CEO Update 249
Please Help Us Identify New NABH Board Members
As the NABH Selection Committee prepares to consider possible nominees, please help us identify potential candidates for:
► Board Chair-Elect and
► One Board seat that will open in 2026
The Selection Committee is interested particularly in identifying senior managers who represent the broad diversity of NABH’s membership, including various levels of care, organizational structures, and size.
Please download a nomination form to recommend individuals you would like to see included in the single slate for 2026. Please attach a curriculum vitae (CV) for each person you recommend. This will help the Selection Committee in its deliberations. You are welcome to suggest yourself.
Please return this form (and candidates’ CVs) by Monday, Oct. 20, 2025, to maria@nabh.org.
Thank you for your time and recommendations!
Please Submit Updates for the NABH’s Online Membership Directory
NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
The original deadline for changes was Oct. 3; however, the NABH team is glad to receive this information at any time because it is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September 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.
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.
Thank you for your time and all you do to advance NABH’s Vision and Mission!
Uncertainty Remains After Oct. 1 Telehealth Changes Arrive
NABH and its members are looking to CMS for additional guidance after the agency’s telehealth requirements became effective on Oct. 1.
For the last several years, Congress extended telehealth policies set to expire on Sept. 30 to allow continued Medicare reimbursement for telehealth services that were not allowed before the Covid-19 public health emergency (PHE).
That changed on Oct. 1 after Congress failed to extend those telehealth flexibilities and CMS furloughed staff during the federal government shutdown, leaving providers confused about what they should bill Medicare for and how.
Thanks to previous congressional action, mental health and substance use services delivered through telehealth services continue to be covered in many cases. For instance, substance use services and services provided for co-occurring mental health and substance use conditions may be delivered via telehealth, regardless of a patient’s geographic location or originating site (i.e., physical location, such as a person’s home).
As of Oct. 1, 2025, CMS requires that if patients receive a mental health telehealth visit, they must have had an in-person visit within the past 6 months (and every 12 months after the initial telehealth visit). When this requirement was imminent at the end of the PHE on May 11, 2023 (before Congress acted to extend flexibilities), CMS said it would waive the requirement for established patients to have received an in-person visit within the past 6 months, requiring only an annual in-person visit thereafter (this requirement was also delayed through Sept. 30, 2025).
Presently, without further guidance, providers cannot be certain if CMS will grandfather established patients and only require an in-person visit within the preceding 6 months for new telehealth patients.
Meanwhile, for new and established patients receiving mental health services via telehealth, CMS allows the required in-person service to be administered by a colleague in the same sub-specialty within the same group practice if the original practitioner is unavailable. In addition, patients and providers may agree to waive the in-person visit if the “risks and burdens of travel outweigh the benefits of an in-person encounter,” according to CMS. If the patient and provider waive the in-person visit, the practitioner must document the reason for this decision in the patient’s medical record.
NABH had hoped CMS would provide information about this policy change; however, since the government shutdown began, CMS has not released additional guidance. As a reminder, this policy change only affects Medicare mental telehealth visits billed to the Physician Fee Schedule and does not impact Medicaid, commercial, PHP/IOP, IPF, or substance use services.
The Center for Connected Health Policy released an FAQ Resource Document to address complex questions Medicare providers may have.
NABH urges members to consult their billing and legal experts to determine their approach to the uncertainty, and we will keep members apprised of any new information we learn.
HHS OIG Recommends Changing Medicare OTP Funding Methodology to Lower Expenditures
A report from the U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) this week showed if the Medicare program’s Opioid Treatment Program (OTP) bundled payment methodology had better reflected the frequency of services delivered, the program could have saved Medicare $301.5 million (53% of total payments to OTPs) between Jan. 1, 2020 and Sept. 30, 2022.
The HHS OIG provided several recommendations to the Centers for Medicare & Medicaid Services (CMS), including that the agency should: 1) consider revising its methodology for the non-drug component of the bundle, 2) consider developing additional HCPCS codes for bundles based on the types and frequency of services provided, and 3) perform monitoring activities to ensure that Medicare only pays when OTPs have properly documented treatment services in patients’ treatment plans.
CMS has implemented the first recommendation and indicated it will consider revisions to the bundled payment methodology each year during the rulemaking process. Meanwhile, CMS did not concur with the second or third recommendations. For recommendation #2, CMS said the recommendation is outside the scope of CMS’ statutory authority; and for #3, CMS said it does not require treatment plans as a condition of payment.
Digital Medicine Society Releases Blueprint for Implementing AI in Healthcare
The Digital Medicine Society has released The Playbook, a guide to implementing AI that the organization says is meant to help providers navigate the complexities of AI into clinical care and deliver better outcomes for patients.
The new resource guides users through three, interconnected sections: 1) Identify the Problem and Assess Your Readiness, 2) Source, Evaluate, and Choose the Right AI Tool, and 3) Implement AI Across Your System.
In related news, the U.S. Food and Drug Administration (FDA) announced last month it will convene an advisory committee on AI and mental health devices. Reuters reported in September that the FDA Digital Health Advisory Committee expected to meet on Nov. 6 to examine how these digital tools could help address a widening gap in access to mental health services in the United States, while also exploring the unique risks they pose.
Attention All NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!
To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.
Fact of the Week
A recent survey from the International Academies of Emergency Dispatch found most mental health crisis calls in the United States still go to 911, not 988: the findings showed that in 2023, Emergency Crisis Centers (ECCs) across the United States received at least 24 million calls involving a mental health crisis, compared with the 17 million calls, texts, and chats the 988 Suicide & Crisis Lifeline received since its launch in 2022.
For questions or comments about this CEO Update, please contact Jessica Zigmond.