CEO Update 89
White House Proposes Changes to IMD Exclusion in 2021 Budget Proposal to Congress
The White House this week released a $4.8 trillion budget for 2021 that would modify Medicaid’s Institutions for Mental Diseases (IMD) exclusion to provide states with flexibility to provide inpatient mental health services to beneficiaries with serious mental illness (SMI).
The budget requests $94.5 billion for HHS, a 10-percent decrease from the 2020 enacted level. Although Congress is likely to reject President Trump’s proposal, the budget is significant for outlining the president’s top policy priorities as he seeks re-election in November. Notably for NABH, those priorities include mental health and addiction treatment services.
That includes changes to the IMD exclusion, which under current law states Medicaid cannot pay for certain inpatient stays at IMDs. The president’s budget would provide more than $5 billion in new federal funding to states to ensure the full continuum of care exists to provide help to people with SMI. These changes—which appear in summary tables at the end of the budget proposal—would also exempt Qualified Residential Treatment Programs (QRTPs) from the IMD exclusion.
The budget also includes $225 million for Certified Community Behavioral Health Clinics (CCBHC) expansion grants, and would extend, through 2021, the CCBHC Medicaid demonstration programs to improve community mental health services for the eight states participating currently in the demonstration. In addition, the White House has proposed $25 million to expand primary healthcare services to address homelessness. These provisions, together with the changes to the IMD exclusion, are “part of a comprehensive strategy that includes improvements to community-based treatment,” the budget proposal noted.
Meanwhile, the president’s 2021 budget would continue 2020 funding to expand medication assisted treatment (MAT) from a small pilot program to half of all eligible Bureau of Prisons (BOP) facilities and provide an additional $37 million to complete MAT expansion to all eligible BOP facilities.
The proposal also includes $1.6 billion—an $85 million increase from the 2020 enacted level—for State Opioid Response grants, which support prevention, treatment, and recovery support services. States would be given flexibility to use these funds to address the increasing number of overdoses related to psychostimulants, including methamphetamines.
NABH will continue to analyze the Trump administration’s budget proposal and keep NABH apprised of any additional details regarding the IMD exclusion, MAT funding, and other topics related to the association’s policy priorities.
CMS Recommends 2020-2021 Policy Changes to Several Programs in Proposed Rule
The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would revise regulations for Medicare Advantage (Part C), the Medicare Prescription Drug Benefit (Part D) program, the Medicare Cost Plan, Programs of All-Inclusive Care for the Elderly (PACE), and the Medicaid program in 2020 and 2021.
According to a summary, the rule would implement certain sections of the Bipartisan Budget Act of 2018, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT), and the 21st Century Cures Act. The rule aims to improve Medicare’s Part C and D programs, codify several existing CMS policies, and implement other technical changes.
For Medicare Part D’s mandatory drug management programs (DMPs), the rule proposes to reduce the misuse of opioid medications in prescription drug plans. Currently, Part D plan sponsors are required to include Part D beneficiaries with a history of opioid-related overdose in DMPs. The rule would create a new exemption DMP category that includes individuals with sickle cell disease, those who receive hospice care, or those who live in long-term care facilities.
CMS will accept public comments on the rule through Monday, April 6.
NABH Supports FCC’s Suicide Hotline Implementation Act Proposed Rule and Nutrition CARE Act
NABH this week joined other members of the Mental Health Liaison Group (MHLG) in sending a public comment letter to Federal Communications Commission Chairman (FCC) Ajit Pai about the FCC’s proposed rule for the Implementation of the National Suicide Hotline Improvement Act of 2018.
“MHLG fully supports the FCC’s proposed rule plan to identify a three-digit number – 9-8-8 – to be designated for suicide and other mental health crises,” the MHLG wrote. “It is important that the designated number can be implemented quickly and with minimal confusion for the public,” it continued. “We implore the FCC and other policy leaders to make it a priority for the new 9-8-8 system to be nationally available and adequately resourced, so that all Americans have access to this crisis line.”
NABH also recently signed onto a letter of support for the Nutrition Counseling Aiding Recovery for Eating Disorders (CARE) Act, which would provide medical nutrition therapy (dietitian services) for seniors and persons with disabilities who are affected by eating disorders under Medicare Part B. As the letter notes, eating disorders are serious mental illnesses that affect 30 million Americans in the course of their lifetime. These disorders have the second highest mortality rates of any psychiatric illness after opioid use disorder.
NABH was one of 27 organizations that sent the letter to Senate Finance Committee Chairman Chuck Grassley (R-Iowa) and Ranking Member Ron Wyden (D-Ore.) to urge the committee to advance S. 2907 for consideration.
CMS to Host Medicare Learning Network Event on Availability of SUD Benefits
CMS will host a Medicare Learning Network event next week to seek feedback from clinicians and associations that represent healthcare providers on what supplemental benefits they use to treat Medicare Advantage patients with substance use disorders (SUDs).
The SUPPORT Act outlines strategies to address opioid misuse and requires CMS to evaluate the extent to which Medicare Advantage plans offer supplemental benefits to treat or prevent SUDs not otherwise covered under traditional Medicare, including how clinicians are impacted by the availability of supplemental benefits used to treat SUDs.
A presentation will be available before the event, which CMS will host on Tuesday, Feb. 18 from 1:30 p.m. until 3 p.m. ET. Click here to learn more and to register.
Join Us for Hill Day at the NABH 2020 Annual Meeting!
NABH is pleased to present Hill Day 2020 at the association’s Annual Meeting in Washington, D.C. on Tuesday, March 17 from 1:30 to 5 p.m. ET.
The NABH team will schedule Capitol Hill meetings and briefings for Annual Meeting attendees interested in Hill Day and will provide background materials and legislative priority documents to attendees before the Annual Meeting.
To take advantage of this free opportunity, please indicate that you want to participate in Hill Day when you register for the Annual Meeting, or contact Julia E. Richardson, director of advocacy and senior counsel, at julia@nabh.org or 202.393.6700, ext. 103.
Please visit NABH’s Annual Meeting homepage to view the meeting’s preliminary program and learn about the meeting’s speakers, exhibitors, and sponsors.
We look forward to seeing you next month!
Fact of the Week
In 2018 an estimated 31.9 million Americans reported using an illicit drug in the past month.
For questions or comments about this CEO Update, please contact Jessica Zigmond