Skip to main content

You’re not alone. Call 988 to connect to the National Suicide and Crisis Lifeline.

Join Us    |    Contact

Year: 2019

Decorative News Icon

NABH Urges Oversight Hearings on Parity Following GAO Report

Written by Emily Wilkins (NABH) on . Posted in Press.

WASHINGTON, Dec. 18, 2019 /PRNewswire/ — A key finding in a new Government Accountability Office (GAO) report on government oversight of compliance with parity underscores the need for federal lawmakers to proactively investigate the work of employer-sponsored group plans and ensure they are complying with the landmark 2008 parity law. Late last week, GAO released a 67-page report that examined and evaluated the practices, policies, and guidance from the U.S. Health and Human Services (HHS) Department and the U.S. Labor Department (DOL), the two federal offices that oversee compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Read more at PR Newswire  
Decorative News Icon

CMS Releases Guidance on Coverage Transition for ‘Dual Eligibles’ Receiving OTP Services

Written by Emily Wilkins (NABH) on . Posted in Resources.

The Centers for Medicare & Medicaid Services (CMS) released an Informational Bulletin on Tuesday that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services. Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time. To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved. CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare. If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.
Decorative News Icon

Milliman Report Highlights Barriers to Accessing Behavioral Healthcare Services

Written by Emily Wilkins (NABH) on . Posted in Press.

WASHINGTON, Nov. 20, 2019 /PRNewswire/ — A report from Milliman, Inc. about disparities between physical and behavioral healthcare for both in-network access and provider reimbursement rates underscores NABH’s position that unnecessary barriers continue to deny access to behavioral healthcare for patients who need it. The Bowman Family Foundation commissioned Milliman to produce Addiction and Mental Health vs. Physical Health: Widening disparities in network use and provider reimbursement, a 140-page report that shows the gap in disparities for employees and their families seeking mental health and addiction treatment versus treatment for physical health conditions widened in 2016 and 2017. Read more at PR Newswire  

NABH Analysis: OTP Provisions in 2020 Physician Fee Schedule

Written by Emily Wilkins (NABH) on . Posted in Analysis.

OTP Provisions in 2020 Physician Fee Schedule

CMS finalized provisions for the nation’s opioid treatment programs (OTPs) in the 2020 Physician Fee Schedule regulation that the agency released on Nov. 1. This NABH Analysis provides a summary of those provisions, which provide for the treatment of opioid use disorders (OUDs) with new bundled service codes for OTPs, and for telehealth and opioid use treatment services in office-based settings. The final rule will be published in the Federal Register on Nov. 15. The regulations implement requirements that were included in last year’s Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act. NABH is pleased that the final rule addressed the following issues that NABH mentioned in its comment letter on Sept. 28:
  • CMS raised the non-drug bundle to 161.71, which aligns with NABH’s valuation. We used a building block methodology to demonstrate that the proposed non-drug bundle, based on the CMS PFS rates, was undervalued by 31-48 percent.
  • We also identified a range of indirect and direct services routinely performed by OTPs that CMS included in the final bundle.
  • NABH advocated for the elimination of the partial bundle and recommended a more gradual overall implementation of elements of the proposed rule. In the final rule, CMS temporarily eliminated the partial episode of care with the intent to engage in future rulemaking to more gradually phase in their bundled approach.
  • Comments and data were provided to CMS reflecting potential destabilization of the workforce relevant to the proposed service requirements. CMS addressed these issues through deference to state laws and scopes of service provisions, and a reduction of the number of services needed to bill the bundle.
  • In explanatory text, CMS made note of the NABH recommendation for a rural add-on rate of 17 percent and indicated it may be considered in future rulemaking to incentivize rural care.
  • NABH recommended consideration to permanently set a zero co-pay, and CMS indicated the intent to address the issue in future rulemaking.
  • We advocated to remove OTPs from the high-risk category. CMS finalized a compromise proposal that moves OTPs that have been fully and continuously certified by SAMSA since October 23, 2018 to moderate risk, while maintaining those without full and continuous certification in the high-level risk category, as they are newly-recognized Medicare providers.
  • NABH-supported telehealth codes were finalized.
  Final Rule Highlights: Opioid Treatment Programs
  • Definition of OUD Treatment Services
    • FDA-approved opioid agonist and antagonist treatment medications
    • Dispensing and administering of such medications (if applicable)
    • Substance use counseling
    • Individual and group therapy
    • Toxicology testing (both presumptive and definitive testing)
    • Intake activities
    • Periodic assessments
  • Bundled Rates/Episode of Care
    • Bundles reflect a weekly episode of care with no time limits.
    • Rates are a combination of a drug and non-drug component.
    • Full and partial episode construction was finalized to eliminate of partial episodes of care. Utilization will be monitored, intent is to create a partial bundle in the future.
    • One service must be furnished within a week to bill a weekly drug or non-drug bundle.
  • Drug component reflects drug dispensing/administration services; rates vary according to the specific drug (methadone-oral, buprenorphine-oral, buprenorphine-injection, buprenorphine-implant, naltrexone injection), and includes buprenorphine-only products.
    • Maintenance dosage and calculation for oral buprenorphine was increased from 10 mg to 16 mg daily.
    • Created an NOS code for new medications.
  • Non-drug component includes counseling, psychotherapy, toxicology testing and tracks with SAMHSA certification.
    • Does not require counseling and psychotherapy but defers to medical need and state laws relevant to scopes of practice.
    • Case/care management is not included as a bundled or add-on code. Intent to collaborate with OTPs to better understand services, with potential future rulemaking.
    • Rates were increased using building block methodology that values the services based on established Medicare PFS (non-facility) rates for similar services; the Medicare Clinical Laboratory Fee Schedule (CLFS); and state Medicaid programs.
    • Bundles include payment for presumptive and definitive drug testing, with no separate billing under CLFS. There is no add-on code in order to avoid incentive to test more frequently than needed.
  • Add-ons
    • Intake activities for new patients, including a physical examination
    • Periodic assessments during an episode of care, such as for pregnant or postpartum patients
    • Take homes for methadone/buprenorphine for up to 7 days of medication
    • Counseling 30-minutes when counseling or therapy substantially exceed the amount in the individual treatment plan
PFS Bundles for Office-based Services/Telehealth
  • Bundled Rates/Episode of Care
    • Codes for three new (monthly) OUD treatment bundles have been added to the telehealth list on a Category 1 basis for care coordination, individual and group therapy, and counseling through two-way interactive audio-video communication technology.
      • G2086, 70-minute psychotherapy, first month. Includes treatment planning, care coordination, individual and group psychotherapy and counseling
      • G2087, 60-minute psychotherapy, subsequent months. Includes care coordination individual and group psychotherapy and counseling
      • G2088, for each additional 30-minute service required beyond 120 minutes. Includes care coordination, individual and group psychotherapy, and counseling
    • To bill G2086 and G2087, one psychotherapy services must be furnished.
    • If no therapy is provided, the bundle may not be billed. Instead, existing CPT codes for care management 99484, 99492, 99493, 99494 and E/M codes may be used.
    • Psychotherapy codes 90832, 90834, 90837, 90853 may not be used by the same practitioner for the same beneficiary in same month that episode bundles are billed.
    • Rates do not include medications, as they are reimbursed under Medicare Part B or D or toxicology testing that is billed under CLFS.
    • Provider must be licensed in the jurisdiction/location of the patient.
    • The codes are not restricted to use by addiction specialists.
    • Additional telehealth services may be requested before February 10, 2020 for consideration for the following calendar year.
    • The rule notes the prior removal of geographic limitations for telehealth services for SUD or co-occurring mental health disorders.
    • The SUPPORT ACT permits services to be furnished at any originating site, including the patient’s home, and requires that no originating site facility fee is permitted when the individual’s home is the originating site.
    • OTP services are not considered physician/practitioner services, and as such may not bill these codes. Instead, services are covered through OTP bundled rates.
NABH will closely monitor and work with CMS and other stakeholders in the implementation of this benefit and provide updates to NABH members as necessary. If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.
Decorative Letters Icon

NABH Issue Brief: CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD

Written by Emily Wilkins (NABH) on . Posted in Issue Brief.

CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD The Centers for Medicare & Medicaid Services (CMS) on Wednesday released guidance to state Medicaid directors that clarifies how section 5052 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act permits institutions for mental diseases (IMDs) to provide treatment to Medicaid beneficiaries with at least one substance use disorder (SUD). NABH was a driving force behind section 5052 becoming law and the NABH team has talked with CMS staff about the law’s implementation. The guidance from CMS covers five key areas: requirements for beneficiaries, requirements for IMDs, requirements for states, maintenance of effort, and interaction with existing IMD policies. This NABH Issue Brief provides a summary of each of those areas.

Requirements for Beneficiaries

An eligible individual for section 5052 (the new IMD authority) is a person who is:
  • a Medicaid enrollee,
  • between the ages of 21 and 64,
  • residing in an IMD primarily to receive withdrawal management or SUD treatment services,
  • diagnosed with at least one SUD, and
  • in an IMD primarily to receive treatment for a SUD (SUD must be the primary diagnosis).

Requirements for IMDs

Eligible IMDs must follow reliable, evidence-based practices and make available at least two forms of medication as part of medication-assisted treatment (MAT). The two drugs may be offered on site upon request or furnished off site by a qualified provider in the community that has an arrangement with the IMD. IMDs “should also offer behavioral health services alongside MAT,” CMS noted.

Requirements for States

States are required to:
  • ensure placement in an IMD will allow the beneficiary to successful transition to the community;
  • ensure that eligible IMDs provide services at lower levels of clinical intensity or establish relationships with providers offering those services;
  • notify CMS how it will ensure eligible individuals receive appropriate evidence-based clinical screening and periodic reassessments to determine the appropriate level of care;
  • cover outpatient SUD treatment services, including early intervention, outpatient services, intensive outpatient services, partial hospitalization, and at least two of the following residential and inpatient levels of care:
    • low-intensity residential services,
    • population specific, high-intensity residential services for adults,
    • medium-intensity residential services for adolescents,
    • high-intensity residential services for adults,
    • high-intensity inpatient services for adolescents,
    • intensive inpatient services withdrawal management for adults, and
    • intensive inpatient services.
Maintenance of Effort On an annual basis states must:
  • maintain or exceed the level of state and local funding for patients in eligible IMDs as well as services furnished to eligible individuals in outpatient, community-based settings;
  • report the total state and local expenditures, excluding the state share of Medicaid expenditures, for:
    • items and services provided while a patient in an eligible IMD,
    • outpatient and community-based SUD treatment,
    • evidence-based recovery and support services,
    • clinically-directed therapeutic treatment to facilitate recovery skills, relapse prevention and emotional coping strategies,
    • outpatient MAT, related therapies, and pharmacology,
    • counseling and clinical monitoring,
    • outpatient withdrawal management and related treatment, and
    • routine monitoring of medication adherence.
Interaction with Existing IMD Policies   States that add the new IMD authority (Section 5052) may also receive monthly capitation payments paid to managed care plans for beneficiaries age 21 through 64 who receive inpatient treatment in an IMD. Section 5052 does not prevent states from pursuing or conducting a section 1115 demonstration to improve access to, and the quality of, SUD treatment for eligible populations. Additional Information CMS is developing a state plan amendment and maintenance of effort reporting templates to assist states. Click here for specific guidance related to state plan amendment submission procedures, including guidance on developing comprehensive methodologies and bundled rates. If you have questions, please contact Scott Dziengelski, NABH’s director of policy and regulatory affairs.
Decorative News Icon

2020 Annual Meeting

Written by Administrator on . Posted in News Releases, Press.

March 16-18, 2020

Mandarin Oriental Washington, DC

We invite you to use this annual opportunity to learn from, connect with, and influence the decision makers who determine the future of behavioral healthcare services in the United States.

The 2020 Annual Meeting will feature sessions on a variety of issues affecting the U.S. behavioral healthcare industry, with a special emphasis on the barriers to providing and access care.

Learn more and register for the 2020 Annual Meeting
Decorative News Icon

Shawn Coughlin Named Next NABH President and CEO

Written by Administrator on . Posted in News Releases, Press.

Association’s Executive VP Succeeds Retiring NABH President and CEO Mark Covall WASHINGTON, Oct. 2, 2019 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) Board of Trustees has appointed Shawn Coughlin as its president and CEO beginning in January 2020. Coughlin succeeds Mark Covall, who is retiring after more than 35 years with the association and 24 years as its president and CEO. The Board announced the succession plan in conjunction with its Fall Board Meeting in Washington… Read more at PR Newswire
Decorative Letters Icon

NABH Issue Brief: CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020

Written by Administrator on . Posted in Issue Brief.

The Centers for Medicare and Medicaid Services (CMS) has proposed a hospital-based partial hospitalization program (PHP) payment rate of $228.20 for 2020, up from the 2019 rate of $220.86, in the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS/ASC) proposed rule the agency released on July 29. CMS also proposed an increase for community mental health centers (CMHCs), which could see a payment rate of $124.59 in 2020 if the rule is made final. By comparison, CMHCs received a payment rate of $120.58 in 2019. The rates set in the proposed CY 2020 rule are not based on the most recent average cost data from the PHP program, a deviation from CMS’ long-standing policy. When CMS calculated the average PHP program cost for the CY 2020 proposed rule, the agency found it had decreased by nearly 15 percent for CMHCs and 11 percent for hospitals-based PHPs. After finding this decrease, CMS reviewed the data sets and found that a single provider in the CMHC set and a single provider in the hospital-based set had such dramatically lower-reported costs that it significantly skewed the average cost for both data sets. Because the lower average costs were the result of single providers and could significantly reduce access for beneficiaries, CMS decided to use the CY 2019 cost average as a floor for both type of PHP rates in the CY 2020 rule. If not for this change, the rate for both types of PHPs would have been significantly lower than what CMS proposed in the rule. It is important to note that CMS stressed that it does not intent to carry this policy forward: “To be clear, this policy would only apply for the CY 2020 rate setting,” the agency said in the rule. CMS will accept comments on the CY 2020 proposed rule until September 27. CY 2020 Rates Level 1 Health and Behavior Services                                                         $28.59 Level 2 Health and Behavior Services                                                         $81.06 Level 3 Health and Behavior Services                                                         $130.27 Partial Hospitalization (3 or more services) for CMHCs                               $124.59 Partial Hospitalization (3 or more services) for Hospital-based PHPs         $228.20
Decorative Letters Icon

NABH Issue Brief: CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule

Written by Administrator on . Posted in Issue Brief.

The Centers for Medicare and Medicaid Services (CMS) on Monday issued a proposed rule for establishing a Medicare Part B benefit and payment bundles for opioid use disorder (OUD) treatment services in opioid treatment program (OTP) settings and new HCPCS codes and bundled rates for office-based treatment of OUD.
OTP Bundled Payment
The proposal implements Section 2005 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act. The rule proposes:
  • A definition of OUD treatment services and OTPs, including an explanation that services include access to all FDA-approved medications, counseling and therapy, and toxicology testing;
  • Enrollment policies that align with SAMHSA OTP regulation and that do not have additional conditions of participation;
  • Bundled payment methodologies that separate drug from non-drug treatment components, account for different medications and variable intensity of services, provide for service add-ons and partial- and full-billing for weekly episodes;
  • Use of audio-video communication technology; and
  • Zero beneficiary cost-sharing requirement for a time-limited period.
Office-based Care Bundled Payment
The agency also proposed a bundled payment for office-based OUD treatment services, to encourage the expansion of access to OUD care, including:
  • Coverage of OUD management, care coordination, psychotherapy, and counseling; medication to be billed and reimbursed under existing Medicare Part B or D; toxicology testing to be billed under Clinical Lab Fee Schedule;
  • Bundled payment methodologies that are based on monthly billing cycles to better align with office-based practices; one bundle for the initial month of treatment that is more service-intensive; and a second bundle for subsequent “maintenance months,” service add-on codes, and not restricted to addiction specialists;
  • Three new HCPCS codes to Category I of the list of Medicare telehealth services for office-based substance use disorder (SUD)/OUD services, permits a patient’s home as a telehealth originating site; and
  • No changes to cost-sharing.
Emergency Departments
Also of interest, the proposed rule requests information on emergency department practice patterns related to the initiation and use of MAT, and referral or follow-up care, for developing such bundles in future rulemaking. Comments are due September 27, 2019. NABH has engaged a consulting firm to help analyze the proposed bundled payment methodology and payment rates, and the association will submit comments.
Decorative Alerts Icon

NABH Alert: CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule

Written by Administrator on . Posted in Alerts.

The Centers for Medicare and Medicaid Services (CMS) announced a Medicare payment increase of 1.5 percent next year for inpatient psychiatric facilities in the final Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) rule the agency released today. Compared with the 2019 payment rate, the increase reflects a total increase of $65 million for Medicare-participating inpatient psychiatric facilities in fiscal year 2020. The payment update aligns with the agency’s proposed rule earlier this year. The rule also adds one new claims-based measured starting in fiscal year 2021 payment determination and continuing in subsequent years. The measure—Medication Continuing Following Inpatient Psychiatric Discharge (National Quality Forum #3205)—assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder, schizophrenia, or bipolar disorder filled at least one evidence-based medication within two days before discharge or during the 30-day, post-discharge period.
Decorative Alerts Icon

CMS Releases Emergency Medical Treatment and Labor Act (EMTALA) Memorandum

Written by Administrator on . Posted in Alerts.

The Centers for Medicare & Medicaid Services (CMS) on July 2 released Frequently Asked Questions on the Emergency Medical Treatment and Labor Act (EMTALA) and Psychiatric Hospitals, a six-page memo addressing common concerns psychiatric hospitals and hospital emergency departments have regarding compliance with EMTALA. EMTALA has been a top regulatory priority for NABH and our team has worked closely with CMS on this issue. In March, NABH released The High Cost of Compliance: Assessing the Regulatory Burden in Inpatient Psychiatric Facilities, a detailed report that quantifies the compliance costs related to EMTALA for inpatient psychiatric care providers. The analysis—which NABH commissioned Manatt Health to produce—also addresses ligature risk, a topic CMS addressed this past April in draft guidance. Here are key excerpts from CMS’ July 2 FAQ Memo:
  • How do surveyors evaluate whether a staff person is qualified to perform a Medical Screening Exam?
    • The surveyor can review state scope of practice as well as hospital bylaws or rules and regulations to determine if the medical screening exams being performed are within a professional’s scope of practice.
  • What is the expectation of a psychiatric hospital when a medical emergency presents in terms of who can conduct a medical screening exam?
    • EMTALA requires hospitals to perform medical screening examinations within their capabilities. If the psych hospital doesn’t have the ability to perform a comprehensive medical screening exam (or provide stabilizing treatment), but the screening exam it performs indicates that the patient may have an emergency medical condition, the hospital is required to arrange an appropriate transfer to a facility for further evaluation and treatment. The hospital is expected to use its resources to perform the exam and provide care within its capabilities prior to transfer. This might be as simple as performing ongoing assessments with repeat vital signs and ensuring the patient is in a safe environment.
  • What is required in terms of stabilization and transfer for non-psychiatric emergencies?
    • There is no expectation that a psych hospital with basic clinical services would be expected to provide the same level of comprehensive medical assessments or treatment as an acute care hospital.
  • How does EMTALA intersect with admission?
    • If the hospital has the staff and facilities to stabilize the emergency medical condition, it is expected to do so. This includes inpatient admission, as appropriate. Having an empty inpatient bed does not always translate to having the capability or capacity to stabilize the emergency medical condition.
  • Can an ER physician in a facility that does not provide psychiatric care conduct the mental health screening?
    • It is within the scope of practice for ED physicians and practitioners to evaluate patients presenting with mental health conditions, same with any other medical, surgical, or psychiatric presentation. The ED practitioner may utilize hospital resources to assist with the examination and treatment or arrange appropriate transfers if additional resources are needed.
Read the full memo here.
Decorative News Icon

NABH Releases The High Cost of Compliance: Assessing the Regulatory Burden on Inpatient Psychiatric Facilities

Written by Administrator on . Posted in News Releases.

Icon

NABH Releases The High Cost of Compliance: Assessing the Regulatory Burden on Inpatient Psychiatric Facilities

1 file(s) 114.27 KB
Download
FOR IMMEDIATE RELEASE CONTACT: Jessica Zigmond 202.393.6700, ext. 101 Jessica@nabh.org NABH Examines the High Cost of Compliance on Inpatient Psychiatric Facilities WASHINGTON, DC (March 19, 2019) — The National Association for Behavioral Healthcare (NABH) on Tuesday released The High Cost of Compliance: Assessing the Regulatory Burden on Inpatient Psychiatric Facilities, a comprehensive report that examines the burdens that certain regulations impose on the nation’s inpatient psychiatric facilities. NABH commissioned Manatt Health to conduct this first-of-its-kind study that focuses on three federal regulatory domains attached to participation in the Medicare program: the so-called “B-tag” requirements, a detailed set of standards for patient evaluations, medical records, and staffing in inpatient psychiatric facilities; “ligature risk points,” or those aspects of the physical environment that a patient could use to attempt self-strangulation; and the Emergency Medical Treatment and Labor Act (EMTALA), which obligates a hospital to screen all patients for emergency medical conditions, and, if an emergency condition is identified, to stabilize the patient before the patient may be discharged or transferred. “Members of NABH’s Regulatory Overload Task Force worked closely with Manatt’s researchers on this study, which surveyed 62 inpatient psychiatric facilities,” said NABH Board Chair Pat Hammer, president and CEO of Oconomowoc, Wis.-based Rogers Behavioral Health. “The findings estimate that, taken together, these three regulatory areas impose $1.7 billion in compliance costs nationwide—each year,” he added. “That means these regulatory burdens represent about 4.8 percent of an average facility’s annual revenue for all inpatient services from all sources.” NABH recognizes that rules are intended to serve the important goals of patient safety and high-quality care. But some of these regulations are outdated, and many are applied inconsistently by surveyors in the field. “Federal regulators have an opportunity to lift heavy compliance burdens from inpatient psychiatric facilities without harming patient care,” said Randi Seigel, a partner with Manatt Health. The report notes that doing so could ultimately improve patient care. “By removing low-value compliance burdens, the reforms outlined in this report would free up clinician time and financial resources that could be better spent improving patients’ access to high-quality psychiatric care,” said Fatema Zanzi, a partner with Manatt Health. NABH released the report at its 2019 Annual Meeting, where the association also launched its Access to Care initiative. Follow us @NABHBehavioral and at #NABH19 for live updates from the meeting. “This report emphasizes what our members have been saying for too long: regulatory overload takes time away from patient care,” said Mark Covall, NABH’s president and CEO. “As our nation works to address its deadly opioid and suicide crises, we need our behavioral healthcare providers to focus on what they do best: provide mental health and substance use disorder patients with the right care, in the right setting, at the right time.” Please visit www.nabh.org to read the full report and to see NABH’s other Access to Care resources, including the association’s Access to Care resolution and brief video. ### About NABH The National Association for Behavioral Healthcare (NABH) advocates for behavioral healthcare and represents provider systems that are committed to delivering responsive, accountable, and clinically effective prevention, treatment, and care for children, adolescents, adults, and older adults with mental and substance use disorders. Its members are behavioral healthcare provider organizations that own or manage more than 1,000 specialty psychiatric hospitals, general hospital psychiatric and addiction treatment units and behavioral healthcare divisions, residential treatment facilities, youth services organizations, and extensive outpatient networks. The association was founded in 1933.
Decorative News Icon

NABH Board Adopts Access to Care Resolution

Written by Administrator on . Posted in News Releases.

Icon

NABH Board of Trustees Adopts Access to Care Resolution

1 file(s) 109.52 KB
Download
FOR IMMEDIATE RELEASE CONTACT: Jessica Zigmond 202.393.6700, ext. 101 Jessica@nabh.org WASHINGTON, DC (March 18, 2019) — The National Association for Behavioral Healthcare (NABH) Board of Trustees on Monday approved a resolution that addresses unfair managed-care practices and recommends guiding principles for providers and payers to incorporate in contracts with managed care organizations (MCOs). NABH’s provider systems are committed to ensuring patient access to behavioral healthcare treatment across the entire behavioral healthcare continuum, which includes inpatient, residential, partial hospitalization, intensive outpatient, outpatient, and recovery and support services. Too often, MCOs limit coverage to crisis stabilization or short-term, acute-care services for all levels of care because they use internally developed and/or proprietary and non-transparent, medical-necessity criteria. “As our Access to Care resolution states, ‘Fair and appropriate coverage for behavioral healthcare services must ensure—not solely offer—access to the entire behavioral healthcare continuum,” said NABH Board Chair Pat Hammer, president and CEO of Oconomowoc, Wis.-based Rogers Behavioral Health. “For this to happen, fair and reasonable managed care contracts must include and apply generally accepted standards of professional practice.” Articulated in clinical research and clinical specialty organization consensus statements, these generally accepted standards of care recognize that behavioral healthcare treatment is intended to:
  • Prevent, diagnose, and/or treat behavioral health conditions;
  • Promote age-appropriate growth and development;
  • Minimize the progression of disability;
  • Facilitate, maintain, and/or restore functional capacity; and
  • Support long-term recovery.
NABH created a Managed Care Committee last fall to identify problems and propose solutions in managed care contracts. The Board of Trustees adopted the Managed Care Committee’s resolution at its Board meeting in Washington, D.C. on the first day of the association’s 2019 Annual Meeting. “We hope this resolution and the guiding principles in it will help our members as they work with MCOs to develop contracts that are patient-centered,” said Mark Covall, NABH’s president and CEO. “This resolution is also significant because it is a major piece of our new Access to Care initiative that we’re launching today. Through this initiative, we will provide information and resources to help inform policymakers, regulators, payers, and patient advocates that only true access to care can lead to recovery. NABH’s Access to Care initiative focuses on two major challenges: unjust managed care contracts and countless regulations, both of which often prevent behavioral healthcare providers from offering patients a full range of services. Please visit www.nabh.org to read the resolution, watch NABH’s Access to Care video, and learn more. And follow us @NABHBehavioral and at #NABH19 for live updates from the 2019 NABH Annual Meeting. ### About NABH The National Association for Behavioral Healthcare (NABH) advocates for behavioral healthcare and represents provider systems that are committed to delivering responsive, accountable, and clinically effective prevention, treatment, and care for children, adolescents, adults, and older adults with mental and substance use disorders. Its members are behavioral healthcare provider organizations that own or manage more than 1,000 specialty psychiatric hospitals, general hospital psychiatric and addiction treatment units and behavioral healthcare divisions, residential treatment facilities, youth services organizations, and extensive outpatient networks. The association was founded in 1933.
Decorative News Icon

NABH Applauds Landmark Behavioral Healthcare Coverage Ruling

Written by Administrator on . Posted in News Releases.

Icon

NABH Applauds Landmark Behavioral Healthcare Coverage Ruling

1 file(s) 94.40 KB
Download
  FOR IMMEDIATE RELEASE CONTACT: Jessica Zigmond 202.393.6700, ext. 101 jessica@nabh.org   NABH Applauds Landmark Behavioral Healthcare Coverage Ruling WASHINGTON, DC (March 5, 2019)— The National Association for Behavioral Healthcare (NABH) applauds the decision filed in California’s Northern District that opens access to behavioral healthcare services for those who need it. “It has been 10 years since President George W. Bush signed the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act, and we have yet to achieve full parity,” said Mark Covall, NABH’s president and CEO. “Today’s decision in California’s Northern District is a turning point. The federal court’s ruling made it clear that insurance companies must use generally accepted standards in the full behavioral healthcare continuum to help patients gain access to the care they need for recovery.” In a nationwide class action lawsuit, the U.S. District Court for the Northern District of California on Tuesday held that United Behavioral Health (UBH) — the country’s largest managed behavioral healthcare organization — developed restrictive medical-necessity criteria that it used to deny coverage for outpatient, intensive outpatient, and residential treatment services. According to the decision, the Court found that UBH’s internal guidelines limited coverage to acute care services, disregarding highly prevalent, chronic, and co-occurring disorders that required greater intensity and/or duration. The Court also found that UBH failed to meet a requirement related to children and adolescents, asserting that although generally accepted standards of care do not require UBH to “create an entirely separate set of guidelines to address the needs of children and adolescents… they do, however, require that UBH’s guidelines instruct decision-makers to apply different standards when making coverage decisions involving children and adolescents, where applicable, including relaxing the criteria for admission and continued stay to take into account their stage of development and the slower pace at which children and adolescents generally respond to treatment.” NABH is especially pleased to see the Court acknowledge that mental health and substance use disorders are chronic illnesses, and that managed care organizations must cover care that not only stabilizes the acute aspects of a patient’s illness, but also addresses a patient’s underlying condition. ### About NABH The National Association for Behavioral Healthcare (NABH) advocates for behavioral healthcare and represents provider systems that are committed to delivering responsive, accountable, and clinically effective prevention, treatment, and care for children, adolescents, adults, and older adults with mental and substance use disorders. Its members are behavioral healthcare provider organizations that own or manage more than 1,000 specialty psychiatric hospitals, general hospital psychiatric and addiction treatment units and behavioral healthcare divisions, residential treatment facilities, youth services organizations, and extensive outpatient networks. The association was founded in 1933.
Decorative News Icon

Behavioral Health Update: January 7, 2019

Written by Administrator on . Posted in Resources.

============================= BEHAVIORAL HEALTH UPDATE A Monthly Report for Members of the American Hospital Association and the National Association for Behavioral Healthcare www.aha.org www.nabh.org January 2019    Updates:
  1. CMS Reports Healthcare Spending Growth Slowed Last Year
  2. HRSA Releases Behavioral Health Workforce Projections
  3. CMS Features FAQ on Price Transparency Provision in IPPS
  4. CMS Requests Feedback on Conflict of Interest at Accrediting Organizations
  5. Behavioral Health IT Coalition Sends Letter to CMS
  6. RAND Report Analyzes Heroin-Assisted Treatment and Supervised Drug Consumption Sites
  7. AMA Study Examines Association Between Psychotic Experiences and Risk of Suicide
  8. MACPAC Releases 2018 Edition of MACStats: Medicaid and CHIP Data Book
  9. PwC Health Research Institute Previews Top Health Industry Issues for 2019
  10. CDC’s NVSR Reports on Drugs Most Frequently Used in Overdoses: 2011-2016
  11. PCORI Board Approves $12.7 million for Mental Health Research Study
  12. U.S. Preventive Services Task Force Seeks Comments on Opioid Interventions
  13. CMMI Posts Fact Sheet on Integrated Care for Kids and Maternal Opioid Misuse Models
  14. Manatt, AMA & Pennsylvania Medical Society Release Report on Practices to End Opioid Crisis
  15. CHCS and ACAP Release Report on Social Determinants of Health via Medicaid Managed Care
  16. Associations Among Motor Activity, Sleep, Energy & Mood Could Suggest New Focus for Depression Treatment
  17. NIDA Highlights Details for National Drug and Alcohol Facts Week
  18. World Congress to Host Opioid Management Summit in February
  19. Register Today for 2019 Annual Meetings
Stories: 1. CMS Reports Healthcare Spending Growth Slowed Last Year Total nominal U.S. healthcare spending increased 3.9 percent to $3.5 trillion in 2017, slowing down from growth of 4.8 percent in 2016, the Centers for Medicare and Medicaid (CMS) reported last month. The new statistics were published in an article in Health Affairs which reported that the rate of growth in 2017 was similar to the increases between 2008 and 2013, which preceded a faster growth rate between 2014 and 2015—a period that included insurance coverage expansion and large increases in prescription drug spending. According to the analysis, nearly all major sources of insurance and sponsors of healthcare experienced slower growth last year. Meanwhile, the share of gross domestic product devoted to healthcare spending was 17.9 percent in 2017, similar to the share in 2016.   2. HRSA Releases Behavioral Health Workforce Projections About 276,400 people are expected to enter the behavioral health workforce during the five-year period between 2016 and 2021, HHS’ Health Resources and Services Administration (HRSA) estimates in a new analysis. The findings are part of HRSA’s Behavioral Health Workforce Projections that the agency compiled following a mandate from the 21st Century Cures Act. In the analysis, HRSA provides national-level workforce estimates for the following occupations between 2016 and 2030: addiction counselors, marriage and family therapists, mental health and school counselors, psychiatric technicians and psychiatric aides, psychiatric nurse practitioners and psychiatric physician assistants, psychiatrists, psychologists, and social workers. According to a 2017 report from the Substance Abuse and Mental Health Services Administration (SAMHSA), nearly one in five adults in the United States—or about 44.7 million people—suffered from a mental illness in the last year, and in 2016 about 28.6 million people aged 12 and older used an illicit drug in the past 30 days. “Beyond the direct toll on individuals and families,” HRSA noted on its website, “mental illness and substance use disorders are well-established drivers of disability, mortality, and healthcare costs.” The HRSA analysis also included state-level behavioral health workforce estimates.   3. CMS Features FAQ on Price Transparency Provision in IPPS  CMS has released two FAQ (here and here) documents on the Affordable Care Act (ACA) requirement that all hospitals establish, update, and publish publicly online a list of the hospital’s “standard charges” for services the hospital provides. CMS included this ACA provision—which becomes effective Jan. 1, 2019—in its final FY 2019 inpatient prospective payment system (IPPS) rule. The final rule did not include a definition of “standard charge,” but CMS noted that hospitals can make public a chargemaster “or another form of the hospital’s choice.” CMS also said the form must be in a “machine-readable” format and added that PDF documents are not considered permissible under that definition.   4. CMS Requests Feedback on Conflict of Interest at Accrediting Organizations The Centers for Medicare and Medicaid Services (CMS) last month requested public comment about the appropriateness of some Medicare-approved accrediting organizations (AO) offering fee-based consultative services to providers and suppliers they also accredit as part of their business model. “CMS is seeking to receive stakeholder input which can help us determine whether the AO practices of consulting with the same facilities which they accredit could create actual or perceived conflicts of interest between the accreditation and consultative functions of the AO,” the agency said in its announcement, adding that it will consider the information it receives to help with future rulemaking.   5. Behavioral Health IT Coalition Sends Letter to CMS In a letter to CMS last month, the Behavioral Health IT Coalition said mental health and addiction treatment providers participating in the Centers for Medicare and Medicaid Innovation (CMMI) MAT bundled payment models outlined in the new law must show e-prescribing capacity. It also said behavioral health facilities must provide evidence that they can exchange clinical data successfully with medical-surgical providers in order to be eligible for funding through these demonstrations. The final recommendation said CMS should incorporate health IT financial incentives into each of the three MAT demonstrations to urge behavioral health and substance use disorder (SUD) providers to adopt 2015 certified electronic health record technology.   6. RAND Report Analyzes Heroin-Assisted Treatment and Supervised Drug Consumption Sites A new report from RAND Corp. examines how four countries use two interventions that the United States does not apply to address opioid use disorder: heroin-assisted treatment (HAT) and supervised consumption sites (SCSs). “Give the severity of the opioid crisis, there is urgency to evaluate potential tools that might reduce its impact and save lives,” the report said. “This working paper is part of a series of reports assessing the evidence on and arguments made about HAT and SCSs and examining some of the issues associated with implement in the United States.”   7. JAMA Study Examines Association Between Psychotic Experiences and Risk of Suicide Individuals with psychotic experiences are at increased risk of suicidal ideation, suicide attempts, and suicide death, according to a new JAMA study.   Recent research has shown a particularly strong association between psychotic experiences and suicidal behavior. This study’s purpose was to provide a quantitative synthesis of the literature examining the longitudinal association between psychotic experiences and subsequent “suicidal ideation, suicide attempts, and suicide deaths in the general population.”   8. MACPAC Releases 2018 Edition of MACStats: Medicaid and CHIP Data Book The Medicaid and CHIP Payment and Access Commission (MACPAC) last month released the December 2018 edition of its MACStats: Medicaid and CHIP Data Book, which has updated data on national and state Medicaid and CHIP enrollment, spending, benefits, and more. This year’s edition shows total enrollment growth in Medicaid and the State Children’s Health Insurance Program (CHIP) decreased 2.2 percent nationally from July 2017 to July 2018.   9. PwC Health Research Institute Previews Top Health Industry Issues for 2019 In its annual forecast, PwC Health Research Institute predicts that providers and payers that have served Medicaid patients will have a significant effect on the healthcare industry in the New Year. “In 2019 the health industry will see value lines created by innovative providers and payers that have figured out how to subsist—comfortably, thank you very much—by serving almost entirely Medicaid or cash-strapped patients,” the report noted. PwC’s 54-page analysis—The New Health Economy Comes of Age—also predicts that life sciences companies will market digital therapeutics and connected devices targeting atrial fibrillation, hemophilia, substance abuse, birth control, depression, diabetes, epilepsy and other conditions. “Once thought to operate outside the greater U.S. economy, the industry—with its byzantine payment system, complicated regulatory barriers and reliance on face-to-face interactions—is being disrupted,” the report noted. “Finally, there’s robust evidence that what PwC calls the New Health Economy is kicking into gear.” According to PwC’s analysis, 84 percent of Fortune 50 companies are involved with healthcare, and venture capital funding for digital health startups is projected to top $6.9 billion in 2018, reflecting a 230-percent increase from five years ago. Meanwhile, the report noted that “American consumers have told PwC’s Health Research Institute since 2013 that they’re “eager to embrace more convenient, digitally enabled and affordable care; finally, they’re finding it, with options that resemble the choices they have in other parts of their lives.”   10. CDC’s NSVR Reports on Drugs Most Frequently Used in Overdoses: 2011-2016 Fentanyl, heroin, hydrocodone, methadone, morphine, oxycodone, alprazolam, diazepam, cocaine, and methamphetamine were the 10 most frequently mentioned drugs among drug overdose deaths that noted at least one specific drug between 2011 and 2016, according to the Centers for Disease Control and Prevention’s (CDC) National Vital Statistics Report (NVSR). Oxycodone ranked first in 2011; heroin during 2012-2015; and fentanyl in 2015. During the study period, cocaine consistently ranked second or third, researchers found. The report’s conclusion said these findings highlight “the importance of complete and accurate reporting in the literal text on death certificates.” 11. PCORI Board Approves $12.7 million for Mental Health Research Study The Patient-Centered Outcomes Research Institute (PCORI) Board of Governors last month approved $12.7 million to fund a study that will examine the effectiveness of different strategies to treat anxiety and depression in expectant and new mothers. Funding will go to researchers in Chapel Hill, N.C.; Chicago; and Toronto to study four different methods of providing treatment, in-person sessions with either a specialist provider or nurse, or the same sessions delivered via telemedicine. “Depression and anxiety symptoms pose a significant burden and lead to high costs among mothers worldwide,” PCORI noted in an announcement about the study. “Psychological treatments—also known as talk therapies, including behavioral, cognitive and interpersonal therapies—have a robust evidence base and are preferred by women and their families over pharmacological treatments,” the announcement continued. “Unfortunately, as few as one in five women can access these effective treatments due to a dearth of available specialists and barriers including cost, transportation, and access. There is therefore a need for widely accessible, low-cost, and innovative psychological treatments for depression and anxiety during pregnancy and postpartum.” Click here to learn about the project’s details. 12. U.S. Preventive Services Task Force Seeks Comments on Opioid Interventions The U.S. Preventive Services Task Force (USPSTF) last month opened the public comment period for its draft research plan on interventions to prevent opioid use disorder. The USPSTF notes clearly that the plan is in draft form and has been distributed for the sole purpose of gaining feedback. The task force will accept public comments through Wednesday, Jan. 16, 2019 at 8 p.m. ET. 13. CMMI Posts Fact Sheet on Integrated Care for Kids and Maternal Opioid Misuse Models The Center for Medicare and Medicaid Innovation (CMMI) has posted a fact sheet on its Integrated Care for Kids (InCK) and Maternal Opioid Misuse, or MOM, Models designed to improve care delivery and reduce expenditures for Medicaid and Children’s Health Insurance Program (CHIP) beneficiaries affected by the nation’s opioid crisis. “By catalyzing state-driven care transformation and aligning financial incentives, both models aim to improve health outcomes and address fragmentation of care for affected beneficiaries,” the Innovation Center noted. “Ultimately, the InCK and MOM models aim to enable better coordination of clinical care and the integration of other services critical for health, wellbeing, and recovery.” 14. Manatt, AMA & Pennsylvania Medical Society Release Report on Practices to End Opioid Crisis Manatt Health, the American Medical Association (AMA), and the Pennsylvania Medical Society last month released a report that examines what Pennsylvania has accomplished in the areas of substance use disorder treatment, pain management, and harm reduction to combat the opioid crisis. The report focuses on the work of two agencies—the Pennsylvania Medicaid agency and the Pennsylvania Insurance Department—and highlights in particular Pennsylvania’s broad support for Medication Assisted Treatment (MAT), parity law enforcement, and comprehensive naloxone access. Researchers also included recommendations on how Pennsylvania can “build on its successes, including expanding efforts in emergency departments and law enforcement to link patients to high-quality care, and requiring insurers to enhance access to non-opioid care so that patients have alternative treatments as opioid prescriptions are reduced.” 15. CHCS and ACAP Release Report on Social Determinants of Health via Medicaid Managed Care The Center for Health Care Strategies (CHCS) and the Association for Community Affiliated Plans (ACAP) last month released findings of a nationwide review of Medicaid managed care contracts and section 1115 demonstrations to identify common themes in state approaches to incentivizing and requiring social determinant of health-related activities (SDOH). Addressing Social Determinants of Health via Medicaid Managed Care Contracts and Section 1115 Demonstrations includes five specific policy recommendations from CHCS to support SDOH activities: make  it easier for vulnerable populations to access needed health services; enhance agency collaboration at the federal level; provide guidance on addressing SDOH through managed care; approve section 1115 demonstrations that test strategies to address SDOH; and support outcomes-based payment for SDOH interventions.   16. Associations Among Motor Activity, Sleep, Energy & Mood Could Suggest New Focus for Depression Treatment Instability in activity and sleep systems could lead to mood changes—which could suggest new approaches for depression treatment, according to new findings published online in the journal JAMA Psychiatry. Current theories of depression suggest that sleep problems, low energy, and low activity levels result from depressed mood, but this new study that examines these factors among people with bipolar disorder or depression suggest the opposite may be true, the National Institute of Mental Health noted in its announcement about the study. Researchers “discovered a unidirectional relationship between motor activity and mood, suggesting that motor activity affects subsequent mood, but that mood does not affect subsequent motor activity and sleep systems could lead to mood changes,” the NIH posting said. 17. NIDA Highlights Details for National Drug and Alcohol Facts Week  The National Institute on Drug Abuse (NIDA) has posted information about National Drug and Alcohol Facts Week, a national health observance from Jan. 22–27, 2019 that will link teens to science-based facts about drugs. NIDA’s website features details about hosting an event, an online teaching guide, free materials, activity ideas and toolkits, and more. 18. World Congress to Host Opioid Management Summit in February World Congress—which hosts conferences and events in healthcare, life sciences, and pharmaceuticals—will host its third annual Opioid Management Summit at the Wink Hotel in Washington, D.C. from February 26-27, 2019. A panel discussion titled Ensure Resources and an Integrated Care Continuum Support Treatment and Recovery will be hosted on the second day of the conference. Click here to learn more and register for the meeting.   19. Register Today for 2019 Annual Meetings The National Association for Behavioral Healthcare (NABH) and the American Hospital Association (AHA) have posted the dates for their 2019 Annual Meetings in Washington, D.C. NABH will host its Annual Meeting from March 18-20, 2019 at the Mandarin Oriental Washington, DC, and the AHA will host its Annual Meeting from April 7-10, 2019 at the Marriott Marquis. Jessica Zigmond prepared this edition of Behavioral Health Update. Feel free to give us your feedback, stories, and suggestions:  NABH:  Jessica Zigmond, NABH, jessica@nabh.org, 202.393.6700, ext. 101; AHA:  Rebecca Chickey, AHA SPSAS, rchickey@aha.org, 312.422.3303 Copyright 2019 by the American Hospital Association and the National Association for Behavioral Healthcare. All rights reserved.  For republication rights, contact Jessica Zigmond.  The opinions expressed are not necessarily those of the American Hospital Association or of the National Association for Behavioral Healthcare.