A Montana habit clinic needs to encourage individuals with rewards. Then got here a Medicaid fraud probe.

A Montana habit clinic needs to encourage individuals with rewards. Then got here a Medicaid fraud probe.

Health Care Financing

A Montana habit clinic’s plan to present individuals with substance use issues as a lot as $1,966.50 in reward playing cards and vouchers to observe its remedy program is elevating questions on using monetary incentives with sufferers.

The tug of warfare over the efficient however largely unregulated software is taking part in out within the northwestern Montana city of Kalispell, the place an area authorities grant is financing rewards for individuals who persist with remedy offered by the outpatient clinic Oxytocin.

Such incentives have gained momentum amongst particular person well being clinics and states in recent times. Since 2021, California, Washington, and Wisconsin have began incentive-based packages. Some personal clinics provide their very own rewards, corresponding to giving purchasers reward playing cards for efficiently passing a drug take a look at.

In Montana, the place Republican Gov. Greg Gianforte has made increasing behavioral well being care a precedence, a state pilot program affords prizes to individuals with addictions who keep off medication. Oxytocin’s program, whereas funded by a authorities grant, is separate from the pilot program.

The allowable worth of prizes that go to beneficiaries of federal well being packages, like Medicaid, is a authorized grey space, so totals fluctuate from one program to the subsequent.

The federal authorities does not have a rule limiting the dimensions of monetary awards or pointers detailing finest practices, stated Richard Rawson, professor emeritus within the Division of Psychiatry and Biobehavioral Sciences at UCLA.

“Folks do not know the place to look to know this methodology, so states and suppliers make it up as they go alongside,” stated Rawson, who has studied such incentives for about 20 years.

In June, Montana’s Flathead County awarded the Kalispell clinic, Oxytocin, a $500,000 grant funded by state alcohol tax income. Of that cash, $300,000 was earmarked for incentives for contributors to attend remedy, based on the clinic’s proposal. It proposed that over a 20-week remedy course, contributors might earn as a lot as $1,966.50 in both reward playing cards or vouchers.

In Oxytocin’s program, a consumer has a number of possibilities every week to earn an incentive by passing urine checks and attending remedy. The greenback quantity will increase with consecutive successes.

The county selected Oxytocin from amongst 4 clinics that utilized for the substance use remedy funding. By November, not less than one criticism had been filed with state companies accusing Oxytocin of committing Medicaid fraud by paying its purchasers — most of whom are Medicaid recipients — that top of a reward to attend remedy.

Oxytocin scientific director Pamela Liccardi declined requests to be interviewed however stated in an e-mail that the enterprise had achieved nothing unsuitable. “There’s a motive the group stands behind us and it isn’t as a result of we do fraudulent issues,” she wrote.

Analysis exhibits that motivational incentives, known as contingency administration, can cut back the variety of days somebody takes illicit stimulants, corresponding to methamphetamines, and might promote abstaining from different substances, corresponding to opiates, by reinforcing wholesome conduct with prizes, privileges, or money.

“We all know persons are dying from methamphetamine now,” stated Michael McDonell, a group and behavioral well being professor at Washington State College, who has helped states create incentive packages. “Contingency administration is the one evidence-based intervention for methamphetamine use dysfunction. It is the one intervention that is proven persistently to be impactful.”

However clinicians are cautious of working afoul of a 1972 federal anti-kickback statute that prohibits providing one thing of worth to a federal beneficiary, corresponding to a Medicaid recipient, to induce them to pick out a selected supplier.

There are “secure harbors” meant to guard sure packages which might be unlikely to result in corruption. However a February authorized advisory opinion from the U.S. Division of Well being and Human Providers’ Workplace of Inspector Common stated these exceptions do not embody incentives geared toward beneficiaries. Federal officers have lengthy been involved that these kinds of affords might result in fraud and abuse.

“Packages that contain giving remuneration to beneficiaries can corrupt medical care decision-making, which might end in overutilization, elevated prices, steering to explicit suppliers or suppliers, or inappropriate medical selections,” the advisory opinion says.

Whether or not packages that supply incentives to beneficiaries of federal well being packages violate the anti-kickback regulation is set on a case-by-case foundation, the inspector normal’s workplace wrote. Among the many components is the worth of the incentives, says the advisory opinion, with out setting a particular benchmark.

Rawson and different researchers stated most suppliers think about a complete of $75 per consumer a 12 months to be secure, primarily based on a 2016 assertion from the inspector normal’s workplace on cheap presents to beneficiaries.

Nonetheless, Rawson stated analysis signifies that quantity is probably going too low to work properly as an incentive. One other annual restrict that packages encounter is $600 per consumer, the brink for reporting taxable revenue to the IRS. Exceeding that quantity might trigger beneficiaries to exceed Medicaid revenue limits, which might result in lack of protection.

Final 12 months, Montana officers started a pilot program that expands stimulant use dysfunction therapies and contains incentives.

Tammera Nauts, with the Montana Main Care Affiliation, stated the state was cautious to keep away from elevating any pink flags for the federal authorities within the guidelines it set for the state program. For instance, taking part clinics cannot give sufferers prizes to take part in remedy the federal authorities covers, corresponding to remedy classes. State pilot websites’ incentives can also’t go over $315 complete per beneficiary a 12 months — a cap Montana was allowed by a Facilities for Medicare & Medicaid Providers waiver.

Suppliers might provide their very own rewards program with out going by the state, and Nauts stated Oxytocin isn’t one of many pilot websites tethered to Montana’s program.

KHN obtained a replica of a criticism filed in opposition to Oxytocin. Along with the allegations of Medicaid fraud, it accuses Oxytocin of getting a number of suppliers who provide providers exterior of their space of experience or with out a license. The doc KHN acquired didn’t embody the identify of the one who filed the criticism, and state officers declined to supply particulars.

The criticism was filed with the state’s Division of Public Well being and Human Providers and Division of Justice. Well being division spokesperson Jon Ebelt stated it will be untimely to touch upon the case earlier than the evaluate is full. Division of Justice spokesperson Emilee Cantrell stated the company’s Medicaid fraud unit was working with the well being division however stated she could not present particulars as a result of an lively criticism is taken into account confidential prison justice data.




A Montana habit clinic needs to encourage individuals with rewards. Then got here a Medicaid fraud probe.This text was reprinted from khn.org with permission from the Henry J. Kaiser Household Basis. Kaiser Well being Information, an editorially impartial information service, is a program of the Kaiser Household Basis, a nonpartisan well being care coverage analysis group unaffiliated with Kaiser Permanente.