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CEO Update 210

NABH Welcomes Dan Schwartz as New Director of Quality and Addiction Services

NABH is pleased to welcome Dan Schwartz as the association’s new director of quality and addiction services, effective this past Monday, Dec 9.
 
Dan brings to NABH a range of experiences in federal agencies related to addiction services, including most recently in his role as a senior behavioral health policy analyst in the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services (HHS). 
 
In that role, Dan engaged in federal policymaking efforts by providing subject matter expertise about the delivery, financing, and regulation of behavioral health services, with an emphasis on the substance use disorder care continuum, controlled substances, and various mental health topics.
 
Dan also served as the staff lead for the HHS Workgroup on Implementation Strategies for Contingency Management; co-led a workgroup that supported developing legislative proposals related to behavioral health; and was a lead analyst for developing and implementing the HHS Overdose Prevention Strategy.
 
“We are excited to have Dan join our team,” said NABH President and CEO Shawn Coughlin. “He brings energy, experience, and enthusiasm to a critical role in our association.”
 
Prior to working at ASPE, Dan worked at the White House Office of National Drug Control Policy and the Substance Abuse and Mental Health Services Administration.
 
Dan earned a master’s degree in public health from Johns Hopkins University, where he was a Bloomberg Fellow in Addiction & Overdose, and a bachelor’s degree in public health from George Washington University.

ADAW Includes NABH Statement About OTPs in Article Responding to Recent NYT Story

The upcoming edition of the publication Alcohol and Drug Abuse Weekly (ADAW) includes a statement NABH posted to its website last weekend in response to a story in The New York Times (NYT) on Dec. 7 that did not provide a full and fair description of opioid treatment programs (OTPs).
 
“OTP facilities play a vital role in addressing the nation’s opioid and addiction crises, and it is imperative that we continue to support providers who do this important work so people in need can immediately access the personalized care, treatment options, and ongoing support services they need to achieve long-term recovery,” NABH said in its statement, which the association sent to members in an NABH Alert on Monday, Dec. 9.
 
ADAW also included responses and statements from The New York Times, NABH member Acadia Healthcare, and the National Association of Addiction Treatment Providers in its latest issue.

NABH and Other Groups Urge CMS to Strengthen MHPAEA Requirements in Medicaid & CHIP

NABH is one of 67 organizations that sent a recent letter to the Centers for Medicare & Medicaid Services (CMS) recommending ways the agency can strengthen the Mental Health Parity and Addiction Equity Act’s (MHPAEA) Medicaid and Children’s Health Insurance Program’s (CHIP) requirements.
 
The seven-page letter urges CMS to implement a host of measures, such as aligning the Medicaid MHPAEA regulations with those in private insurance and adopting the six-step comparative analysis framework for these templates (codified in the Consolidated Appropriations Act of 2021); strengthening enforcement provisions of MHPAEA in Medicaid and CHIP; amending the templates to require separate analysis and reporting of mental health and substance use disorder; and requiring the collection and evaluation of relevant outcome data to assess MHPAEA compliance in operation.
 
“We would encourage CMS to, at a minimum, post summary documents of these analyses in plain language so Medicaid enrollees and their authorized representatives can get meaningful information about whether and how their plan is in compliance with MHPAEA,” the letter concluded. “These summaries should be accompanied by additional instructions for consumers on how they can get claims processed or reprocessed when a violation has been identified, and how they can enforce their rights if they believe they have been subject to discrimination.”

Call for Behavioral Healthcare Clinicians to Help Develop IPF Patient Assessment Instrument

CMS and its contractor Abt Global are recruiting psychiatrists, psychologists, nurses and other behavioral healthcare clinicians to help develop and test a draft patient assessment tool known as the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).
 
CMS’ primary objectives for this significant policymaking process are to improve both quality of care and payment accuracy. Eventually, the agency plans to require that a common PAI be used during admission and discharge of every IPF patient.

NABH has confirmed with CMS that our members will have multiple opportunities to weigh in on this project. We strongly urge your participation in the alpha stage, during which Abt will identify the PAI data elements to field-test – a critical stage that requires real-world input from our field. 

To join the alpha stage of IPF PAI development, please apply here by Dec. 30, 2024.

NIMH to Host Webinar on Youth Suicidal Behaviors on Monday, Dec. 16

The National Institute of Mental Health (NIMH) will host an hourlong webinar about youth suicidal behaviors this Monday, Dec. 16 starting at 2 p.m. ET.
 
NIMH Acting Director Shelli Avenevoli, Ph.D., and researcher Arielle H. Sheftall, Ph.D. will examine current trends, risk factors, and protective strategies in youth mental health. The two presenters will also highlight research advancements that can shape future efforts to reduce suicide rates among young people in the United States.
 
Click here to register.

Pew Article Highlights How to Reduce Methadone Access Roadblocks in Pharmacies

The Pew Research Center published an article last week outlining federal and state policy changes that could facilitate access to methadone for opioid use disorder in pharmacies by streamlining legal and regulatory requirements to operate Opioid Treatment Program (OTP) medication units.
 
The recommended policy changes focus on approval processes; methadone ordering and storage; and inventory, recordkeeping, and reporting systems.
 
The article was based on a report by the Legislative Analysis and Public Policy Association that analyzes current state and federal laws and regulations that affect access to methadone in pharmacies, with specific consideration of three models for pharmacy-based methadone access: (1) a medication unit in a pharmacy, (2) a mobile medication unit near a pharmacy, and (3) methadone being prescribed by a clinician and dispensed at a pharmacy.

HHS Publishes Report on Wait Time Standards for Behavioral Health Network Adequacy

HHS released a report last week that examined how regulators implemented behavioral healthcare appointment wait time (WT) standards as part of insurance network oversight.
 
The report identified existing wait time standards used in federal and various state programs, including how they are defined, measured, reported, and enforced. Experts interviewed for the project emphasized the importance of using wait time standards to help ensure network adequacy of behavioral health services and acknowledged that further work is needed to refine and interpret standards and properly factor in telehealth and patient preferences.
 
“Regulators interviewed at times have imposed penalties on health plans found to be non-compliant with WT standards,” the report concluded. “However, they prefer to work with health plans to develop corrective action plans and find other strategies to address access gaps, viewing collaborative approaches as more productive than imposing penalties, which could exacerbate access problems for consumers,” it continued. “Regulators also recognize that provider shortages make it harder for health plans to recruit providers to their networks.”

Call for Presenters: NABH to Kick Off AI Webinar Series in 2025

NABH is seeking presenters who have integrated AI in their business operations to share their experiences in the association’s new webinar series about AI in behavioral healthcare scheduled for Spring 2025.
 
The first webinar will focus on using AI to reduce administrative burden and create efficiencies, and the second webinar will highlight using AI for clinical-decision support.

Please contact NABH Associate Manager for Congressional Affairs Emily Wilkins at Emily@nabh.org by close of business this coming Monday, Dec. 16 if you want to participate.   

ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

NABH recently hosted a webinar about using hospital data effectively in your negotiations with health plans.

The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. Please click here for the webinar’s recording and here for the presentation slides.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Deaths involving carfentanil increased sharply to an average of 34.4 a month between July 2023 and June 2024 from an average of 3.3 a month between January 2021 and June 2023, according to a recent report from the Centers for Disease Control and Prevention.

For questions or comments about this CEO Update, please contact Jessica Zigmond.