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CEO Update 145

MedPAC Report to Congress Analyzes Behavioral Health Services and Patients

In its annual report to Congress last week, the Medicare Payment Advisory Commission (MedPAC) examined behavioral health services covered under Medicare’s inpatient and outpatient prospective payments systems and physician fee schedule. The 76-page report’s behavioral health chapter addresses Medicare beneficiaries’ service utilization patterns, Medicare spending trends to providers and clinicians, and payment adequacy and margins. Regarding access, the report notes a drop in inpatient psychiatric facility (IPF) patient volume from 2019 through 2021 (the most recent data evaluated) due to the COVID-19 pandemic. Meanwhile, during the same period, the occupancy rates grew in government IPFs—an indicator of service shortages for patients with severe mental illness. Concerning the 2021 acuity level of IPF patients relative to beneficiaries in other settings, IPF patients were 3.5 times more likely to be disabled and 2.4 times more likely to have low-income status (eligible for Part D low-income subsidy or dually-qualified for Medicare and Medicaid), metrics used as proxy indicators of acuity, according to the report. For telehealth, among other findings, MedPAC cited the widely recognized increased use in telehealth services for behavioral health patients, which grew to 28% in 2021 from 1% of Part B behavioral health services in 2019. MedPAC recommends gathering more information to assess the alignment between payments and the cost of care for ancillary and other behavioral health services, as well as additional data about patient-level outcomes. These additional data would be used to better understand variation in Medicare margins across IPF facility types, including differences due to scale and the mix of patients in different IPFs. The report also provides data on service utilization for patients affected by the Medicare’s 190-day-limit policy.

DOJ Releases Guidelines for Managing Substance Withdrawal in Jails

The U.S. Justice Department’s (DOJ) Bureau of Justice Assistance and the National Institute of Corrections this week released Guidelines for Managing Substance Withdrawal in Jails: A Tool for Local Government Officials, Jail Administrators, Correctional Officers, and Health Care Professionals.   In an announcement, DOJ said the document supports the department’s commitment to increasing access to evidence-based treatment for individuals with SUDs and those at risk for overdose, including individuals who are incarcerated or reentering their communities.   “These guidelines are a critical and much-needed resource to support local government officials, jail administrators, correctional officers and healthcare professionals faced with the difficult task of managing substance withdrawal in jail settings,” Associate Attorney General Vanita Gupta said in a statement. “Providing this new, evidence-based tool and treatment guidance, developed by a committee of clinical and correctional experts, will better safeguard the health and well-being of individuals at risk for or experiencing substance withdrawal in jails.”

DEA Now Requires One-Time Training for Buprenorphine Prescribing

Starting this week, the Drug Enforcement Agency (DEA) requires clinicians who register to prescribe controlled medications to complete a new, one-time, eight-hour training. In January, the Substance Abuse and Mental Health Services Administration (SAMHSA) announced clinicians no longer need a federal waiver to prescribe buprenorphine to treat opioid use disorder. Instead, the DEA now requires all clinicians prescribing any controlled substance to complete a one-time training. Exceptions for the training requirement include practitioners who are board-certified in addiction medicine or addiction psychiatry, and those who graduated from a medical, dental, physician assistant, or advanced practice nursing school in the United States within five years of June 23, 2023. In addition, Rural Health Clinics (RHCs) will have the opportunity to apply for a $3,000 payment on behalf of each provider who received buprenorphine waiver training between Jan. 1, 2019 and Jan. 25, 2023 (when Congress eliminated the waiver requirement). According to the Health Resources and Services Administration, about $900,000 in program funding remains available for RHCs and will be paid on a first-come, first-served basis.

The International Certification and Reciprocity Adopts SAMHSA’s National Model Standards for Peers

The International Certification and Reciprocity Consortium (IC&RC) has announced it has adopted SAMHSA’s National Model Standards for Peer Support Certification in the form of a new credential. In an announcement, the IC&RC said this national entry-level peer credential is intended to be the first rung of a career ladder that will lead to stronger substance use disorder (SUD) workforce development that is needed greatly nationwide. The IC&RC is the first—and currently only—nationally recognized, peer-certification organization to adopt the standards.

FDA Publishes First Draft Guidance on Psychedelic Drug Trials

The U.S. Food and Drug Administration (FDA) has published its first draft guidance on clinical trials for psychedelic drugs as research on using psychedelic drugs to treat conditions such as depression and post-traumatic stress disorder increases. In an announcement, FDA noted that developing psychedelic drugs poses several challenges, including minimizing the risk of the drugs being misused and addressing the role that psychotherapy plays in psychedelic drug administration. “By publishing this draft guidance, the FDA hopes to outline the challenges inherent in designing psychedelic drug development programs and provide information on how to address these challenges,” Tiffany Farchione, director of the division of psychiatry in FDA’s drug center, said in a news release. “The goal is to help researchers design studies that will yield interpretable results that will be capable of supporting future drug applications.”

GAO Examines Behavioral Healthcare Services in Critical Access Hospitals

A new Government Accountability Office (GAO) study of 10 critical access hospitals (CAHs) found that these providers offered behavioral healthcare services in a variety of ways in various settings, including emergency departments, inpatient services, and outpatient services. Unlike other hospitals, under Medicare fee-for-service, CAHs are paid based on the cost of providing services in most, but not all, care settings. GAO researchers received mixed views on how Medicare fee-for-service payment policies affect CAHs’ ability to provide behavioral healthcare services in various settings that are not paid solely based on cost. GAO said officials from multiple CAHs and stakeholders said factors outside Medicare were “substantial challenges” to their ability to provide behavioral healthcare services and patients’ access to these services. “Hiring and recruitment of behavioral health professionals, such as psychiatrists and licensed clinical social workers, was cited as one of their biggest challenges due to nationwide workforce shortages,” the study said. “In addition, they said shortages of inpatient psychiatric beds made it difficult to find inpatient treatment for their patients,” the study continued, adding that patients were sometimes stuck in an emergency department for several days waiting to be transferred to an open psychiatric bed elsewhere in their community or state.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week:

The two most common mental disorders among adults aged 18 to 65 were major depressive disorder (15.5%, or about 31.4 million adults) and generalized anxiety disorder (10%, or about 20.2 million adults), according to the SAMHSA-funded Mental and Substance Use Disorders Prevalence Study from RTI International. The NABH team wishes all its members, their teams, and their families a safe and happy Independence Weekend! For questions or comments about this CEO Update, please contact Jessica Zigmond.