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CEO Update 246

House Passes Short-Term Funding Bill

The House passed a continuing resolution on Friday to fund the federal government through Nov. 21, which would give Congress more time to develop a full-year funding package.
 
The bill now heads to the Senate, where it needs 60 votes to pass, necessitating some Democratic votes in support. Congress must pass the bill by the end of September to avoid a government shutdown.
 
The bill also includes several healthcare extenders, including delaying the expiration date for Medicare telehealth flexibilities and preventing cuts to the Disproportionate Share Hospital (DSH) program, which helps hospitals cover the cost of treating patients who are uninsured or underinsured. This comes amidst growing Congressional concern about the significant potential harms of DSH cuts, with a bipartisan group of 141 Representatives sending a letter to House leadership this week urging that current funding be maintained.
 
However, the bill does not extend the enhanced premium tax credit (EPTC) that improves the affordability of Marketplace plans.

Senate Passes SUPPORT Act Reauthorization

On Thursday, the Senate passed the SUPPORT for Patients and Communities Reauthorization Act of 2025, which reauthorizes billions of dollars in funding to address overdoses, substance use disorders, and mental disorders.
 
A variety of programs are reauthorized through fiscal year 2030, such as grants to address substance use disorders among pregnant and postpartum women, grants to promote housing for individuals in recovery from substance use disorders, and a loan repayment program for certain health care providers treating substance use disorders.
 
Additionally, the bill establishes new requirements for the U.S. Department of Health and Human Services, including establishing a Federal Interagency Work Group on Fentanyl Contamination of Illegal Drugs, and conducting a review of the scheduling of buprenorphine/naloxone combination products under the Controlled Substances Act.
 
The Act previously passed the House on June 4, 2025. With Senate passage, the bill now goes to the President for his signature.

CMS Finalizes New Provide Directory Requirements for Medicare Advantage Organizations

The Centers for Medicare & Medicaid Services (CMS) this week finalized a new rule that will require Medicare Advantage (MA) organizations to submit data on their provider directories, which will be published online as part of the Medicare Plan Finder tool.
 
In addition to providing the data to CMS, MA organizations will need to update their provider directory data within 30 days of discovering any changes, as well as attest to CMS at least annually that the information submitted is accurate.
 
The final rule will be applicable beginning Jan. 1, 2026.

Please Submit Changes for the NABH 2025 Membership Directory by Friday, Oct. 3

NABH is compiling information for its 2025 Membership Directory, which we will publish online only. To help ensure we have the most accurate information on our members, please use the link to our membership update tool that was sent earlier this week to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
The answers to these questions will help us provide a more accurate description of our members to policymakers, regulators, partner organizations, and the media.
 
The deadline to submit your changes to NABH is Friday, Oct. 3.  If you need assistance or the link to be resent, please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104.
 
As always, thank you for your time and for all you do to provide quality behavioral healthcare to those who need it most.

CBO Estimates $350 Billion Cost to Permanently Extend EPTC

This week, the Congressional Budget Office (CBO) released a new estimate of the effects of permanently extending the EPTC – a credit that reduces the premiums of Marketplace plans – which is scheduled to expire at the end of calendar year 2025 after first being introduced in 2021.
 
CBO estimates that permanent extension would increase the federal deficit by $350 billion through 2035, and by that year, 3.8 million more people would have health insurance than if the EPTC reverts to its original structure. They also estimate that benchmark plan premiums would be 7.6% lower (not factoring in the tax credit), given that healthier individuals would be more likely to enroll with the EPTC.
 
The original premium tax credit was limited to individuals with incomes between 100-400% of the federal poverty level, while the EPTC eliminated the maximum income threshold for eligibility.

Senate Confirms EBSA Nominee

The Senate on Thursday confirmed Daniel Aronowitz to lead the Employee Benefits Security Administration (EBSA) in the U.S. Department of Labor.
 
Previously, Mr. Aronowitz served as the President of Encore Fiduciary, a fiduciary liability underwriting company.
 
EBSA is the primary federal regulator overseeing employee benefits, including most employer-sponsored health plans. Notably, EBSA is one of three agencies – alongside CMS and the Internal Revenue Service – tasked with implementing the Mental Health Parity and Addiction Equity Act.

CMS Releases Rural Health Transformation Program Funding Opportunity

On Monday, CMS released the Notice of Funding Opportunity (NOFO) for the Rural Health Transformation (RHT) Program. Congress appropriated $50 billion for the RHT Program in H.R. 1, which will be available to states for five fiscal years.
 
CMS will issue cooperative agreements to states with approved applications. States must involve rural stakeholders – which could include NABH members with facilities in rural areas – throughout the application and implementation phases. CMS also requires states to identify the organizations intended to receive RHT funding within their applications. Therefore, NABH encourages all members to review the NOFO and work with their states to support their RHT Program application.

CMS will host two webinars for program applicants and interested stakeholders:

  • Friday, Sept. 19 from 3 – 4:30 p.m. ET; register here.
  • Thursday, Sept. 25 from 3 – 4:30 ET; register here.

States must submit applications by Nov. 5, 2025. CMS will only have one funding opportunity for this program and will announce awardees by Dec. 31, 2025.

Joint Commission and Coalition for Health AI Issue Guidance for Responsible Use of AI

Joint Commission and the Coalition for Health AI (CHAI) on Wednesday issued guidance on artificial intelligence (AI) use in healthcare, which is intended to “serve as internal governance to help U.S. health systems safely and effectively implement [AI] at scale.”
 
The guidance includes high-level recommendations for responsible use of AI across seven elements: AI Policies and Governance Structures, Patient Privacy and Transparency, Data Security and Data Use Protections, Ongoing Quality Monitoring, Voluntary, Blinded Reporting of AI Safety Related Events, Risk and Bias Assessment, and Education and Training.
 
From these high-level recommendations, Joint Commission and CHAI will develop a series of playbooks to include baseline controls, examples, and challenges to each element. The organizations are soliciting feedback on the initial document and will incorporate community feedback and examples into updates of this guidance and the Playbooks, which they say will be released later this year and into 2026.
 
If any NABH members have feedback on the newly released guidance or how AI is or could be used in their organizations, please contact Emily Wilkins, NABH’s director of government relations (emily@nabh.org).

GAO Releases Report on Administrative Spending for Georgia’s Medicaid Work Requirements

The Government Accountability Office (GAO) released a report this week examining the administrative processes and costs to implement work requirements in Georgia’s Medicaid program.
 
In 2020, CMS approved Georgia’s Medicaid section 1115 demonstration request to expand coverage to adults aged 19-64 contingent on them reporting 80 hours of work or educational activities each month. To implement the demonstration, Georgia needed to make several changes to their administrative eligibility and enrollment systems, conduct specialized outreach efforts, and undertake other administrative tasks prior to opening enrollment in 2023.
 
In the first 4.5 years of the program, Georgia reported spending $80.3 million total, of which $54.2 million were administrative costs. The federal government funded 88% ($47.4 million) of the administrative costs, which GAO warns may have exceeded the allowable match rate. In addition to the high administrative costs to the federal government, GAO found weaknesses in CMS’ oversight of that spending.
 
This report helps shed light on the processes and costs associated with Medicaid work requirements, which is especially important as states begin implementing work requirements and other changes to Medicaid included in H.R. 1.

Fact of the Week

A new study found that individuals with opioid use disorder who received medication during incarceration were more likely to continue treatment six months post-release than those who did not. Medication receipt was also associated with substantial reductions in adverse risks: 52% for fatal opioid overdose, 24% for nonfatal opioid overdose, 56% for all-cause mortality, and 12% for reincarceration.

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