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CEO Update 120

CMS Gives Medicare Part A & B Providers One More Year to Repay AAP Loans

The Centers for Medicare & Medicaid Services (CMS) said Thursday it will give Medicare Part A and B providers and suppliers an additional year to repay loans the agency made to them during the Covid-19 public health emergency (PHE). CMS had advanced payments to Medicare Part A and B providers and suppliers through the Accelerated and Advance Payment (AAP) program to help cover costs as the PHE disrupted healthcare services this year. Initially CMS had required providers to start making repayments in August 2020. “CMS’ advanced payments were loans given to providers and suppliers to avoid having to close their doors and potentially causing a disruption in service for seniors,” CMS Administrator Seema Verma said in an announcement. “While we are seeing patients return to hospitals and doctors providing care we are not yet back to normal,” she added. According to the agency’s new terms, after that first year, CMS will automatically recoup 25% of Medicare payments otherwise owed to the provider or supplier for 11 months. After that period, CMS will increase the recoupment amount to 50% for another six months. CMS said it will send letters to providers who have any outstanding balances after the entire period—a total of 29 months— informing them that repayment will be subject to a 4% interest rate. Those letters will also include guidance on how to request an Extended Repayment Schedule (ERS) due to financial hardship. The agency’s announcement urged providers and suppliers to contact their Medicare Administrative Contractor for information about how to request an ERS. An ERS will allow a provider or supplier to repay these debts over the course of three to five years. CMS also said providers and suppliers may use Provider Relief Funds to repay these Medicare loans. CMS said it will communicate with each provider and supplier about the amount they owe and all applicable terms in the coming weeks.

New CMS Guidance Requires Psychiatric Hospitals to Report Covid-19 Data Weekly

CMS has released guidance that requires Medicare- and Medicaid-participating psychiatric hospitals to report Covid-19 data to the agency on a weekly basis. CMS published an interim final rule in early September that said hospitals would be required to submit Covid-19 data during the public health emergency in a frequent, standardized way that the U.S. Health and Human Services Department (HHS) secretary specified. This week’s awaited guidance makes it clear that the nation’s psychiatric hospitals—along with rehabilitation hospitals—need to report their data weekly, and not on a daily basis as other hospital types are required to do. NABH advocated for CMS to lessen the reporting frequency for psychiatric hospitals and is pleased with the change. The agency listed the required data in new guidance and also developed an infographic that highlights when the agency plans to alert hospitals about gaps in reporting and compliance. These materials are also available on NABH’s Covid-19 resources webpage.

HRSA Releases Provider Relief Fund Phase 3 Distribution Guide and Fact Sheet

HHS’ Health Resources and Services Administration (HRSA) has released a 12-page provider guide and separate fact sheet to help the nation’s healthcare providers navigate the third phase of the Provider Relief Fund (PRF) distribution during the Covid-19 pandemic. The guide includes specific details on eligibility requirements, application requirements, and reporting guidelines, while the fact sheet condenses the guide’s information and also provides links. HHS announced an additional $20 billion in additional funding last week and encouraged behavioral healthcare providers to apply. The department also developed a list of providers eligible for the funding, including addiction counseling centers, mental health counselors and psychiatrists. The Phase 3 Distribution application process opened this past Monday, Oct. 5, and the application deadline is Friday, Nov. 6. HRSA has scheduled an informational webinar to learn more about the Phase 3 Distribution process next Thursday, Oct. 15 at 3 p.m. ET. Click here to register. HHS has scheduled a webinar about the Phase 3 Distribution process specifically for behavioral healthcare providers and the associations that represent them for Friday, Oct. 16 at 3 p.m. ET. Click here to register.

NABH Submits Comments to CMS on 2021 Physician Fee Schedule Proposed Rule

NABH on Oct. 2 provided feedback to CMS on the telehealth services and substance use disorder (SUD) provisions in the agency’s 2021 physician fee schedule (PFS) proposed rule. In a letter to CMS Administrator Seema Verma, NABH said it supports the proposed rule’s provisions that would continue some of the expanded Medicare coverage of services provided via telehealth, including provisions to extend permanently Medicare coverage for group psychotherapy and psychological testing. The association also said it supports those provisions clarifying that clinical social workers and clinical psychologists and therapists can furnish online assessment and management services, virtual check-ins, and remote evaluations. “We urge you to continue covering evaluation and management services and behavioral health counseling as well as opioid/addiction treatment program counseling and periodic assessment services provided via audio-only technology, i.e., telephone,” the letter said. “Furthermore, we recommend continuing to pay for these services at the same or comparable rates as in-person care—as well as paying for administrative fees to help cover the costs of this technology.” NABH also provided comments on the Opioid Treatment Program (OTP) bundled payment regulations, emphasizing more equitable reimbursement for naloxone and community education for naloxone, as well as reduced limitations on the frequency of reimbursement to align with medical necessity determinations. In addition, NABH’s letter said the association supports continued coverage of periodic telehealth assessments beyond the PHE (including audio-only), and to be reimbursed every 60-90 days, consistent with many state requirements to perform such assessments. The association encouraged CMS to continue the simple, one-bundle structure that has been used successfully to date and reiterated NABH’s recommendation from last year that CMS provide a 17% adjustment to encourage the development of rural OTPs. And NABH underscored the importance of continuing to permit greater flexibility in take-home medications, as well identifying the need to permit reimbursement for OTPs who are under a Substance Abuse and Mental Health Services-provisional certification. Finally, NABH supported the agency’s proposal to expand the PFS bundled payments for Opioid Use Disorder to all SUDs.

U.S. Labor Department to Provide $40 Million in Rural Healthcare Workforce Training Grants 

The U.S. Labor Department’s Employment and Training Administration has announced about $40 million in available grant funding for employment and training programs in healthcare occupations—including behavioral and mental healthcare—that serve rural populations. According to the announcement, employment and training programs through this funding can propose a wide range of models, including Registered Apprenticeship Programs and Industry-Recognized Apprenticeship Programs. Pre-apprenticeships are permitted only “as on-ramps” to apprenticeship programs proposed as a response to the funding notice and must lead to apprenticeships during the life of the grant. The deadline to apply is Friday, Nov. 13. Click here for additional information and how to apply.

U.S. Justice Department to Develop Guidelines to Manage Substance Withdrawal in Jail-based Settings

The U.S. Justice Department’s Bureau of Justice Assistance (BJA) and the National Institute of Corrections is seeking feedback to develop evidence-based, clinical guidelines and protocols that will help jail administrators, correctional officers, and jail-based clinicians identify and safely manage substance withdrawal in jail-based settings. According to an announcement, the guidelines will address a host of issues, including, but not limited to, rapid withdrawal from opioids, benzodiazepines, alcohol, methamphetamine, and cocaine individually or in combination, including specification of persons who exhibit withdrawal symptoms or report histories or information from other sources that indicate the necessity of immediate referral to medical facilities outside of the jail; screening for risk of suicide, specifically opioid withdrawal-potentiated suicides; and medication maintenance for entering detainees with prescriptions for opioid or antipsychotic medications. The BJA will select one applicant for a 10-month award to create a document that outlines the guidelines and protocols. Applications are due by Wednesday, Oct. 28. Click here for more information.

Joint Commission to Host Virtual Behavioral Health Care and Human Services Conference

The Joint Commission will host its Behavioral Health Care and Human Services conference in a virtual format on Friday, Oct. 28. This year, attendees will have the option to choose from two tracks: Track A, designed for organizations accredited under the Behavioral Health Care Accreditation Manual, and Track B, intended for those accredited under the Hospital Accreditation Manual and supplemented with the Behavioral Health Care Manual. Click here for more information and to register.

Today is the Deadline to Submit Recommendations for the 2021 NABH Board of Trustees

The deadline is today, Friday, Oct. 9, to submit nominees for NABH’s Board Chair-Elect and three NABH Board of Trustees seats that will become available in 2021. NABH’s Selection Committee is particularly interested in identifying senior managers who represent broad diversity within the NABH membership, including various levels of care, organizational structures, and size. If you have not done so yet, please download a nomination form to share your recommendations of individuals you would like to see included in the single-slate ballot for 2021. Please be sure to attached a curriculum vitae (CV) for each individual you recommend, which will help the Selection Committee in its deliberations. You are welcome to recommend yourself. Please send your completed form and all candidate CVs to NABH Director of Operations Maria Merlie. Thank you for your time!

Please Complete the 2020 NABH Annual Survey! 

The 2020 NABH Annual Survey opened in late August and NABH members should have received personalized links to the survey from consulting firm Dobson DaVanzo. If you have not received a link, please click here and follow the instructions to submit your survey today. Your feedback will help inform and improve NABH’s advocacy efforts. The survey closes on Saturday, Oct. 31. Thank you for your time!

Fact of the Week

In the first half of 2019, just more than one in 10 adults (11%) reported symptoms consistent with a diagnosable anxiety or depressive disorder. By July 2020, during the Covid-19 pandemic, that number had increased to 40%. For questions or comments about this CEO Update, please contact Jessica Zigmond.