including adolescents, who meet eligibility criteria will be able to participate in the Recovery Incentives Program. Minors under age 12 are eligible to participate with parental consent. Minors ages 12-20 who participate in the Minor Consent program do not need parental consent to participate in the Recovery Incentives Program.
21) Can members who reside in counties that participate in the DMC-ODS Regional Model receive CM services from any county in the region?
To be eligible to participate in the Recovery Incentives Program, members must reside in a participating DMC-ODS county. As of August 2024, Shasta County is the only county in the DMC-ODS Regional Model Partnership that plans to participate in the Recovery Incentives Program.
22) Do providers need to verify member Medi-Cal eligibility before initiating CM services?
Yes, providers must verify Medi-Cal eligibility to initiate CM services and to use the incentive manager system. There can be no assumption of eligibility for members and there is no alternative funding source for the Recovery Incentives Program if Medi-Cal eligibility is not verified. The eligibility check should be done via the Automated Eligibility Verification System (AEVS) for Medi-Cal.
23) Will providers receive a standardized consent form for members who choose to enroll in the Recovery Incentives Program?
Yes, DHCS and the UCLA Training and Implementation Team will provide a consent form template to participating provider sites as part of the training and technical assistance process.
24) Can a member enroll in CM prior to their admission to an outpatient program?
Medi-Cal members who are receiving care in residential treatment (e.g., ASAM levels 3.1–4.0) or institutional settings are ineligible for CM services until they are transitioned to an outpatient DMC-ODS provider that has been approved to offer CM. While the Recovery Incentives Program will not be offered in residential or institutional treatment settings (including jails or prisons) in accordance with Centers for Medicare and Medicaid (CMS) approval, DHCS intends to work closely with those providers to encourage referrals and engagement during transitions from residential levels of care and post-release from jails and prisons. Medi-Cal members can receive CM during the day of discharge from residential, inpatient, or correctional settings. Find additional details in
BHIN 24-031.
25) When does a member need to have last used stimulants to be eligible to participate in the Recovery Incentives Program?
Eligibility for participation in the Recovery Incentives Program is determined based on medical necessity evaluation, including an appropriate ASAM LOC assessment. A beneficiary is not required to demonstrate the severity of their stimulant use disorder by submitting a urine drug screen. A beneficiary must have a diagnosis of any of the related moderate or severe cocaine or stimulant use disorder diagnoses, including diagnoses in remission, as defined in the Diagnostic and Statistical Manual of Mental Illnesses (DSM), current edition (for which CM is medically appropriate) to participate in the Recovery Incentives Program.
If a member is being readmitted to the program, at readmission, the member shall have a new ASAM multidimensional assessment that indicates they can appropriately be treated in an outpatient treatment setting (i.e., ASAM levels 1.0–2.5) and confirm that the member meets the medical necessity criteria for CM. If the member has remained engaged in other services, such as residential treatment, during their absence from CM, an update to the most recent ASAM assessment is sufficient, and the member does not require a new diagnostic assessment.
26) When assessing a member's eligibility for the Recovery Incentives Program, do providers need to conduct a normal triage or an ASAM Assessment?
Providers will go through their typical intake process when enrolling members into the Recovery Incentives Program who are not already enrolled to receive treatment at the provider site. During this intake process, an ASAM assessment that indicates that the member can be appropriately treated in an outpatient treatment setting, a diagnostic review that indicates that the person has any of the related moderate or severe cocaine or stimulant use disorder diagnoses, including diagnoses in remission, as defined in the DSM, current edition, and a determination that treatment for StimUD is medically necessary must be documented. The policies and procedures surrounding intake protocols in each provider's county should always be followed.
27) How far in the past can an ASAM assessment determination be valid for a member to be eligible to participate in the Recovery Incentives Program?
The ASAM Criteria shall be used to determine placement into the appropriate LOC for all members and is separate and distinct from determining medical necessity. An ASAM Criteria reassessment for non-residential DMC-ODS services is required when the member's condition changes. Providers are encouraged to review the expectations for when and how often to conduct ASAM assessments as well as other additional details regarding ASAM assessment determination in
BHIN 24-001.
28) Are members eligible for the Recovery Incentives Program if they are enrolled in a CM treatment program for opioid or alcohol use?
In order to be eligible to participate in the Recovery Incentives Program, a member
cannot be receiving other CM services for stimulant use. Participating in a CM program for conditions other than stimulant use, would not disqualify them from participation in the Recovery Incentives Program.
29) Are residential services included in the services that a member can be engaged in while participating in the Recovery Incentives Program?
The Recovery Incentives Program is
only being implemented in outpatient, intensive outpatient, NTPs and/or partial hospitalization settings. However, those in residential care should be informed about the Recovery Incentives Program so that if/when they can step down to an outpatient LOC and meet the stated eligibility criteria, they can enroll in the Recovery Incentives Program and begin receiving CM services.
30) Is a member eligible to participate in the Recovery Incentives Program if they voice preference to stay in outpatient treatment despite their ASAM assessment recommending a residential LOC?
Yes. A member is eligible to participate in the Recovery Incentives Program even if they decline placement in the residential treatment program as recommended by an ASAM assessment. The LOC should be determined collaboratively between provider and the member, when possible. If the member fails to achieve two consecutive stimulant-negative samples within the first 12-week period of the Recovery Incentives Program, the treatment provider and member should decide whether CM is a clinically appropriate intervention for that member, and if necessary, modify the course of treatment and update the member's problem list and progress notes.
31) What is the protocol if there is a change to a client's Medi-Cal benefits while they are participating in the Recovery Incentives Program?
Providers are required to verify Medi-Cal eligibility every 30 days. If the member is determined to no longer have Medi-Cal benefits, the client would no longer be eligible to participate in the Recovery Incentives Program and a warm hand-off should take place to connect the client with resources that they would then be eligible for.
32) Will the Incentive Manager Portal notify the CM Coordinator if a member loses their Medi- Cal benefits and is no longer eligible for the Recovery Incentives Program while participating in the program?
The Incentive Manager Portal will
not notify the CM Coordinator if a member loses their Medi- Cal benefits. Medi-Cal eligibility should be reviewed every 30 days using the AEVS for Medi- Cal. However, the Incentive Manager Portal will prompt CM staff to verify the member's Medi- Cal eligibility every 30 days.
33) Are members, who are prescribed stimulants for ADHD, eligible to participate in the Recovery Incentives Program?
If a member is taking stimulant medication for ADHD, they would be ineligible to participate in the Recovery Incentives Program because ADHD stimulant medication can cause a false stimulant-positive UDT result.
34) Do members need to test negative for stimulants in advance of starting CM treatment?
No, members do not need to test negative (or positive) for stimulants in advance of starting CM treatment; however, they will not be eligible to receive an incentive until submitting a negative UDT for stimulants.
35) If a member is already enrolled in SUD treatment, do they need to be re-screened for medical necessity in advance of starting CM treatment?
If a member already has a diagnosis of StimUD of moderate or severe from the DSM for Substance-Related and Addictive Disorders, they do not need to be re-screened for medical necessity. Initiation of CM services will require a revised treatment plan. DMC-ODS IA states that a reassessment will occur when function changes; standard practice is at least every 12 months.
36) How long is CM treatment?
California's Recovery Incentives Program is a 24-week outpatient treatment, followed by six or more months of aftercare and recovery support services. During the initial 12 weeks of the Recovery Incentives Program protocol, participants will be asked to visit the treatment setting in person for two treatment visits per week. These sessions will be separated by at least 48 hours, preferably 72 hours (e.g., Monday and Thursday/Friday, or Tuesday and Friday) to help ensure that drug metabolites from the same drug use episode will not be detected in more than one UDT. During weeks 13–24, participants will be asked to visit the treatment setting for testing once a week. Participants will be able to earn incentives during each visit throughout the treatment protocol.
37) Does a member move from twice-a-week tests to once-a-week tests after 12 weeks, regardless of the results?
Yes, all members will visit the treatment settings twice per week during the initial 12 weeks of CM treatment, followed by one visit per week during weeks 13 – 24 of CM treatment, regardless of UDT results.
38) CM does not involve negative reinforcement, but what if a client has a CPS case worker or probation officer, in which case any positive UDT results must be reported – how do providers handle this?
Providers should consult with their legal counsel regarding their obligations under HIPAA and 42 CFR Part 2 and should follow their respective agency policy.
39) Will members receive their incentive as soon as they provide a stimulant-negative UDT?
Yes, members receive an incentive as soon as they submit a stimulant-negative UDT. Members can choose the type of incentive from an approved list and the method of delivery (email, text, or printed).
40) Why is this program set up in such a way that visits are reduced to once a week in weeks 13-24?
Most CM treatment programs that have been studied only involved 12 weeks, after which the incentives ended after the 12th week. By adding a second 12-week period (a stabilizing period) to the initial 12-week active CM intervention period, members are gradually tapered from the treatment/incentive schedule, and it keeps them engaged in treatment programming. This also allows them to start feeling the benefits of abstinence even after the initial 12-week active CM intervention period.
41) Are members required to participate in another outpatient treatment program and/or other services to participate in the Recovery Incentives Program?
Participation in another outpatient treatment and/or services other than the Recovery Incentives Program is not required to participate in the Recovery Incentives Program (i.e., participation in another outpatient treatment and/or services other than the Recovery Incentives Program is optional). Members can participate in CM as a standalone service if they prefer. However, members should be encouraged to participate in other services at your treatment site, as needed.
42) Are providers required to implement group sessions for those participating in the Recovery Incentives Program?
There is no requirement for members to participate in group sessions as part of the Recovery Incentives Program.
43) If a member is discharged from another program at a provider site for a positive UDT result for other substances, would they be able to continue their participation in the Recovery Incentives Program separately?
Yes. Members can participate in CM as a standalone service if they prefer. However, members should be encouraged to participate in other services at your treatment site, as needed.
44) How many times can a member enroll in the Recovery Incentives Program?
In rare circumstances, following completion of the initial CM treatment phase of the program, a member may benefit from re-entering the CM treatment phase protocol instead of proceeding to CM continuing care services. Repeating the ASAM assessment and diagnostic assessment is not required for the member to re-enter the CM treatment phase of the program. In these instances, the clinical documentation must demonstrate that CM services are medically necessary and appropriate based on the standard of care. The maximum incentive amount per calendar year remains $599 if a member is re-enrolled.
45) What circumstances warrant a readmission to the Recovery Incentives Program and the necessity of a new ASAM Assessment?
A member may be considered for readmission if they leave CM services for more than 30 days. At readmission, the member shall have a new ASAM multidimensional assessment that indicates they can appropriately be treated in an outpatient treatment setting (i.e., ASAM levels 1.0–2.5) and confirm that the member meets the medical necessity criteria for CM. If the member has remained engaged in other services, such as residential treatment, during their absence from CM, an update to the most recent ASAM assessment is sufficient and the member does not require a new diagnostic assessment.
46) How many consecutive stimulant-positive UDTs can a member have before being discharged from the Recovery Incentives Program?
There is no indication for discharging members for testing positive. Members should be encouraged and offered additional support/services to help them achieve abstinence. They remain eligible to participate in the program for the entire 24 weeks. The only exception to this is if they are absent from the program for more than 30 days OR they are transitioned to residential LOC. In these cases, the person would be discharged from the Recovery Incentive Program but would remain eligible for readmission if they meet eligibility requirements.
47) What is the recommended number of missed appointments a member can have before they are discharged from the Recovery Incentives Program?
A member will be discharged from the program if they are absent for 30 or more consecutive days.
48) What would constitute an "excused" absence?
In some instances, a member may have a legitimate reason not to attend an appointment. If the member notifies the clinic or CM Coordinator at least 24 hours in advance with a valid reason for missing an appointment, the CM Coordinator should attempt to reschedule the visit for an earlier or later time that same day or on a contiguous day, so that the visit is not missed. If the visit cannot be rescheduled, it is counted as an "excused absence" instead of an "unexcused absence". Excused absences include a planned surgery or other medical procedures, illness, death in the family, or a court date in addition to prosocial events (such as a wedding), or another reason determined to be excused by agency staff. The member must provide documentation of the reason for the absence at the next scheduled visit (e.g., note or receipt from a medical clinic, funeral announcement, wedding invitation, court document, etc.). Failure to provide documentation for an excused absence will result in that absence being entered as an unexcused appointment and an incentive reset will occur.
49) Is there a minimum amount of advance notice needed for a member to request an excused absence?
No, but preferably the member should let you know 24 hours in advance at the minimum. Advanced notice is always required for an absence to be considered excused.
50) Does an incentive reset occur with an excused absence?
No reset occurs when there is an excused absence lasting one or two sessions. However, a reset will occur if the absence extends to three or more sessions.
51) If a member “no-shows" for a visit, how does this affect their Recovery Incentives Program visit schedule?
In the Recovery Incentives Program, missed CM visits would be documented in the IM Portal as an unexcused absence. It is best practice for staff to contact members following a no-show to encourage them to attend their next scheduled visit. An incentive reset will occur after an unexcused absence.
52) Upon submitting an excused absence, does the 48-hour timeframe that is needed between submitted UDTs reset?
Upon entry of the outcome of a visit in the IM portal (i.e., an excused or unexcused visit is entered, or an attended visit during which a stimulant positive or negative UDT occurred is entered), the "48-hour clock" will reset and begin again, based on the time of documentation in the IM Portal.
Once an absence is entered into the IM portal, the system will not allow another UDT result to be entered for at least 48 hours. For example, if an excused absence was documented on a Monday, the clinic (and the IM portal) wouldn't expect another UDT to be conducted and entered until at least Wednesday (48 hours after Monday). It is best practice to schedule CM visits 72 hours apart.
If for any reason, staff are not able to enter information into the portal, they should call the Incentive Manager Help Line for assistance so that the information can be documented in the IM portal in real time.
53) Will CalAIM standards for documentation need to be followed when documenting CM visits in the Electronic Health Record (EHR) system used at provider sites?
Each CM visit shall be documented consistent with existing DHCS policy described in
BHIN 23-
068.
54) What is the Recovery Incentives Program staffing model?
Each participating provider must have at least one CM coordinator. The CM coordinator(s) will be the main point of contact for all participating members and will be responsible for collecting UDT samples, inputting test results, and supporting the delivery of incentives. In addition, each provider must also designate a backup CM coordinator and a CM supervisor. Additional information about these roles and responsibilities are available in the CM provider training manual provided by the UCLA Training and Implementation team.
55) Is the CM coordinator a full or part-time position?
Providers participating in the Recovery Incentives Program will be required to have a designated CM coordinator who will lead the tracking and delivery of all CM services, including administering and interpreting UDT results and distributing incentives based on the algorithm developed by the incentive manager vendor. The CM coordinator must also participate in ongoing technical assistance and implementation sessions. DHCS recommends that providers hire a part-time or full-time staff member that exclusively supports the delivery of CM. However, DHCS recognizes that this is not always possible, and some counties and providers may need to designate existing staff to serve as the CM coordinator on a part-time basis, in addition to other job functions. CM coordinators who split responsibilities across CM and other job functions will be required to conduct the same CM activities as those who are dedicated to CM.
56) How will the CM coordinator position be funded?
The CM coordinator position will be funded through the provision of billable CM services.
57) What should a provider site do if a CM coordinator leaves their role?
The backup CM coordinator or CM Supervisor should provide CM services until a long-term solution can be identified. The UCLA Training and Implementation team will provide ongoing technical assistance to participating counties and provider sites throughout the course of the Recovery Incentives Program and will be available to assist providers on a case-by-case basis. The site must notify UCLA and the IM portal of any staffing changes.
58) How can providers complete the initial Overview Training, (which is required before providers can complete Part 1 and 2 of the Implementation Training)?
Before staff can register for Part 1 and 2 of the Implementation Training, they will have to complete the Overview Training (a 2-hour, self-paced online course) available here:
https://psattcelearn.org/courses/recovery-incentives-californias-contingency-management-
program-contingency-management-overview-training/).
59) Is the period of CM continuing care provided by CM staff? Or are members meant to enroll in other programs/services during this period?
The period of CM continuing care is meant to be implemented in the 6 months following completion of the 24-week CM treatment period. During the period of CM continuing care, members are encouraged to receive other treatment and recovery-oriented support at your site such as counseling and peer support services. As such, CM continuing care can be provided by other program staff at the treatment site and is not restricted to CM staff.
60) Which staff member will handle the intake process if someone is a new client who only wants to enroll in the Recovery Incentives Program?
New clients will go through the usual intake process at your treatment site and can be conducted by whichever staff member at your site that completes intakes.
61) How are CM coordinator services claimed, and how are providers reimbursed?
DMC-ODS Counties offering CM services shall submit claims to SD/MC adjudication system using HCPCS code H0050, with the modifier “HF" on the claim for each CM visit as they would for any other DMC-ODS service. The designated code and modifier are designed to reimburse the bundled costs of a single member visit to a CM coordinator, billed in 15-minute increments, which include:
-
CM coordinator time: pre-, during, and post-visit with the member
-
Supervision
-
Indirect overhead
-
Costs of purchasing UDT cups and testing strips
In addition, each claim or encounter for CM shall include a diagnosis specific to the UDT results. The following diagnosis codes shall be used on claims (in addition to other diagnoses relevant to the visit):
-
R82.998: Diagnosis for positive urine test.
-
Z71.51: Diagnosis for negative urine test.
62) Do claims submitted using H0050 require a Level of Care (LOC) modifier?
Yes, all DMC-ODS claims submitted to SD/MC for CM services require a LOC modifier. The LOC modifier entered on the claim should correspond to the Drug Medi-Cal Service Group for which the service facility location is certified. For example, if the provider site is an Outpatient Drug Free (ODF) site, the county should include “U7" on the claim in addition to any applicable modifiers.
63) Do claims submitted using H0050 require population modifiers (e.g., for pregnant women)?
Please reference the
MEDCCC Library for the current DMC-ODS billing manual, the Service Tables outline allowable modifiers by service code.
64) If a member has other health coverage in addition to Medi-Cal, do providers need to bill their other insurer for CM services before billing Medi-Cal?
Given the unique nature of the CM services covered as part of the Recovery Incentives Program, providers will be able to directly bill Medi-Cal for CM services, without first billing Medicare for CM services provided to dually eligible members. However, due to third-party liability requirements, private insurance must be billed prior to billing Medicaid to ensure Medicaid is the payer of last resort.
65) Can a member's CM diagnosis code (R82.998 or Z71.51) be their secondary diagnosis code, or must it be a primary diagnosis code? If a CM diagnosis code must be a primary diagnosis, will DHCS add these codes to the acceptable list of billable diagnoses under DMC-ODS?
As of September 7, 2021, the SD/MC claims system has been updated to not deny outpatient DMC claims that do not use an included diagnosis code. Diagnosis codes for outpatient claims are now monitored outside of the SD system. For CM, diagnosis codes can be entered as either primary or secondary diagnosis codes.
66) How will county administrative costs be covered?
DHCS will allow counties to invoice for allowable DMC-ODS plan administrative costs. Counties shall implement mechanisms to separately track administrative costs incurred to implement CM and report these costs on the CM line of the MC5312.
67) Will DHCS reimburse costs above the 15% administrative cap?
The percentage spent by counties on allowable administration costs is determined retroactively, after the close of the fiscal year. Therefore, DHCS cannot compare claimed administrative costs against the cap until the cost reconciliation process is complete, after the close of the fiscal year. Since this information will not become available until future budget years, DHCS cannot guarantee that administrative costs above the 15% administrative cap will be reimbursable; it will depend on available funds in the CM budget.
68) How does reimbursement work for incentives disbursed to members?
DHCS contracts with an incentive manager vendor and will directly reimburse the vendor for disbursed incentives. Participating counties and providers will not bill DHCS for disbursed incentives.
After August 15, 2024, counties shall be responsible for the non-federal share of incentive payments. Incentive Payment funding splits will be determined using Short-Doyle Medi-Cal payment rules to determine the correct funding. The county share of the Incentive Payment received by the member will be billed back to the county using a manual process.
69) Where is funding for the Recovery Incentives Program coming from?
DHCS will initially finance the non-federal share of CM services with state funds that are available for a limited period of time as a result of the DHCS Home and Community Based Spending Plan, which includes CM services. If counties elect to continue participation in the optional benefit, they shall be responsible for covering the non-federal share of CM administrative costs after June 30, 2024, and the non-federal share of CM services and incentives after August 15, 2024.
70) On the day of a CM visit, can other services be billed/other billable services occur?
On the days when Recovery Incentives Program visits occur, other billable services can occur.
71) Are CM providers allowed to conduct outreach to help potential members learn about the Recovery Incentives Program?
Yes, CM providers can conduct outreach related to the Recovery Incentives Program. Outreach can increase the likelihood that eligible members will learn about CM services, which may in turn increase the likelihood that they will initiate and adhere to a treatment program for their stimulant use disorder (StimUD). Provider communications about the Recovery Incentives Program (and any other health care service) should not be inaccurate, misleading, or coercive. See question 75 for best practices when communicating about the Recovery Incentives Program.
72) Will providers face risk under federal law if they offer or communicate about the Recovery Incentives Program?
No; in general, federal law restricts providers' ability to offer financial incentives as part of member therapy or member recruitment. However, the federal government has explicitly stated that the federal AKS and the Civil Monetary Penalties Law (CMP) do not apply to motivational incentives that are delivered as part of the Medicaid CM benefit so long as the incentives are provided in compliance with the CMS-approved CalAIM Section 1115 Demonstration waiver and the DHCS-approved Recovery Incentives Program protocol. Thus, providers may promote this benefit as they would any other benefit under DMC-ODS. However, DHCS strongly suggests that providers do so in accordance with the guidelines and best practices discussed in question 75 and question 76.
73) If a provider offers CM services under DMC-ODS, does that mean the provider can also offer other types of member incentives without legal risk?
No, the AKS and CMP do not apply to the Recovery Incentives Program. However, the AKS and CMP apply to any other member incentives offered by providers that are not authorized for CM in the Section 1115 Demonstration Waiver.
74) Are there any limits on how providers can communicate the availability of motivational incentives under the Recovery Incentives Program?
Yes, over the years, the U.S. Department of Health & Human Services Office of Inspector General (OIG) has cautioned providers about various problematic communications activities that may violate the AKS or the CMP. The OIG's guidelines apply to the promotion of all health care services. For example, depending on the circumstances, it may create legal risk if a provider were to do any of the following:
- Offer motivational incentives to members who do not qualify for the Recovery Incentives Program.
- Communicate about the Recovery Incentives Program in a manner that is inaccurate, misleading, or coercive (see below for examples of permissible outreach language).
- Offer financial incentives to Medi-Cal members over and above the motivational incentives available in the Recovery Incentives Program.
- Pay for outreach or member recruitment services on a commission basis, or in a manner that otherwise considers the volume or value of business generated.
- Offer financial incentives to other health care providers in exchange for telling members about, or referring members for, CM and related SUD services.
75) What are some best practices for communicating about the Recovery Incentives Program?
When communicating about the Recovery Incentives Program with current members, potential members, or the general public, providers should avoid any statements that are inaccurate, misleading, or coercive. See below for a list of DOs and DON'Ts, which apply to general CM outreach materials as well as conversations with current or potential members.
Clarify that the Recovery Incentives Program is available to individuals who meet certain eligibility criteria, such as having a qualifying StimUD, enrolling in Medi-Cal, and residing in a participating county. | Use language that could mislead ineligible people into believing that they will qualify for incentives. |
Explain that the Recovery Incentives Program is intended to support treatment goals over time, such as substance non-use and treatment adherence. | Suggest that a member will receive an incentive just for showing up. |
Accurately describe the nature and potential value of the motivational incentives (e.g., “up to $599," “gift cards to use at retail and grocery stores"). | Overstate the potential value of the incentives (e.g., “almost $1,000!"), or state that incentives will be made in cash. |
Ensure members understand that participation in the Recovery Incentives Program is optional. | Suggest that a member must enroll in the Recovery Incentives Program in order to receive other health care services. |
Let potential members know that incentives are conditioned on undergoing a medical assessment and taking regular drug tests, in accordance with DHCS' Recovery Incentives Program protocol. | Suggest that incentives are conditioned on members receiving services beyond those required under DHCS' Recovery Incentives Program protocol. |
Emphasize that CM is a new and exciting service under DMC-ODS to support people with StimUD. | Suggest that CM services are unique to a particular provider, or that one provider's CM services are better than another's. |
76) What is an example of permissible outreach language?
Providers have the flexibility to craft their own outreach messages as long as all communications are not inaccurate, misleading, or coercive, as described above. See below for one example of messaging that follows the best practices laid out in this FAQ:
Do you struggle with meth, cocaine, or other stimulants?
You may qualify for up to $599 in payments to help you stay off stimulants*. This treatment program is open to people who:
- Live in participating county/counties;
- Are eligible for Medi-Cal;
- Have a medical screening to make sure they're a good fit;
Agree
to
regular
drug
testing.
To
learn
more,
contact
us
at
RecoveryIncentives@dhcs.ca.gov.
*Recovery Incentives Program providers must provide incentives distributed by the IM portal. Members are prohibited from using CM incentives to purchase cannabis, tobacco, alcohol, or lottery tickets.
77) Are there available promotional brochures for the Recovery Incentives program?
A flyer and business card templates are available on the
UCLA ISAP Recovery Incentives website
78) Who
is
the
incentive
manager (IM)
vendor?
DHCS contracts with Q2i to provide the incentive manager software used in the Recovery Incentives Program.
79) Can a member receive an incentive if they test positive for other drugs?
If a member tests negative for stimulants, they are eligible to receive an incentive during that visit. The presence of opioids or other drugs shall not be an indication to terminate the member from CM treatment but rather shall be an indication the member may need additional treatment, either concurrently or subsequently. If a member tests positive for another drug, the provider should provide the member with information about treatment services for that drug according to their specific needs.
80) Will each provider be able to select the type of gift cards that are distributed to members?
No, provider sites will not select the type of gift cards that are distributed to members. The calculation and disbursal of incentives will be conducted exclusively by the incentive manager vendor in a format approved by DHCS. The member will choose a gift card vendor from a pre- approved list and choose the format (print, text, or email) they prefer to receive the gift card.
81) Will providers be required to securely store incentives on-site?
No, provider sites will not be required to store physical incentives that are distributed to members. The incentive manager vendor will be responsible for storing incentives, which will be disbursed electronically or as a printed gift card voucher.
82) Will incentives be adjusted for cost-of-living differences across counties/regions?
In accordance with CMS' approval of the CM benefit, DHCS performed a pilot of standardized CM protocol, including incentive amounts for all DMC-ODS counties and providers participating in the Recovery Incentives Program. At this time, incentive rates will be standardized across all counties.
83) Do providers manage members' Recovery Incentive Program visit schedules or does the Incentive Manager Portal determine the schedule?
The CM Team at your site manages the members' Recovery Incentive Program schedule; however, CM visits must follow the approved protocol timeframes outlined in
BHIN 24-031.
84) Can a member's contact number be updated easily in the Incentive Manager Portal?
It is an easy process to update a member's contact information once a member is added to the Incentive Manager Portal. There's a “Manage Users" pane where you can search for members by name, and you can update their contact information from there.
85) What is the protocol if the Incentive Manager Portal/internet/power is down when a member provides a UDT during a Recovery Incentives Program visit?
Call the IM Portal Call Center and inform them that the system is down and follow their direction. If available, continue to document Recovery Incentives Program services in the EHR, or utilize any downtime procedures.
86) How much tracking of data will providers need to conduct in the Recovery Incentives Program?
The Incentive Manager Portal keeps track of most pertinent data; however, counties will be required to submit a quarterly report to DHCS. The Incentive Manager Portal will calculate incentive amounts and maintain a record of UDT results and gift cards disbursed. Participating sites agree to participate in the program evaluation; which includes staff and member surveys and interviews. Other data will be captured through current DHCS systems for billable services provided to the member.
87) Do members have access to a phone application that helps them keep track of their incentives?
No, members do not have access to the Incentive Manager Portal through any medium such as a phone application. Incentives will be available via text or email, and if they choose to receive incentives in printed form, the member is responsible for securing the printout for use. If the paper is lost, the incentive cannot be redelivered.
88) Why is there a monetary decrease for incentives offered during weeks 13-24 from $15 to $10, as the gradual increase in weeks 1-12 appears to be the motivation for members?
In the Recovery Incentives Program, weeks 13-24 are referred to as the stabilizing period. Many CM interventions conducted as part of research studies have ended after 12 weeks and have not included a stabilizing period after the active intervention period. The stabilizing period serves to help members stabilize and maintain the progress they made in weeks 1‐12. This period is also important in terms of treatment retention.
During the stabilizing period (weeks 13-24), stimulant-negative samples will be rewarded with $15 gift cards during weeks 13-18, $10 gift cards for weeks 19-23, and a $21 gift card for week 24. For members who have taken advantage of other clinical interventions offered at your site, such as group or individual counseling, the continuing incentives that can be earned during the stabilizing period serve as a tool to encourage members to remain fully engaged in those interventions.
89) What do I do if I record an incorrect result in the Incentive Manager Portal and need to correct it?
Great care should be taken to ensure accurate entry of information into the Incentive Manager Portal. If you record an incorrect result in the Incentive Manager Portal and need to correct it, you must call the IM Portal Call Center for assistance. A Call Center staff member will correct the result.
90) Can a gift card be "re-loaded" or does the member get a new gift card each time they receive an incentive?
Members receive a new gift card for each incentive they earn. The member can also choose to bank the incentive and apply the amount to a gift card later.
91) If the member's phone/physical gift card is reported stolen or is lost, should we inform anyone at the Call Center for the Incentive Manager Portal?
Gift cards cannot be reprinted or redistributed. Please inform the member of this when they receive their incentives. You do not need to inform our program staff or Call Center staff.
92) Is it wrong to ask members for a receipt of their gift card purchases occasionally just to "check-in?"
We do not require, nor recommend, that members provide a receipt of any purchases made with their incentives. Asking them how they used them at their next scheduled visit and celebrating what they earned is a good way to keep them motivated.
93) If a member transfers to another provider site in the middle of their participation in the Recovery Incentives Program, would their benefits/incentive amount carry over?
Yes, if a member transfers to another site in the middle of their participation in the Recovery Incentives Program, their incentive amount/escalation status will carry over.
94) Can a member "cash out" their banked incentives at any time during the program?
Yes, a member can "cash out" their banked incentives at any time during their participation in the Recovery Incentives Program - ideally during a visit when they provide a stimulant-negative UDT. When cashing out, a member must apply the entire bank to a single gift card.
95) When a member wants to redeem incentives from the rewards bank, do they have to take out the entire balance or can they take out smaller amounts?
If a member would like to redeem their banked incentives, the entire amount will be designated to a single gift card. Banked incentives cannot be split between multiple vendors.
96) Is a member locked into redeeming all gift cards with one vendor or can they redeem their gift cards with one vendor and then choose a different vendor later?
Members can choose a new vendor each time they redeem an incentive.
97) If a member loses their phone, can they have their gift card sent to a friend or family member?
Yes, members can have their gift cards sent to whatever phone number or email they'd like.
98) If a participant banks $400, for example, and tests positive, will they lose what they saved?
No, any incentives that a member earns in the Recovery Incentives Program are theirs to keep.
99) What are the hours of the IM Portal Call Center?
The IM Portal Call Center is available Monday to Friday between the hours of 8:00AM PT and 7:00PM PT.
100) Is the IM Portal Call Center the same as the Warm Line?
The IM Portal Call Center is for inquiries regarding the Incentive Manager Portal and should be used for urgent matters or questions specific to the IM portal.
The Warm Line is a resource offered through UCLA ISAP on their Recovery Incentives Program website (https://uclaisap.org/recoveryincentives/warm-line.html) and can be used for inquiries related to the implementation of the Recovery Incentives Program. Inquiries sent to the Warm Line can take up to one business day for response.
101) What is a member's ID (as required when enrolling a member in the Incentive Manager Portal)?
The member ID is the member's Medi-Cal number.
102) What type of UDTs will be used by providers participating in the Recovery Incentives Program?
All participating provider sites will be required to use a UDT product that has been approved by DHCS. DHCS has identified which UDT products meet the program's specifications. Please refer to BHIN 24-031 and the
DHCS Recovery Incentives Approved Urine Drug Tests list linked on the program webpage.
UDT kits will be purchased directly by your site or through your County according to your usual procurement process. Check with your County CM project staff to determine how to obtain the UDT kits.
103) What types of substances do the UDTs test for?
All UDTs approved for the Recovery Incentives Program must meet program specifications as described in
BHIN 24-031, which includes testing for stimulants (cocaine, amphetamine, and methamphetamine), as well as for opiates and oxycodone. Some of the approved UDT products also include testing for fentanyl.
104) Why do some of the approved UDTs include fentanyl testing?
Some manufacturers of UDT products approved for use in the program have redesigned their products to include testing for fentanyl. These redesigned UDT products meet the program specification requirements for testing for stimulants (cocaine, amphetamine, and methamphetamine), as well as for opiates and oxycodone with the addition of a fentanyl test UDTs with fentanyl testing can provide information about a member's drug use that they may not report at their appointment. Fentanyl is the leading cause of drug overdose death and it is important to identify the combination of other illicit drugs with fentanyl, which increases the risk of overdose.
105) Why may a site choose to use these tests over the others?
The stimulant testing features of all UDT products approved for use in the program, including UDT products that test for fentanyl, are the same. While the UDT products with added fentanyl testing included may be more expensive, there is a benefit to utilizing UDT products with fentanyl testing features. Fentanyl is the leading cause of drug overdose deaths, and it is important for individuals to be aware of the presence of fentanyl when using any illicit drugs. Identifying individuals who are at risk for fentanyl exposure creates an opportunity for provider sites to provide appropriate counseling, referral for evaluation for MAT, and resources, including access to Naloxone to reverse an overdose.
106) What if a member tests positive for fentanyl?
A UDT indicating the presence of fentanyl does not impact the incentive delivery schedule for the program. Instead, a fentanyl positive UDT result presents the provider an opportunity to talk about make a referral for evaluation for MAT, provide counseling about the risks of fentanyl and ways to prevent overdose.
Harm reduction is an essential component of any treatment program. According to provisional data released by the Centers for Disease Control and Prevention in May of 2022, drug overdose deaths continued to rise in the United States in 2021, surpassing 100,000 deaths per year. A high number of these deaths are due to the synthetic opioid fentanyl, which has been found mixed in or as a replacement for many other drugs of abuse, including benzodiazepines, opiates and other opioids, and stimulants. Given the presence of fentanyl in some stimulants, death as the result of accidental ingestion of fentanyl is a real risk for members beneficiaries in the Recovery Incentives Program.
107) Will positive UDT results require confirmation testing by an external lab?
No, UDT results indicting the presence of fentanyl do not require confirmation by an external lab. All participating providers will be required to use a UDT product that has been approved by DHCS.
108) Will DHCS provide and pay for UDTs?
UDT kits will be purchased directly by the provider site or county. Check with County CM project staff to determine how to obtain the UDT kits.
Provider sites must use their usual processes to purchase and administer UDTs as part of the Recovery Incentives Program. The costs of purchasing UDTs and other supplies are included in the CM reimbursement rate. Find additional details about reimbursement for CM services in the
Reimbursement section above.
109) Is there a general protocol to follow before administering a UDT to identify whether a member is taking any medications that can cause a false stimulant-positive UDT or to identify any potential issues with the UDT that may affect the results?
The consent form provides a list of medications and substances that may cause a false-positive test. This list is reviewed with the member during the initial intake process when they provide consent to participate in the Recovery Incentives Program. Therefore, the member has been informed that use of any of the medications in this list can cause a false stimulant-positive UDT. As indicated in the consent, the results of the UDT will be used even if the member believes that it is a false positive. Reviewing the list with the member and encouraging them to talk to the prescriber (in the case of prescription medicine) and/or to explore alternatives is good practice if this issue comes up.
110) Do UDTs need to be administered exclusively by CM staff or can they be administered by another staff member at the treatment site?
UDTs administered to members in the Recovery Incentives Program must be exclusively administered by CM staff; therefore, cannot be administered by another staff person at the treatment site.
111) Have any other UDTs been reviewed and approved for use in the Recovery Incentives Program?
DHCS periodically reviews the UDTs approved for the Recovery Incentives Program to ensure quality and availability. If you currently use another onsite POC UDT test, you can submit an application to DHCS to see if it might be approved (refer to the Program Manual for further details). If any of these submitted UDTs are approved, they will be added to the list of UDTs that have been approved for use in the Recovery Incentives Program so that participating sites in the Recovery Incentives Program can use them. DHCS maintains a list of approved UDTs that can be found on the
DHCS Recovery Incentives Program Approved Urine Drug Tests website page.
112) What do you mean by monitored versus observed UDTs?
UDTs in the Recovery Incentives Program are meant to be monitored, not observed. CM staff are not required to enter the toilet space and directly observe a member when they are providing a UDT sample. If a site currently conducts observed UDT collection, they are not prevented from continuing that practice with members in the Recovery Incentive Program.
113) Why is it recommended that provider sites shut off the hot water in the restroom in which UDT samples are provided? What if this is not possible?
It is recommended that the hot water be shut off in the restroom in which UDT samples are provided to help ensure the accuracy and validity of the UDT tests (i.e., a member will not be able to heat up a sample that is not their own by holding it under the hot water). If it is not possible to shut off the hot water, this can be discussed further during the Readiness Assessment process.
114) If a provider already implements twice-weekly observed UDTs in other programs at their site, would the UDTs that are involved in the Recovery Incentives Program be a separate set of twice-weekly tests?
Providers must use a UDT product that has been approved by DHCS for use in the Recovery Incentives Program. Providers can continue current practices with participants who are not participating in the Recovery Incentives Program and may use whichever of the approved UDTs that they choose to use for the Recovery Incentives Program.
115) If a client is already involved in other treatment services at a provider site, would it be prudent to provide Recovery Incentives Program testing on the same days/times?
Yes, we recommend providers schedule their Recovery Incentives Program visits alongside the other services the provider offers, so that clients can align their Recovery Incentives Program visits schedule with any other program visits that they are already present for.
116) Will members be able to self-administer UDTs and show the results to the clinic staff?
Members will collect their own samples. The CM staff will evaluate the member's test cup to see whether the sample is positive for stimulants. Providers shall use appropriate precautions to avoid tampering with UDT specimens, including the following: requiring members to leave personal possessions (e.g., backpack, purse, items in pockets) in a secure location outside of the restroom; requiring members to thoroughly wash hands or use hand sanitizer prior to entering the restroom, including between fingers and under nails; turning off access to hot water in the restroom (or turning off the water faucet altogether, and requiring hand-washing outside of the restroom); and adding bluing agent to the toilet. Each test must be accompanied by reliability measures, including temperature, creatinine, and pH level.
117) Do providers need to hold a Clinical Laboratory Improvement Amendments (CLIA) waived test certification to participate in the Recovery Incentives Program?
Yes, providers need to hold a CLIA waived test certification and be registered with the California Department of Public Health (CDPH) (or be accredited by an approved accreditation body).
Laboratory Field Services, which is part of CDPH, has
an online application process through which providers can apply for both the CLIA waiver and the state registration. Each provider site within an agency that participates in the Recovery Incentives Program needs its own CLIA waived test certification and state registration. A recording of the state lab registration/CLIA waived test certification training offered on October 11-12, 2022, is available for sites that were not able to attend at
https://vimeo.com/759984612.
118) Do providers need to identify a laboratory director to receive a CLIA waived test certification?
Yes, providers need to identify a waived lab director to receive a CLIA waived test certification. The requirements for a waived lab director are outlined in
Business and Professions Code
section 1209(a). If a provider site does not have access to a licensed physician, surgeon, or other qualified individual to serve as a laboratory director, please reach out to your county representative for further guidance. Please notify the Recovery Incentives team at
RecoveryIncentives@dhcs.ca.gov with any issues or concerns.
119) Who should serve as laboratory director? What are the roles and responsibilities of the laboratory director position?
The ideal person to serve in the laboratory director role would be the medical director at each site. In instances where sites are county-run, the ideal person to serve as laboratory director may be the county medical director or county psychiatrist. The specific qualifications and role requirements for the Laboratory Director position are detailed in
Business and Professions Code
section 1209 (a) – (g). The primary function of the laboratory director is to ensure that procedures are followed correctly. The role also entails review of documentation and training.
Ultimately, the laboratory director is still responsible for verifying that staff members are performing the UDTs, according to expectation.
120) If a site already does point-of-care (POC) UDT testing and has a CLIA waived test certification, does it need to obtain a separate waiver for the Recovery Incentives Program?
No, each provider site only needs one CLIA waived test certification.
121) Do providers need to offer CLIA waived fentanyl tests?
Currently, two CLIA waived UDTs contain fentanyl tests are approved for the Recovery Incentives Program. All the UDTs currently approved for use in the program include tests for opiates and oxycodone as an indicator of exposure to opioids, so that providers can refer members for appropriate MAT and other services, as needed.
122) Should sites provide members with fentanyl test strips?
Sites should be able to provide information to members about where to obtain fentanyl test strips and how to use them (see CDPH website/Fentanyl Testing to Prevent Overdose: https://www.cdph.ca.gov/Programs/CID/DOA/Pages/OA_prev_sep.aspx).
123) Is Fentanyl testing reimbursable through the Recovery Incentives Program?
While not all the urine drug tests currently approved for the Recovery Incentives Program test for fentanyl, sites participating in the Recovery Incentives Program are not prohibited from independently testing for fentanyl. The expenses associated with testing for Fentanyl, including the use of test strips and urine drug tests for Fentanyl outside of those on the DHCS Approved UDTs list, are not reimbursable through the Recovery Incentives Program, but may be reimbursable as part of other Medi-Cal services provided to the member.
124) How can a Recovery Incentives Program site obtain Naloxone for participants in the Recovery Incentives Program?
Substance use disorder recovery facilities (outpatient, residential, and sober living homes) are eligible entities for the California Naloxone Distribution Project and may have naloxone made available and shipped directly to the site for free. To request free naloxone, complete the online
Naloxone Distribution Project application located on the DHCS website.
125) Is there a difference between the CLIA requirements for the Recovery Incentives Program and the requirements for other UDT processes conducted at SUD treatment programs?
If provider sites are conducting UDTs as part of their existing SUD treatment programs, it is likely that they already have a CLIA waived test certification in place. There is no difference between doing POC testing for traditional SUD treatment services and the Recovery Incentives Program.
126) Are
the
testing
thresholds
different
between
approved
tests
for
the
Recovery
Incentives Program and standard CLIA waived tests?
Each test has unique thresholds and validity measures. The DHCS approved UDTs have been evaluated by an expert toxicologist to meet the standards required for the Recovery Incentives Program. If a site is interested in using a UDT device other than those indicated in the BHIN, they can request an evaluation of that device to determine if it meets the program requirements. Instructions for submitting a UDT device for evaluation are also listed in the BHIN.
127) How much does the CLIA application cost?
There are two applications and fees. The state application fee is $113, and the federal application fee is $180. To pay the federal fee, provider sites can either wait for their coupon to arrive to their mailing address and then send it in, or they can go to
https://www.pay.gov/public/home.
128) What is the CMS 116 form and where can I find information regarding the specific name types of tests my facility performs?
The CMS 116 form is the CLIA application. Application forms can be found online here:
CDPH Forms
Additional help is available at
LFScc@cdph.ca.gov.
129) Do provider sites need to complete the Lab 155 Form?
No, the Lab 155 form is not on the CDPH checklist:
https://www.cdph.ca.gov/Programs/OSPHLD/LFS/CDPH%20Document%20Library/ELLFS_Ne
wLicenseApplicationChecklist.pdf.
130) How should non-profits complete the “owner" section of the CMS 116 form?
It is up to each individual provider site to determine the best entity to list as the “owner" on the form.
131) What is the wait time from submitting an application to receiving a CLIA waived test certification?
Currently, the wait time is six months. Submitting an application without errors can improve individual wait times. DHCS is working with CDPH to expedite the process. Once the CLIA application has been submitted, please provide the APL# to the UCLA Implementation team for expedited processing.
132) Will an extended wait time impact the implementation of the Recovery Incentives Program?
Sites must have a CLIA waived test certification in place prior to conducting POC UDTs. Therefore, implementation of the Recovery Incentives Program cannot start until this process is complete.
133) Can providers partner with an outside laboratory to process UDTs?
No, in order to participate in the Recovery Incentives Program, provider sites must be able to collect UDTs and read test results on-site. Samples may not be sent to an outside laboratory for this program.
134) Can providers amend submitted/pending CLIA waived test certification applications?
Providers will have an opportunity to correct errors on their applications if CDPH sends them a notice for correction. If a provider needs to amend an application for something that is not an error, the applicant can email
LFScc@cdph.ca.gov.
135) Where can providers find an example of a completed CLIA waived test certification application?
The online user manual includes photos of the various screens as applicants work through the online application. The manual can be found at:
https://www.cdph.ca.gov/Programs/OSPHLD/LFS/Pages/ELLFS_NewSingle.aspx.
136) What is the appropriate staffing designation for CM Coordinators, CM Backup Coordinators, and CM Supervisors?
Staff who are working as CM Coordinators, CM Backup Coordinators, or CM Supervisors fall within the “healthcare professional" category and can perform the POC testing under the direction of the site's laboratory director.
137) Can provider sites attempt to apply under an existing lab's CLIA waived test certification?
Every provider site requires a
separate state registration and CLIA waived test certification, unless they meet one of the exception criteria below. Additionally, all provider sites under the same state registration and CLIA waived test certification, must be under the
same
ownership and have the
same laboratory director.
138) What do I do after my site has submitted our CLIA Waiver and State Lab Registration applications?
Upon completing one or both applications, please contact
CAThompson@mednet.ucla.edu with the application ID (APL #) for your site. Following submission, please check the CDPH application portal regularly for all updates regarding your applications at:
https://mylicense.cdph.ca.gov/prweb/PRWebLDAP1/app/default/JNjzDdEndczmIjcX8iwY6FV
R4wsiXbPN1fW1kioTBJ4*/!STANDARD
139) If a provider has three (3) CM staff (2 CM Coordinators and 1 CM Supervisor) assigned to implement the Recovery Incentives Program at one site/facility, does each staff member need to complete the Readiness Assessment?
Only one Readiness Assessment is required per
physical treatment site.
140) Does each CM staff at a provider site need to complete the Implementation Training before the site can initiate the Readiness Assessment process?
No, in order to
initiate the Readiness Assessment process at a provider site, a CM Coordinator and a CM Supervisor
at minimum must have attended both parts of the Implementation Training. For a provider to be approved for launch at their site, all three (3) CM staff (1 CM Coordinator, 1 CM Back-Up Coordinator, 1 CM Supervisor) must complete the Implementation Training. Additional staff can be onboarded after launch.
141) How does a provider complete the Readiness Assessment if they have multiple locations/sites?
Each site must complete its own Readiness Assessment.
