Contingency Management for Addiction – Highly Effective, But Protect Against the Risks!
Contingency Management (CM) is one of the most effective intervention strategies available for this country’s addiction epidemic. BUT…treatment programs inevitably put themselves at risk when they try implementing it on their own. A clear example of this from Kaiser Health News involves a Montana provider system that is currently under investigation.
It's even possible this provider has done nothing wrong. But the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General (OIG) take the potential for waste, fraud, and abuse very seriously. It’s their job to prevent the taxpayer from being overbilled. These investigations can result in criminal offenses. It's not enough to have policies and procedures in place. When it comes to CM, you also need a meticulously documented paper trail of rewards and implementation.
It’s an arduous process. Working across 45 states, DynamiCare has found that treatment staff-based CM, unless constantly & closely monitored, can lose track of things. Providers stop testing or test carelessly. Drug screen results at some point stop getting logged properly. Someone “loses count” of the dollars or cents – or the gift cards get “lost”. It can happen only on occasion. But we’ve seen it happen systematically, too. The CM process is simply too intricate, confusing, and thus prone to error – even with the best of intentions. And an OIG investigation does not assume good intentions. Why? Because OIG has repeatedly discovered overt fraud by some bad actors in the addiction treatment field.
The good news is that DynamiCare’s digital therapeutic platform mitigates this risk. DynamiCare is the only CM tech platform that uses rigorous protocols to track all reward distributions. Dynamicare issues rewards that prioritize confirmed sobriety. Also, DynamiCare is distinct and independent of the treatment program. So DynamiCare has zero incentive to overbill. DynamiCare’s automated and 100% trackable system for the implementation of CM removes the burden of tracking for providers, giving everyone peace of mind that everything is meticulously documented.
In fact, DynamiCare Health is the *only* CM technology platform that has been reviewed by the U.S. Dept. of Health & Human Services OIG and found to pose no risk of violating these federal regulations. This formal review was supported by the National Council for Mental Wellbeing - the non-profit advocate for organizations that deliver mental health and substance use services in America.
In 2022, the Office of the Inspector General (OIG) within the Department of Health and Human Services issued a definitive advisory opinion that specifically settles this concern: When CM is delivered through DynamiCare’s digital platform, agencies do not need to worry about the federal Anti-Kickback statute or the Beneficiary Inducements section of the Act. This protection extends to health plans, addiction treatment providers, employee assistance programs, research institutions, and more. Anyone who contracts with DynamiCare does not need to worry about investigation or criminal prosecution. DynamiCare takes care of it.