Author: Administrator

Republican Wins Bring Changes to White House and Congress; Leadership Posts Pending

Former President Donald Trump’s re-election to office on Nov. 5 also led a strong Republican wave in both chambers of Congress, with Republicans winning control of the Senate and likely retaining a small majority in the House of Representatives.
 
Either party needs 218 seats to win the majority in the House; as of this writing, Republicans can claim 211 seats, Democrats can claim 199 seats, and 25 races are too close to call.
 
In the Senate, Democrats have 45 seats, Republicans have 53 seats, and two seats are still too close to call. Senate Veterans Affairs Committee Chairman Jon Tester (D-Mont.) lost his bid for reelection. Meanwhile, Senate HELP Committee members Sherrod Brown (D-Ohio) and Bob Casey (D-Pa) lost their bids for a fourth term, while Sen. Tammy Baldwin (D-Wis.) was narrowly reelected to her third term.
 
Congress will return Nov. 12 to develop a funding package for FY 2025, while the deadline to fund the federal government is Dec. 20. With the change in both the administration and Congress, it is likely that Congress will pass a short-term Continuing Resolution (CR) until the Spring when the 119^th Congress will establish funding priorities.
 
House Republican leadership elections are scheduled for next Wed., Nov 13. Speaker Mike Johnson (R-La.) and members of the House Republican leadership are seeking reelection to their respective posts. Meanwhile, Senate Republican leadership elections will also likely be held Nov. 13, with Sens. John Thune (S.D.), John Cornyn (Texas) and Rick Scott (Fla.) vying to replace Sen. Mitch McConnell (Ky.) as Majority Leader. Sen. John Barrasso (Wy.) is running unopposed for Majority Whip.
 
House Democratic leadership elections will likely be the week of Nov. 18, with all Members seeking to maintain their leadership posts, led by House Minority Leader Hakeem Jeffries (NY). Senate Democratic Leadership elections will likely be in early December, based on past practice. The only open job is retiring Sen. Debbie Stabenow’s (MI) position as chair of the Policy and Communications Committee.
 
NABH government relations staff will introduce NABH and our priority issues to incoming freshman Members of the House and Senate as the 119^th prepares to convene.

2025 Physician Payment Rule Finalizes Slight Increase to Psychiatrist Payments; Provides Some Telehealth Support

In its recently released physician fee schedule 2025 final rule, the Centers for Medicare & Medicaid Services (CMS) increased payments to psychiatrists by 1.0%, contrary to an overall negative update of 2.93% for physician payments relative to 2024 rates. Congressional discussions are expected to determine how to offset this overall drop, perhaps by year’s end or in early 2025.

Telehealth
With regard to telehealth measures in the rule, CMS phased out current flexibilities implemented during the COVID-19 pandemic, as required by federal law. However, NABH is pleased CMS made permanent certain telehealth flexibilities, including allowing some practitioners to provide two-way, real-time, audio-only communications when the patient is not capable of or does not consent to using video technology. In addition, the rule implements three digital therapeutics codes for the first time (G0552, G0553 and G0554) that fall under existing FDA authority, which pertain to initial telehealth care plan education for patients, the first 20-minute of treatment, and subsequent 20-minute treatments. The agency also finalized additions to the Medicare Telehealth Services List, including caregiver training services, patient counseling, and safety planning
 
Telehealth provisions that only apply to 2025 include continuing to permit distant-site practitioners to use their enrolled practice locations rather than a home address when providing telehealth services from their home. Also, treatment frequency limits will remain suspended in 2025.
 
Because Congress has not finalized an extension of pandemic-originating telehealth services, the rule rolls back major Medicare telehealth services to pre-pandemic levels. NABH notes there is broad bipartisan support for extending these services, with separate bills passing both House and Senate earlier this year, which could potentially lead to enactment by year’s end, although an extension remains uncertain. Given the broad support of this extension, if Congress passes telehealth legislation before year’s end, the agency could issue an interim final rule to restore this coverage, which could take effect immediately. The longer Congress takes to act, the less time CMS has to prepare and issue such a rule.
 
Crisis Care and Opioid Use Disorder (OUD) Provisions
The rule introduces new billing codes and telehealth services to improve the quality and access of opioid use disorder treatment. The rule also finalized new coding and payment rules for safety-planning interventions for patients in crisis. 

Physician Supervision
The final rule allows supervising physicians to provide guidance virtually through real-time audio and visual telehealth. This new definition of physician supervision for “incident to” services will be submitted by the physician using CPT code 99211. The code also pertains to telehealth supervision for outpatient evaluation and management of established patients who may not require another health care professional in the appointment.
 
CMS will continue to permit telehealth supervision of all other services furnished that require the direct supervision of the physician or other supervising practitioner through telehealth through 2025, when both the treatment and supervision are furnished virtually through, for example, a three-way telehealth visit.

Please Visit Our New Website!

NABH’s website is live!  NABH has designed our updated site to help members, policymakers, journalists, patient advocates, and the general public learn about our association and the resources we provide in a way that is easier to navigate so you find what you’re looking for quickly and efficiently.
 
We have also updated our member password, which is required for member-only resources, such as our letters to congressional offices and regulatory agencies, as well as previous editions of CEO Update (all of which can be found by clicking on the “News” tab. NABH members should refer to the NABH Alert they received on Thursday, Oct. 31 for the new member password.
Please e-mail nabh@nabh.org with any questions or feedback you may have about the new site

Register Today for NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar on Thursday, Nov. 14, 2024 to learn about using hospital data effectively in your negotiations with health plans.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare, who will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Register here for this hourlong webinar that will begin at 1 p.m. on Nov. 14. 

National Study Highlights MA Plans with High Numbers of Veteran Enrollment and Utilization

A new study published in Health Affairs found that veterans increasingly enrolled in Medicare Advantage (MA) plans between 2016 and 2022, including a growing number of MA plans in which 20% or more of the enrollees were veterans. 
 
According to the findings, about one in five Veterans Health Administration (VHA) enrollees in these high-veteran MA plans did not incur any Medicare services paid by MA within a given year—a rate 2.5 times that of VHA enrollees in other MA plans and 5.7 times that of the general MA population. Meanwhile, VHA enrollees in high-veteran MA plans were significantly more likely to receive VHA-funded care.
 
The study reported that in 2020, CMS paid more than $1.32 billion to MA plans for VHA enrollees who did not use any Medicare services, with 19.1% going to high-veteran MA plans.

Manatt to Host Webinar About State Medicaid Innovations to Addressing America’s Behavioral Health Crisis

Research firm Manatt will host a webinar with state leaders to address topics such as 1115 demonstrations, strategies to combine Medicaid with other sources of funding, and what policies states are implementing to address the nation’s behavioral health crisis.
 
The hourlong webinar will start at 3 p.m. ET on Thursday, Nov. 21. Click here to register. 

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

In Appalachia, the seat of one of the earliest and deadliest waves of the opioid crisis, physicians at West Virginia University’s Rockefeller Neuroscience Institute are using focused ultrasound waves to reset the brain’s reward center, the nucleus accumbens. They hope the procedure can treat addictions ranging from drugs like opioids and methamphetamine to gambling and eating.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Deadline Extended: Please Submit Updated Member Information by Friday, Sept. 27!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

Last month NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use that link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

We have extended the deadline for members to submit changes to Friday, Sept. 27. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Mental Health Parity Final Rule Promises Meaningful Implementation of Groundbreaking Law

NABH is very pleased that the U.S. Health and Human Services (HHS), Labor (DOL) and Treasury Departments’ parity final rule released this week takes major steps toward meaningful implementation of true parity between behavioral and physical healthcare coverage.

Additional sub-regulatory guidance on how to execute the complex rule is pending, and the rule’s provisions will be implemented in a staged manner. Consequently, it will take some time before we can achieve actual parity nationwide and among countless health plans. Given this complexity, NABH, our members, and other partners will remain engaged with federal and state policymakers until the final rule provides meaningful parity protection.

The long-awaited rule lays the groundwork for more stringent compliance protocols and related definitions (noted below) to finally bring the Mental Health Parity and Addiction Equity Act to life 16 years after it was signed into law in October 2008. Responding to the 9,500 comments from stakeholders about the proposed parity rule released in July 2023, HHS, DOL and Treasury made some positive changes from their initial proposal in the final rule, which also reflects the concerns of health plans regarding the feasibility of some of the proposed rule’s recommendations.

In addition, many of the changes allow for closer alignment with existing federal statute, seemingly to acknowledge the risk of legal challenges to the final rule to align with the recent U.S. Supreme Court decision in Loper Bright Enterprises v. Raimondo, in which the High Court overturned the 40-year-old Chevron deference doctrine.

The rule affects group health plans and group or individual health insurance coverage that cover both behavioral and physical healthcare services. In general, the main focus of the rule is to require health plans to prepare comparative analyses that assess parity compliance of their non-quantitative treatment limitations (NQTLs), including specifying the mandatory components of these analyses, and a process for publicly sharing these reports. Examples of important NQTLs include:

• “Medical management standards (such as prior authorization) limiting or excluding benefits based on medical necessity or medical appropriateness, or based on whether the treatment is experimental or investigative,
• Formulary design for prescription drugs,
• For plans with multiple network tiers (such as preferred providers and participating providers), network tier design,
• Standards related to network composition, including but not limited to, standards for provider and facility admission to participate in a network or for continued network participation, including methods for determining reimbursement rates, credentialing standards, and procedures for ensuring the network includes an adequate number of each category of provider and facility to provide services under the plan or coverage, and
• Plan or issuer methods for determining out-of-network rates, such as allowed amounts; usual, customary, and reasonable charges; or application of other external benchmarks for out-of-network rates.”

A Data-driven Approach for Demonstrating NQTL Parity Compliance
The rule requires health plans to implement a data analysis plan to assess how each NQTL impacts access to mental health (MH)/substance use disorder (SUD) care, including whether each NQTL causes “material differences” in access. In the final rule, health plans will be allowed to consider “the terms of the NQTL at issue, the quality or limitations of the data, causal explanations and analyses, evidence as to the recurring or non-recurring nature of the results, and the magnitude of any disparities.” Using such analyses, NQTLs that are found to be parity non-compliant will not be implemented until they are compliant. The final rule also notes that NQTL oversight will be a collaborative process that includes working with health plans to find ways to address potential issues with compliance, rather than taking a strictly punitive approach.

Increased Compliance Transparency
Plans and issuers are required to provide all comparative analysis upon request to the three federal departments, states, and consumers experiencing treatment limitations. For self-insured employers, all beneficiaries are entitled to request the comparative analyses. These analyses must include:

• “a description of the NQTL,
• the identification and definition of the factors used to design or apply the NQTL,
• a description of how factors are used in the design or application of the NQTL,
• a demonstration of comparability and stringency, as written,
• a demonstration of comparability and stringency, in operation, and
• findings and conclusions.”

More Stringent NQTL Compliance Measures
NQTLs include prior authorization requirements and other medical management techniques, standards related to network composition, and methodologies to determine out-of-network reimbursement rates. The rule addresses these NQTL issues by:

• Reinforcing that health plans and issuers cannot use NQTLs that are more restrictive than those predominantly applied to physical health benefits in the same classification.
• Disallowing implementation of new NQTLs that do not meet parity standards.
• Specifying how insurers are to measure and report on their network composition, out-of-network reimbursement rates, and medical management and prior authorization NQTLs.
• Concerning the design of NQTLs, prohibiting discriminatory information, evidence, sources, or standards that systematically disfavor access to behavioral healthcare benefits as compared with physical health benefits.

Mitigating the Impact of Bias in NQTL Design
The final rule prohibits the use of “discriminatory factors and evidentiary standards” in designing a NQTL. Specifically, factors are considered discriminatory if, “based on all the relevant facts and circumstances, they systematically disfavor access or are specifically designed to disfavor access to mental health or substance use disorder benefits as compared to medical/surgical benefits.” For example, a seemingly neutral NQTL, but which is based on historical claims data not compliant with parity, would violate this provision of the final rule.

Generally Accepted Standards of Care (GASC)
Another important gain is the rule’s requirement that health plans explain any medical necessity standards that diverge from GASC. While the parity law does not require that medical necessity guidelines align with GASC, this new requirement will bring meaningful transparency and accountability to the process of creating these extremely effective guidelines.

Standardized “Substantially All,” “Treatment Limitations,” and Other Elements
When determining the treatment limits of a MH or SUD benefit, the parity test to compare the coverage with relevant physical health benefits should be applied to substantially all medical/surgical benefits in that classification. HHS, DOL, and Treasury included this approach in the final rule, rather than the proposed mathematical test for “substantially all” to implement a less cumbersome option.

The rule further defines “treatment limitations” as well as “processes, strategies, evidentiary standards, and other factors.” This provides greater clarity for compliance and eliminates potential loopholes. The rule also offers more specific examples of each, including specifying that the list of example non-quantitative treatment limitations (NQTLs) is meant to not be exhaustive. The final rule defines “treatment limitations” as: “Limits on benefits based on the frequency of treatment, number of visits, days of coverage, days in a waiting period, or other similar limits on the scope or duration of treatment. Treatment limitations include both quantitative treatment limitations, which are expressed numerically (such as 50 outpatient visits per year), and nonquantitative treatment limitations (such as standards related to network composition), which otherwise limit the scope or duration of benefits for treatment under a plan or coverage.”

Mandates Use of Standard Clinical Identifiers
In defining MH and SUD, the rule uses the International Classification of Diseases (ICD) and the Diagnostic and Statistical Manual of Mental Disorders (DSM), removing any non-clinical considerations from the definition. Importantly, this makes it clear that eating disorders and autism spectrum disorders fall within the definition of MH/SUD for parity compliance.

“Meaningful Benefits” Definition
To meet the mandatory “meaningful benefits” test, MH and SUD benefits will be compared with all benefits provided for physical health coverage in the same classification. This provision accommodates NABH’s request for a final definition that can mitigate future coverage disagreements among stakeholders, including plans, providers, auditors, and the courts. A meaningful benefit includes “a core treatment,” i.e., “a standard treatment or course of treatment, therapy, service, or intervention indicated by generally recognized independent standards of current medical practice.” This provides additional clarity about what is expected for coverage at every level of benefit under parity.

No “Network Adequacy” Guidance
The final rule does not include a special calculation for network adequacy, which the proposed rule suggested. In the discussion of the final rule, HHS, DOL and Treasury noted they responded to comments citing operational and legal concerns. The final rule also does not require a particular approach for analyzing data around network adequacy, such as reimbursement data.

Self-insured Employers
The final rule contains a number of considerations for self-insured employers in working with third-party administrators (TPAs) to help them achieve parity compliance with minimal additional burden. This includes considerations about how to engage TPAs in getting required data, as well as sharing compliance reporting obligations and liability for non-compliance. The federal departments also signaled interest in continuing to work with employers to ease the burden of compliance and improve coordination with TPAs.

Opt-out Option Removed
The rule amends the sunset provision to prevent opting out of compliance with MHPAEA, as required by law, after Dec. 29, 2022, with a June 27, 2023 deadline for certain plans that are subject to collective bargaining.

Effective Dates
The deadline to implement “the meaningful benefits standard, the prohibition on discriminatory factors and evidentiary standards, the relevant data evaluation requirements, and the related requirements in the provisions for comparative analyses” is Jan. 1, 2026.

For more details, please see the federal departments’ joint fact sheet and news release.

Senate Passes CBO Data Sharing Act

On Tuesday the Senate passed by unanimous consent bipartisan legislation that would allow the Congressional Budget Office (CBO) director to gain stronger authority to access sensitive healthcare data from federal agencies with fewer delays.

House Budget Committee Chairman Jodey Arrington (R-Texas) and ranking Democrat Brendan Boyle (Pa.) introduced the CBO Data Sharing Act (H.R.7032) in January. The legislation would give the CBO director the authority to request and receive information, including sensitive data, from federal agencies without lengthy negotiations or formal agreements, provided confidentiality is upheld. The bill also ensures that future laws cannot unintentionally restrict the CBO’s access to such data unless stated explicitly. The bill aims to prevent data-sharing roadblocks and ensure that Congress has more reliable information when considering changes to Medicare, Medicaid, and other public health policies.

The bill does not directly address the CBO’s interactions with federal health agencies; however, it is expected to have healthcare policy implications by helping the CBO overcome bureaucratic hurdles to secure essential health data and deliver faster, more accurate analyses of healthcare proposals.

As an example, the CBO released a 2023 report on proposals to modify or eliminate the Institutions for Mental Diseases (IMD) exclusion that limits Medicaid funding for inpatient care in psychiatric hospitals or other mental health facilities. To fully assess the potential impact of these proposals, the CBO requested detailed data from CMS on facilities meeting the IMD criteria. CMS denied the request, citing legal restrictions under the Public Health Service Act of 2000. Consequently, the CBO had to rely on less detailed public information, which limited the accuracy of its analysis. Had this bill been in place, the CBO could have bypassed that bureaucratic hurdle and provided Congress with more reliable data, according to the House Budget Committee’s bipartisan fact sheet about the legislation.

The House passed H.R. 7032 in April. The legislation now heads to the White House, where it is expected that President Biden will sign the bill into law.

ICYMI: Watch NABH’s World Suicide Prevention Day Webinar

NABH thanks all who joined us on Sept. 10 for our webinar that highlighted the 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH welcomed Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and
Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

If you missed it, please click here for the webinar’s recording; here for the presentation slides; and on the links below for some useful resources:

• The National Strategy for Suicide Prevention
• Recommended Standard Care for People with Suicide Risk
• Zero Suicide Toolkit
• Zero Suicide Institute
• 988 Lifeline

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Mental health jobs are expected to grow three times the rate of all U.S. jobs in the next decade, according to a recent analysis of data from the U.S. Labor Department’s Bureau of Labor Statistics.

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

Reminder: Please Submit Updated Member Information by Next Friday, Sept. 13!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

Last month NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is next Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Former CDC Directors Caution that Paring Down Agency Could Cost Lives and Damage Economy

Eight former Centers for Disease Control and Prevention (CDC) directors penned an op-ed this week in STAT that warns cutting funding to the Atlanta-based public health agency could endanger lives and the U.S. economy.

“One misguided narrative is that the CDC should focus only on a ‘core mission’ of combatting infectious diseases,” wrote former directors William Foege, William Roper, Jeffrey Koplan, Julie Gerberding, Tom Frieden, Brenda Fitzgerald, Robert Redfield, and Rochelle Walensky, all of whom are physicians. “In fact, the core mission of the CDC is to save lives and protect Americans from all health threats — not only infectious diseases but also cancer, environmental risks, injuries, and the conditions that are the leading causes of death among Americans.”

They added that the CDC has helped save millions of lives through reduced tobacco and alcohol use, diabetes prevention and control, injury prevention including reducing traumatic brain injury, healthier pregnancies with lower maternal mortality, and other health-protection programs.

“Limiting our health defense to just some threats would be like allowing our military to protect us from only some types of attack, telling the National Weather Service to warn people about tornadoes but not hurricanes, or allowing doctors to treat only some diseases,” they continued.

The piece is a response to a Republican bill that would cut funding to the CDC by 22% and also to an op-ed earlier this year from Scott Gottlieb, M.D., former director of the U.S. Food and Drug Administration who now serves on the board of Pfizer.

September Issue of JAMA Pediatrics Includes Several Mental Health-Related Articles

NABH calls members’ attention the September edition of JAMA Pediatrics, which includes a number of articles focused on mental health.

Topics include healthcare needs and costs for children exposed to prenatal substance use, hospital admissions for eating disorders, mental health of transgender youth following gender identity milestones, and more.

September is National Recovery Month and Suicide Prevention Month

September is National Recovery Month, and the Substance Abuse and Mental Health Services Administration (SAMHSA) will commemorate the annual observance with a campaign focused on the four dimensions of recovery: health, home, purpose, and community.

Week One will emphasize health and will highlight choices that support well-being – such as eating a nutritious diet, exercising regularly, developing healthy sleeping habits, and managing other health issues –that can help support people with mental health and substance use conditions in their journey to recovery. Click here to access SAMHSA’s Recovery Month social media toolkit.

September is also Suicide Prevention Month, and SAMHSA has created a separate toolkit with hashtags and posts for the month and also World Suicide Prevention Day on Sept. 10 to remember the lives of those lost to suicide.

Reminder: Join NABH for World Suicide Prevention Day Webinar on Sept. 10

Please join NABH this coming Tuesday, Sept. 10, World Suicide Prevention Day, for a webinar that will feature two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH will welcome Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please click here to register for this hourlong webinar on Tuesday at 2 p.m. ET.

Join NABH for October Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar to learn about using hospital data to improve negotiations with health plans on Wednesday, Oct. 16, 2024.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. A member of NABH’s Managed Care Committee, Fox will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Fox has more than 25 years of senior leadership experience in the behavioral health sector. Prior to her current role, she served as the business development director at Peachford Hospital, a Universal Health Services facility. Fox earned her undergraduate degree from Michigan State University, where she received a dual degree in Communications and Spanish. She later earned a master’s degree in healthcare administration from Loyola University Chicago.

Please register here for this hourlong webinar on Wednesday, Oct. 16 starting at 2 p.m. ET. We hope you join us!

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

An analysis of provisional data from the National Institute on Drug Abuse found that between 2015 and 2023, there was a nearly five-fold increase in overdose deaths among non-Hispanic Black men 55 and older.

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

Reminder: Please Update Your Member Information for the 2024 NABH Membership Directory!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

NABH has e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Legislative Preview: What to Expect from Congress This Fall 

Following their annual August recess and respective party conventions, federal lawmakers will return to Capitol Hill on Monday, Sept 9 to determine next steps for funding the federal government and provide stop-gap funding for veterans’ benefits.

The House and Senate will continue to attempt to pass appropriations bills funding various federal agencies before the Sept. 30 deadline. Both chambers have passed respective appropriations bills for Labor and HHS with vastly different funding levels, which likely won’t be reconciled before the deadline.

Numerous other agency funding bills are still pending. Congressional leaders are already having conversations about passing a Continuing Resolution (CR) to fund the government, which Congress will need to approve by Sept. 30 to stave off a government shutdown. The length of the CR will likely extend past the election or potentially after the 119 Congress takes office in January.

In addition, Congress will likely consider a $3 billion emergency aid bill that would cover veterans benefits and services as the Veterans Affairs Department (VA) warns of a nearly $14.9 billion shortfall through fiscal year 2025. A bipartisan group of appropriators and other senators intend to introduce legislation that would provide almost $2.3 billion in additional fiscal 2024 funding for the VA to cover compensation and pensions in the near term, along with almost $597 million for readjustment benefits. Without action from Congress by Sept. 20, the VA has warned it won’t be able to pay out roughly $3 billion in disability compensation, pension, and education benefits as early as Oct. 1. Because this is considered “must pass” legislation, Congress could attempt to add additional bills to this action.

Congress is expected to adjourn Sept. 27 after completing these tasks and return after the Nov. 5 elections. At that time, Congress will return to address unfinished business before the end of the year, commonly known as the “lame duck session.” Typically, most work during this session depends on which political party won majorities in the House and Senate during the November elections and whether there is a pending change in majority in either legislative chamber.

The outcome of the U.S. presidential race can also play a role in the level of activity during a lame duck session. Some congressional members might continue to push for an end-of-year health package, which could include reauthorizing the SUPPORT Act and a telehealth extension, among other priorities.

September is National Recovery Month and Suicide Prevention Month 

Next month marks National Recovery Month, and the Substance Abuse and Mental Health Services Administration (SAMHSA) will commemorate the annual observance with a campaign focused on the four dimensions of recovery: health, home, purpose, and community.

Week One will emphasize health and will highlight choices that support well-being – such as eating a nutritious diet, exercising regularly, developing healthy sleeping habits, and managing other health issues –that can help support people with mental health and substance use conditions in their journey to recovery. Click here to access SAMHSA’s Recovery Month social media toolkit.

September is also Suicide Prevention Month, and SAMHSA has created a separate toolkit with hashtags and posts for the month and also World Suicide Prevention Day on Sept. 10 to remember the lives of those lost to suicide.

Reminder: Join NABH for World Suicide Prevention Day Webinar on Sept. 10

Please join NABH on World Suicide Prevention Day, for a webinar that will feature two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH will welcome Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please click here to register for this hourlong webinar on Tuesday, Sept. 10 at 2 p.m. ET.

HHS and DOJ to Host Webinar on Incarcerated Youth and Medicaid Next Week

HHS and the U.S. Justice Department (DOJ) will host a webinar next Tuesday, Aug. 27 that will highlight policy approaches designed to connect justice-involved youth with Medicaid and CHIP services.

In late July, the Centers for Medicare & Medicaid Services (CMS) sent a letter to state health officials that addressed the statutory requirements in the Consolidated Appropriations Act, 2023 regarding the availability of certain state plan services for incarcerated youth in Medicaid and the Children’s Health Insurance Program (CHIP) and modification of CHIP eligibility requirements for children who become incarcerated in juvenile or adult corrections systems.

During this webinar, HHS and DOJ leadership and subject matter experts will discuss how this opportunity will help advance health equity and build healthier and safer communities.
Click here to register for the webinar that will start at 2 p.m. ET.

SAMHSA Offers On-Demand Module on Motivational Interviewing Strategies for AUD

SAMHSA is offering an on-demand module to help physicians, physician associates, nurses, social workers, and other healthcare professionals learn how to use Motivational Interviewing strategies as a guided approach to clinical interactions and fostering behavior change in patients with alcohol use disorder.

SAMHSA’s PCSS-MAUD Motivational Interviewing for Alcohol Use Disorder Treatment is a self-paced training program that addresses the Accreditation Council for Graduate Medical Education competencies of patient care, medical-based knowledge, and practice-based learning.

National Academies Examines Strategies to Improve Behavioral Healthcare Access in Medicare and Medicaid

The National Academies has released Expanding Behavioral Healthcare Workforce Participation Through Medicare, Medicaid, and Marketplace Plans, a new resource it developed after SAMHSA and CMS asked the not-for-profit institutions t convene a committee that would examine current challenges in ensuring broad access to evidence-based behavioral healthcare services through Medicare, Medicaid, and Marketplace programs—and propose strategies to address those challenges.

“Barriers to obtaining behavioral health treatment are most evident in populations receiving Medicare, Medicaid, and Marketplace plans,” the National Academies wrote in its description of the new resource. “Behavioral healthcare providers serving individuals enrolled in these plans are more likely to experience challenges around reimbursement and training, which disincentivizes participation.”

Join NABH for October Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar to learn about using hospital data effectively in your negotiations with health plans on Wednesday, Oct. 16, 2024.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. A member of NABH’s Managed Care Committee, Fox will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Fox has more than 25 years of senior leadership experience in the behavioral health sector. Prior to her current role, she served as the business development director at Peachford Hospital, a Universal Health Services facility. Fox earned her undergraduate degree from Michigan State University, where she received a dual degree in Communications and Spanish. She later earned a master’s degree in healthcare administration from Loyola University Chicago.

Please register here for this hourlong webinar on Wednesday, Oct. 16 starting at 2 p.m. ET. We hope you join us!

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

The National Institutes of Health announced it has launched a program to advance research that will support Native American communities to lead research to address overdose, substance use, and pain, including factors such as mental health and wellness.

NABH will not publish CEO Update next Friday, Aug. 30. The NABH staff wishes you, your teams, and your families a safe and happy Labor Day weekend next week! CEO Update will resume on Friday, Sept. 6.

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

Please Update Your Member Information for the 2024 NABH Membership Directory!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

This week NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

HRSA Social Worker Licensure Compact Seeks to Increase Behavioral Healthcare Access and Enhance Telehealth Services

The Health Resources and Services Administration (HRSA) announced recently its first Licensure Portability Grant Program investment in a multi-state social worker licensure compact.

According to HRSA, state licensure compacts allow states to agree on a common approach to licensing health care providers, allowing providers to practice across state lines without having to apply for a license in each state. Streamlining licensure while maintaining quality standards improves access to services both by better facilitating hiring and by easing pathways to utilizing telehealth. HRSA made the announcement at its National Telehealth Conference last month.

“Social workers are essential to expanding access to behavioral health care services, a top priority of the Biden-Harris administration,” HHS Deputy Secretary Andrea Palm said in a statement. “HRSA is leading the way in growing the behavioral health workforce both by training more providers and by breaking down barriers to allow the workforce to make mental health and substance use disorder services more accessible across the country,” she added.

Click here to see the grant program awardees.

Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

 Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

According to a Pew Charitable Trusts fact sheet released this week, more than 10.2 million people ages 12 and older misused stimulants – which includes cocaine, prescription stimulants for ADHD and methamphetamine – in 2022. This reflects a nearly 9% increase from 2021.

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

Contingency Management Battles Ongoing Headwinds

Earlier this week, a STAT news article reviewed the executive branch’s response to advocacy efforts to expand financing for the only evidence-based treatment for stimulant use disorder, contingency management (CM.)  CM provides financial rewards for abstinence from stimulants and has decades of research demonstrating that intervention changes the reward centers of the brain, resulting in behavior change. There are no medications for stimulant use disorders.

Currently, the Substance Abuse and Mental Health Services Administration limits CM rewards to $75, which is too low for effective treatment. In addition, members of Congress have confused CM treatment with harm reduction and made the treatment a highly charged political issue. Speaking on behalf of NABH, Sarah Wattenberg, director of quality and addiction services, stated, “I understand their political concerns, but sometimes you just have to bite the bullet.” She continued, “Too many people are dying, and we need to act now.”

Reminder: Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar this month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

A recent JAMA study found that between Jan. 2010 and Dec. 2021, 60% of youth who lost their lives to suicide lacked mental health diagnoses. This study’s findings highlight the importance of “…equitable access to MH screening, diagnosis, and treatment for all youths. “

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

CMS Finalizes 2.5% IPF Payment Increase and Payment System Reforms

The Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2025 final rule on the inpatient psychiatric facility prospective payment system (IPF PPS) implements a net increase of 2.5 percentage points. The overall update of $65 million, compared with FY 2024 payment levels, represents a slight decrease from the proposed 2.6 percentage point increase.

This update includes a market basket increase of 3.3 percentage points that is offset by a 0.5 percentage point for productivity. In addition, to maintain the mandated outlier pool of 2.0% of total payments, CMS finalized an outlier payment reduction of 0.3 percentage point to stay within this target, which reduces the number of cases that will qualify for an outlier payment.

CMS also finalized several adjustments to ensure that the PPS design and other changes discussed below are implemented in a budget-neutral manner. Due to these adjustments, the base per diem rate will be reduced to $876.53 from $895.63.

All-Inclusive Reporting
NABH is extremely disappointed that CMS finalized a significant narrowing of its all-inclusive reporting policy, which will take effect for upcoming cost reporting periods. Current policy allows IPFs to use an alternative methodology for reporting ancillary charges on cost reports. The final rule restricts this reporting option for ancillary charges only to Indian Health Service (IHS) hospitals, tribally owned and government-owned psychiatric, and acute care hospitals. CMS overlooked NABH’s strong caution that for many “all-inclusive IPFs,” significant administrative, timing and cost considerations will make impossible a timely transition to this change.

Under the finalized timing framework, CMS contractors will begin assessing compliance with the change through a look-back process that begins following the completion of a provider’s upcoming cost-reporting period that begins on or after Oct. 1, 2024. Specifically, all IPFs will be required to have a charge structure that allows the reporting of ancillary costs and charges on their cost reports for all ancillary services and correlating charges, such as labs and drugs.

With this change, IPFs that are currently in the all-inclusive category now will have their cost reports included in the annual IPF PPS update that CMS calculates. Because CMS calculates the annual update using the sum of routine and ancillary costs, in prior years the agency has removed from the calculation the all-inclusive IPFs, as their cost reports lack data on ancillary services. The final rule notes that in 2018, because of this exclusion, 82,491 (out of 364,080 total stays) were removed from the update calculation. CMS acknowledges that this exclusion has been producing skewed updates that do not represent the costs of the entire IPF field, with approximately 55 percent of stays from freestanding all-inclusive facilities removed in 2018, and 0.3 percent of stays from all-inclusive psychiatric units.

In response to feedback that all-inclusive IPFs are providing full and clinically-appropriate services and that the absence of ancillary charges on cost reports is due to gained cost efficiencies, CMS said it “believe[s that] IPFs are providing these necessary services to patients.” The agency added:  “…maintaining an accurate charge structure would be part of a business’s accounting for reordering and restocking pharmaceuticals at a minimum, as well as more accurate payment for the purposes of outlier payments.”

Payment Increase for Electroconvulsive Therapy
For FY 2025, to achieve some alignment with outpatient rates, CMS finalized the proposed 71 percent increase for ECT payment per treatment from the current rate of $385.58 to $661.52.

IPF PPS Modifications
As mandated by Congress, CMS reviewed key IPF PPS elements with a focus on facility and patient-level adjustments, and in this rule finalizes multiple, relatively modest changes. While the agency is maintaining the rural and teaching facility adjustments, as is, the rule finalizes multiple budget-neutral changes to the structure of the PPS. As shown in Tables 4 and 5 in the rule, CMS finalized these changes:

• Added DRGs 917 (Poisoning and toxic effects of drugs w MCC) and 918 (Poisoning and toxic effects of drugs w/out MCC).
• Replaced DRGs 080 (Nontraumatic stupor & coma w MCC) and 081 (Nontraumatic stupor & coma w/o MCC) with DRGs 947 (Signs and Symptoms w MCC) and 948 (Signs and Symptoms w/out MCC.
• Removed 2 DRGs: DRG 887 (Other mental disorder diagnoses) and DRG 896 (Alcohol, Drug Abuse or Dependence w/out rehab therapy w MCC).
• Multiple changes to comorbidity payment add-ons were finalized as shown in Table 10.

IPF Quality Reporting Program
As proposed, the final rule implements one new measure: the 30-Day Risk-Standardized All-Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge. In response to concerns raised through public comments that its implementation may not be feasible, CMS did not finalize the proposed requirement for IPFs to submit patient-level quality data every quarter (versus the current annual basis).

Please see CMS’ fact sheet for more information about the rule.

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Senate Passes Kids Online Safety and Privacy Act

The Senate on July 30 voted 91-3 to pass the Kids Online Safety and Privacy Act (KOPSA), a combination of the Kids Online Safety Act and the Children and Teens’ Online Privacy Protection Act. The bill would for the first time make social companies such as Facebook and TikTok responsible for the ill effects of design features that recommend content and encourage engagement.

KOPSA prescribes that technology companies must limit the amount of data they collect on children under 17; not target minors with advertising; give children the highest privacy settings by default; offer the ability to opt out of various design features like content recommendations and engagement nudges; and have an independent third party audit their platforms for potential harm to children; among other provisions.

Recent developments have increased pressure on Congress to pass a bill protecting online safety and privacy. Several states have passed social media and privacy laws aimed at mitigating youth harms. And in June, U.S. Surgeon General Vivek Murthy called for social media platforms to come with warning labels.

Technology companies and free speech advocates staunchly oppose the bill, which is expected to face certain legal challenges if it becomes law. Grassroots organizations alarmed by child suicide have pushed for the federal legislation, and have helped to enact laws in California, Colorado, Connecticut, Maryland, and New York meant to regulate social media for minors.

House companion bills are awaiting committee action, with House Energy and Commerce Chair Cathy McMorris Rodgers (R-Wash.) planning a vote this Fall. House Leadership has also signaled interest in the measures and there is bipartisan support for them.

Passing this legislation would be the first major regulation in years to alter how large technology companies interact with children on their platforms.

SAMHSA Releases 2023 National Survey on Drug Use and Health

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released key findings from the 2023 National Survey on Drug Use and Health (NSDUH).

Conducted by the federal government since 1971, the NSDUH is a primary source of statistical information on self-reported substance use and mental health of the U.S. civilian, noninstitutionalized population 12 or older. Estimates are presented by age group and by race/ethnicity for selected measures.

ASAM Past President Stuart Gitlow Pens Op-Ed on Cannabis Re-Scheduling

Stuart Gitlow, M.D., M.P.H., M.B.A., DFAPA, DFASAM, past president of the American Society of Addiction Medicine, penned an Op-Ed in ASAM Weekly in response to a proposal by the U.S. Justice Department to reschedule marijuana from Schedule I to Schedule III.

Currently, marijuana is illegal at the federal level, while many states have implemented decriminalization and legalization initiatives. This creates a difficult position for physicians (among others, such as dispensaries) who might recommend or fill out state-required forms for medical marijuana.

In his opinion piece, Gitlow argued that this would not change under rescheduling. Additionally, rescheduling would not decriminalize or legalize marijuana use. He also wrote there has not been sufficient research confirming any “true medical utility” of marijuana, whereas there is an understanding that the plant has addictive potential and impacts public health negatively.

Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

ICYMI: CMS Shares Discusses EMTALA and Behavioral Health in ACEP Podcast

CMS participated in the American College of Emergency Physicians’ ACEP Frontline podcast to discuss the Emergency Medical Treatment & Labor Act (EMTALA) and behavioral health.

The podcast describes how behavioral health conditions and physical health conditions are considered similarly from the standpoint of EMTALA.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

NBC News reported recently that athletes prioritized their mental health ahead of the Summer 2024 Olympic Games that opened in Paris a week ago.

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

House Passes Bill to Reauthorize Child Welfare Programs Included RTF Provision

The House Ways and Means Committee on Thursday passed unanimously H.R. 9076, the Bipartisan Protecting America’s Children by Strengthening Families Act, to reauthorize and reform the nation’s child welfare programs under Title IV-B of the Social Security Act. Authorization for these programs expired in fiscal year 2021, and there have been no serious reforms since 2008.

Introduced by Reps. Darin LaHood (R-Ill.) and Danny Davis (D-Ill.), H.R. 9076 focuses mainly on America’s child foster care system and also includes a provision titled Improving Data Collection and Reporting for Youth in Residential Treatment Programs.

The language directs HHS and other agencies to update guidance to state agencies in administering state plans approved under parts B and E of title IV of the Social Security Act on a) best practices for federal and state agencies to collect data and share information related to the well-being of youth residing in residential treatment facilities, including those facilities operating in multiple states or serving out-of-state youth; b) best practices on improving state collection and sharing of data related to incidences of maltreatment of youth residing in residential treatment facilities, including with respect to meeting the requirement of section 471(a)(9)(A) of such Act for such youth in foster care; and c) best practices on improving oversight of youth residential programs receiving federal funding and research-based strategies for risk assessment related to the health, safety, and well-being of youth in the facilities.

The House Ways and Means Committee’s passage of this legislation follows the influential panel’s hearing last month about child welfare programs, which included testimony from Paris Hilton, who supported H.R. 2955, The Stop Institutional Child Abuse Act, aspects of which were incorporated into the data collection and reporting Section of H.R. 9076.

The next step would be for H.R. 9076 to move to the House floor for a vote; however, it’s unclear whether the House will consider the legislation. It’ also unknown if the Senate will consider the bill or consider similar legislation.

NABH will continue to monitor any congressional action related to H.R. 9076

HHS Streamlines Technology, Cybersecurity, and AI Functions Under ONC

HHS on Thursday announced a reorganization to streamline and strengthen its technology, cybersecurity, data, and AI strategy and policy functions.

Under the restructured format, the Office of the National Coordinator for Health Information Technology, or ONC, will be renamed the Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology, or ASTP/ONC. All oversight of technology, data, and AI policy and strategy will move from its current structure under the Assistant Secretary for Administration to ASTP/ONC, including the HHS-wide roles of chief technology officer, chief data officer, and chief AI officer.

In addition, the public-private effort between the health sector and the federal government on cybersecurity (“405(d) Program”) will move from ASA to the Assistant Secretary for Strategic Preparedness and Response, or ASPR, joining the other health sector cybersecurity activities already located in ASPR’s Office of Critical Infrastructure Protection.

Biden Administration Awards $45.1 Million to Expand Mental Health and Substance Use Services

The Biden administration this week announced grant awards totaling $45.1 million – including $15.3 million specifically for children and youth– to expand mental health and substance use services.

The youth funding will go toward supporting their mental health in school settings; serving children and families who have experienced traumatic events and grief; and providing services specific to young people of transitional ages who are at risk for or have serious mental health conditions.

“Be it fostering wellness in young people, caring for the unhoused, facilitating treatment and more, this funding directly supports the needs of our neighbors,” HHS Secretary Xavier Becerra said in an announcement about the funding. “These investments will empower communities to implement effective solutions that promote long-term healing and resilience.”

Click here to read about the various grant awards and access links to apply.

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services’ (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

A new poll from the National Alliance on Mental Illness found 82% of Americans are still not familiar with 988, the lifeline that helps people in mental health, substance use, and suicide crises get connected to support services.

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

FDA & FTC Issue Warnings to Crack Down on Illegal Sales of Food Products with Delta-8 THC

The Food and Drug Administration (FDA) and the Federal Trade Commission this week issued warnings to five companies to crack down on illegal sales of food products containing delta-8 THC.

The products’ packaging resemble familiar snacks and candies, potentially leading to accidental ingestion or overconsumption. The agencies are especially concerned about the appeal to children and potential impurities or unpredictable effects from processes used to synthesize delta-8 THC, the psychoactive cannabinoid from the Cannabis sativa plant.

The companies have 15 working days to submit written responses detailing how they will address these violations and prevent future ones. If the violations are not addressed promptly, the agency may take legal action.

From Jan. 1, 2021, to Dec. 31, 2023, the FDA received more than 300 adverse event reports involving children and adults who consumed delta-8 THC products. In response, the agency issued a warning to customers in June 2022. Meanwhile, between Jan. 1, 2021, and May 31, 2022, national poison control centers handled 10,448 single substance exposure cases involving edible products containing THC, 77% of them for people 19 or younger. 

Adverse effects can include hallucinations, vomiting, tremor, anxiety, dizziness, confusion and loss of consciousness, the agency said.

Joint Commission’s Revised Guidelines for Restraint and Seclusion to Begin Next Year

The Joint Commission has announced new and revised requirements will apply to behavioral healthcare and human services organizations that use restraint and/or seclusion starting on Jan 1, 2025.

The changes include revising the definition of restraint; reducing redundancies; streamlining processes; and removing requirements for physical holding of a child or youth and incorporating this concept into the requirements for restraint and seclusion because physical holding that restricts freedom of movement is a type of restraint.

Click here to learn more.

DEA Rule on Telehealth Slated for September

The Drug Enforcement Administration is expected to issue its highly anticipated telehealth prescribing rule in September, according to an article in Inside Telehealth, an Inside Health Policy publication.

“A last-minute title change of the proposed rule may indicate that the registration could allow for prescribing controlled substances across state lines, sources say,” the article noted.

The article also said the rule’s title was updated to “Special Registrations for Telemedicine and Limited State Telemedicine Registration,” according to DEA’s spring regulatory agenda published July 5.

NIH Study: Doctors Reluctant to Treat Addiction Report Lack of Support as Barrier

A new National Institutes of Health study found “instiutional environment” as the most frequently reported reason why physicians are reluctant to intervene in addiction treatment.

“Institutional environment” refers to factors such as lack of support from a physician’s institution or employer; insufficient resources, such as staff and training; challenges in organizational culture; and competing demands. This reason for reluctance was cited in 81% of the studies reviewed, followed by insufficient skill (74%), lack of cognitive capacity to manage a certain level of care (74%), and inadequate knowledge (72%).

Meanwhile, about 66% of studies cited negative social influences – or beliefs about public and community acceptance of addiction care – while 56% of studies cited fear of harming the patient-physician relationship as deterrents for physicians to intervene in addiction.

The study’s findings highlighted the need for institution-wide changes to improve the adoption of evidence-based substance use disorder treatment practices among physicians, such as increasing organizational support, leadership and staff buy-in, and education and training.

Kaiser Family Foundation to Host ‘Beyond Chevron: How the SCOTUS Decision will Affect Healthcare Policy Decisionmaking’ Webinar Next Week

The Kaiser Family Foundation (KFF) will host a webinar next week to discuss the potential challenges stemming from the U.S. Supreme Court’s decision on June 28 to overturn the Chevron precedent that required federal courts to defer to reasonable agency decisions when federal law is unclear.

Moderated by  KFF Executive Vice President for Health Policy Larry Levitt, the discussion will address questions such as: How will the decision change how regulators approach drafting new regulations? What type of health policy regulations are likely to be most vulnerable to future court challenges? How will it alter the legislative process and the ability to pass new laws? And to what extent will Congress be able to provide greater specificity in delegating authority to federal agencies in future legislation?

The 45-minute webinar will be held on Thursday, July 25 at Noon ET. Click here to register.

Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Early population estimates from the Centers for Disease Control and Prevention (CDC) show that around 7% of the entire U.S. adult population reported having Long COVID in 2022. “Some of the most common mental health conditions associated with Long COVID include fatigue, sleep disturbances, depression, anxiety, psychosis, cognitive impairment, obsessive-compulsive disorder, and posttraumatic stress disorder,” the Substance Abuse and Mental Health Services Administration (SAMHSA) reported recently. “Both COVID-19 and Long COVID can result in new onset of behavioral health conditions in those who have not previously reported these conditions, and aggravate complications for those with pre-existing mental health conditions and substance use disorders.”

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

FDA Releases Guidance on Constructing Effective Clinical Trials for Devices

The FDA on Thursday issued guidance about constructing effective clinical trials to develop medical devices that treat patients who misuse opioids.

The new guidance is intended to improve both the design and development of clinical studies to provide a reasonable assurance of safety and effectiveness for a device intended to treat OUD. Challenges in developing OUD device studies include inaccurate patients report of drug use, high rates of missing data, and confounding effects of concomitant drug treatments.

The guidance is not legally enforceable.

CMS Updates IOP and PHP Payment Rates for 2025

The Centers for Medicare & Medicaid Services (CMS) this week issued its calendar year (CY) 2025 Medicare hospital outpatient prospective payment system (OPPS) proposed rule, which proposes a net increase of 2.3 percentage points, relative to current year rates. The net update reflects a market basket increase of 3.0 percentage points and the statutorily required 0.4 percentage point cut, along with several budget neutrality adjustments and a minor increase in outlier payments.

The proposed update would apply to services paid under the OPPS, intensive outpatient programs (IOP), partial hospitalization programs (PHP), community mental health centers (CMHCs), opioid use disorder (OUD) treatments in an IOP, and other settings.

In addition to other items, the proposed rule addresses the behavioral healthcare provisions summarized below and lists in Table 68 the eight proposed ambulatory payment classification (APC) per diems for IOPs and PHPs that are set according to the number of services provided per day.

IOPs
For the IOP benefit established last year, the current dual-rate, per-diem structure would be maintained: one rate for days with three services and another rate for days with four or more services. In general, the structure of the IOP mirrors the design of the PHP, including provisions on coding, billing, and payment policies.

The rule defines IOPs as distinct and organized outpatient programs of psychiatric services provided for individuals who have an acute mental illness or substance use disorder, consisting of a specified group of behavioral health services paid on a per-diem basis for a minimum of nine hours of IOP services per week, or other payment system.

Opioid Treatment Program (OTP) Payment Add-On
For the new OPPS coverage of OUD treatments that OTPs provide, CMS would maintain the payment add-on of three times the payment rate for APC 5861 (intensive outpatient of three services per day) for hospital-based IOPs.

FQHCs and RHCs
The annual payment update for IOP services provided by federally qualified health centers and rural health clinics will be addressed in the pending physician fee schedule proposed rule for CY 2025.

PHPs
For PHPs, services provided in hospital outpatient departments and CMHCs, CMS proposes to maintain the current payment structure, which sets reimbursements based on whether a patient receives three services versus four or more services per day. PHPs are intensive, structured outpatient programs that are alternatives to psychiatric hospitalization, consisting of a specified group of mental health services paid on a per-diem basis for a minimum of 20 hours of PHP services per week, based on per diem costs.

Access to Non-Opioid Treatments for Pain Relief
As mandated by Congress, CMS is proposing temporary add-on payments for certain non-opioid treatments for pain relief. This complex provision would take effect from Jan. 1, 2025 through Dec. 31, 2027, and would require certain clinical evidence for medical devices and FDA-approved indications for pain management. The payment add-on would be capped at the estimated average of 18% of the full OPPS payment, calculated using the top five procedures by volume for each drug or device. Table 84 in the rule lists the proposed seven injections and other items that would qualify for a payment add-on under this provision.

CMS will accept comments on this rule through Sept 9. See the agency’s related fact sheet for more information.

CMS’ Proposed 2025 PFS Rule Would Cut Overall Payments by 2.8%

In its proposed rule  for the calendar year (CY) 2025 physician fee schedule, the Centers for Medicare & Medicaid Services on Wednesday recommended reducing the conversion factor by 2.8% to $32.36 in CY 2025, compared with $33.29 in CY 2024. This change reflects the expired 2.93% statutory payment increase for CY 2024; a 0.00% conversion factor update under the Medicare Access and Children’s Health Insurance Program Reauthorization Act; and a .05% budget-neutrality adjustment.

Proposed New Behavioral Healthcare Services
The lengthy rule includes these proposals to improve payment for and access to behavioral healthcare services:

• For people determined to have elevated suicide or overdose risk, a new payment for safety planning interventions and post-discharge follow-up contacts;
• New digital tools payment for:
  • Post-discharge telephonic follow-up;
  • Software devices that treat a mental health condition in conjunction with ongoing treatment; and
• Extending evaluation and management services payment to allow clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors to conduct interprofessional consultations among themselves, as well with psychiatrists and other physicians.

Proposed Payment Updates by Specialty
Table 128 in the proposed rule lists these and other proposed updates by specialty:

• +3.0% for clinical psychologists;
• +1.0% for psychiatrists;
• +4.0% for clinical social workers;
• +1.0% for family practice physicians;
• +1.0% for internal medicine physicians; and
• No change for nurse practitioners.

Opioid Treatment Programs (OTPs)

Telehealth Extended for Methadone Treatment
Regarding methadone treatments, CMS proposes extending current telehealth flexibilities permanently for periodic assessments and initiation of treatment. For beneficiaries lacking permanent access to two-way audio-video communications technology, CMS would allow periodic assessments to be furnished via audio-only communications when applicable requirements are met. To support this proposal, CMS cites evidence that audio-only visits produce many of the same benefits as video-based visits. The rule also notes that this provision would advance the agency’s health equity goals.

For initiation of treatment with methadone for any new patient, audio-visual telehealth may be used if an OTP can conduct an adequate evaluation of the patient. Audio-only telehealth is not permitted. Such telehealth evaluations would use OTP intake add-on code (HCPCS code G2076) and must comply with the Drug Enforcement Administration, the Substance Abuse and Mental Health Services Administration (SAMHSA), and other requirements. These OTP provisions also are intended to align with SAMHSA’s goals for reducing barriers to access.

Payment for Patient Intakes
The rule proposes payment updates for intake activities (HCPCS code G2076) by OTPs, which align with recent SAMHSA reforms to advance patient-centered and evidence-based paradigms of care for Opioid Use Disorder (OUD) treatments such as harm-reduction interventions and recovery support services. Specifically, the rule would implement payment for social determinants of health risk assessments (HCPCS code G0136) to identify unmet health-related social needs or the need for OUD-related harm-reduction interventions and recovery support services. In addition, CMS seeks feedback on how OTPs currently coordinate care and make referrals to community-based organizations that address unmet Health Related Social Needs (HRSNs), provide harm-reduction services, and/or offer recovery support services.

Opioid Agonist and Antagonist Medications
CMS proposes to establish payment for new opioid agonist and antagonist medications that the U.S. Food and Drug Administration approved recently. Specifically, the rule would create a new add-on code to the bundled payment to reflect take-home supplies for nalmefene hydrochloride (nalmefene) nasal spray (Opvee®). The agency also proposes paying for a new extended-release injectable buprenorphine product (Brixadi®), indicated to treat moderate to severe OUD using a new weekly bundled payment code to reflect the weekly formulation of Brixadi®. In addition, the rule would update payment for the existing bundled payment for monthly injectable buprenorphine (HCPCS G2069) in order to reflect payment for the monthly formulation of Brixadi®. CMS’ goals for these changes are to help prevent additional opioid overdose deaths, reduce illicit opioid use, and retain more individuals with an OUD in treatment.

Billing Clarification
The rule also clarifies that for billing, an OUD diagnosis code is required on claims submitted under the Medicare OTP benefit, which helps ensure that payments for Part B OTP services are for the treatment of OUD.

Additional Telehealth Proposals
Permanent Expansion of Audio-only Telehealth
CMS proposes to permanently expand the allowable forms of telehealth “interactive telecommunications systems” to include audio-only communication technology if the patient is not capable of, or does not consent to, the use of video technology.

Temporary Telehealth Expansions
In addition, CMS is proposing temporary changes for the use of audio-visual (not audio-only) telehealth for the purpose of physician/practitioner supervision. Specifically, the rule would expand through CY 2025 the allowance for supervising practitioners to be “immediately available” through audio-visual telehealth. In addition, for CY 2025 only, teaching physicians could continue to supervise audio-visual telehealth services furnished by residents in all teaching settings, such as through a 3-way telehealth visit. Also for CY 2025, the agency will continue to permit physicians to use their currently enrolled practice location instead of their home address when providing telehealth services from home.

The rule also extends through CY 2025 the pandemic-originating coverage of telehealth services provided by federally qualified health centers and rural health clinics. This extension also includes the waiver allowing for reporting of enrolled practice addresses, rather than home addresses, when providers perform services from their home, and the waiver for virtual supervision for residents in all teaching settings when the services are provided virtually.

NABH is displeased that beginning Jan. 1, 2025 – in compliance with federal law – the rule repeals crucial telehealth flexibilities that would subject most digital care to pre-pandemic regulations.

Permanent Audio-visual Telehealth for Low-Risk Services
For services furnished after December 2025, CMS proposes that physician/practitioner oversight via audio-visual telehealth shall be limited to services that are “low risk by their nature, do not often demand in-person supervision, and are typically furnished entirely by the supervised personnel.” CMS’ stated goal for approving remote supervision for these particular low-risk services is that they already are known to balance patient safety concerns with the need to expand access and optimize workforce capacity:

• Services with the underlying HCPCS code that has been assigned a PC/TC indicator of ‘5’; and
• Services described by CPT code 99211 (Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional).

In addition to CMS’ proposed telehealth expansions, Congress is also considering extending telehealth flexibilities beyond this year, most likely through a two-year extension. NABH strongly endorses these flexibilities.

Quality
For reporting in 2025, CMS proposes six new, optional metrics for the quality payment program.
Please see the agency’s news release to read a high-level summary of the rule.

CMS will accept comments on the proposed rule through Sept. 9.

Reminder: SAMHSA Accepting Nominations for First SAMHSA Trailblazers in Advancing Recovery Awards

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week it has started accepting nominations for the inaugural SAMHSA Trailblazers in Advancing Recovery (STAR) awards, which honor leaders with lived experience of mental health and/or substance use condition, including family members whose lives have been affected.

The new STAR awards will also recognize organizations that have demonstrated a commitment to promoting equitable and inclusive access to wellness and recovery supports for individuals with mental health and/or substance use conditions.

Last year SAMHSA published Recovery from Substance Use and Mental Health Problems Among Adults in the United States, which reports that more than 70% of people, or about 50 million people, identified as ever having a mental health and/or substance use problem were in recovery.

Nominations opened June 26 and will remain open through July 18. SAMHSA is planning an awards ceremony that it will livestream in September as part of National Recovery Month. Click here to learn about the award categories, eligibility requirements, and nominating process.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through today, July 12, 2024.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Results from a recent national survey showed 61% of Americans are unaware that primary care physicians can prescribe medication for opioid use disorder and 13% incorrectly believed that they could not, according to study published in JAMA.
                                  
For questions or comments about this CEO Update, please contact Jessica Zigmond.

House Ways and Means Committee Hearing Examines U.S. Child Welfare System 
and RTFs

The House Ways and Means Committee on Wednesday held a hearing about strengthening America’s child welfare system and protecting America’s children through reauthorizing Title IV-B, a child and youth foster-care program.

Although committee members focused primarily on improving the nation’s child foster care system, they also asked several questions of witness Paris Hilton, who testified about Residential Treatment Facilities (RTFs) and offered support for S.1351/H.R.2955, The Stop Institutional Child Abuse Act. Members and witnesses acknowledged the need for RTFs and also called for greater state and federal oversight, an expanded workforce, additional mental healthcare for children in the youth foster-care system outside RTFs, and more community-based care.

The hearing was one of several this Congress held to explore reauthorizing the Social Security Act’s Title IV-B program, which provides flexible funding for states to support family preservation, reunification, adoption, and permanency for children in foster care. Congress has not reauthorized the program since 2008.

In addition to potentially reauthorizing Title IV-B, several committee members discussed legislation they have drafted related to RTFs, which the committee could examine in a future mark-up session. These bills include:

H.R. 8817, the Promoting Accountability, Reporting, Information Sharing, and Health Act, by Reps. Steube (R-Fla.) and Jimmy Panetta (D-Calif.), which directs the U.S. Health and Human Services Department, the U.S. Education Department, the Administration for Children and Families, the Center for Medicare & Medicaid Services, and the U.S. Justice Department, to develop guidance on best practices for federal agencies and states. The guidance would focus on collecting data collection and sharing information related to youth well-being in RTFs, improving data on maltreatment, and enhancing oversight of youth residential programs receiving federal funding.

H.R. 8643, the Foster Youth Mental Health Support Act, by Rep. Michelle Steel (R-Calif.), which amends subpart 1 of Title IV part B of the Social Security Act to strengthen state plan requirements to include comprehensive mental health and well-being for children and youth in foster care.

Both bills were recently introduced, and NABH will share the bill language with members as soon as it is available. NABH sent the Ways and Means Committee comments about RTFs and our new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs.

NABH Congratulates Board Chair Frank Ghinassi for AHRQ Technical Expert Panel Position

NABH is pleased to announce NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers University Behavioral Health Care and vice president of the behavioral health and addictions service line at RWJBarnabas Health, is serving on a behavioral health technical expert panel (TEP) that the Office of the Assistant Secretary, or ASPE, convened in partnership with the Agency for Healthcare Research and Quality (AHRQ).

ASPE and AHRQ engaged research firm Mathematica to identify and recommend behavioral health integration measure concepts for further development. In Phase 1 – completed in March 2024 – the team conducted an environmental scan and gathered feedback from key stakeholders about priorities for measures related to the integration of behavioral and physical healthcare.

In Phase 2, the current phase, the team will develop draft measure specifications based on further review of the literature and interviews with key stakeholders. The TEP will provide feedback on the draft measure specifications as well as the face validity of the measures, according to a memo from Mathematica, which said it will use the TEP feedback to refine the measure specifications.

ICYMI: Surgeon General’s Op-Ed on Why Social Media Platforms Should Carry Warning Labels

U.S. Surgeon General Vivek Murthy, M.D., M.B.A., last week penned an op-ed in The New York Times urging social media platforms to carry warning labels.

“The mental health crisis among young people is an emergency— and social media has emerged as an important contributor,” Murthy wrote. “Adolescents who spend more than three hours a day on social media face double the risk of anxiety and depression symptoms, and the average daily use in this age group, as of the summer of 2023, was 4.8 hours. Additionally, nearly half of adolescents say social media makes them feel worse about their bodies,” he continued. “It is time to require a surgeon general’s warning label on social media platforms, stating that social media is associated with significant mental health harms for adolescents.

Murthy added that a surgeon general’s warning label – which requires congressional action – would regularly remind parents and adolescents that social media has not been proved safe. He recognized that a warning label alone will not keep kids safe and added that the advisory he issued last year includes specific recommendations for policymakers, platforms, and the public to make social media safer for kids.

SAMHSA Accepting Nominations for First ‘SAMHSA Trailblazers in Advancing Recovery’ Awards

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week it has started accepting nominations for the inaugural SAMHSA Trailblazers in Advancing Recovery (STAR) awards, which honor leaders with lived experience of mental health and/or substance use condition, including family members whose lives have been affected.

The new STAR awards will also recognize organizations that have demonstrated a commitment to promoting equitable and inclusive access to wellness and recovery supports for individuals with mental health and/or substance use conditions.

Last year SAMHSA published Recovery from Substance Use and Mental Health Problems Among Adults in the United States, which reports that more than 70% of people, or about 50 million people, identified as ever having a mental health and/or substance use problem were in recovery.

Nominations opened June 26 and will remain open through July 18. SAMHSA is planning an awards ceremony that it will livestream in September as part of National Recovery Month.

Click here to learn about the award categories, eligibility requirements, and nominating process.

SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

A study published in JAMA last week found that, despite their known association with reduced risk of a fatal drug overdose, only a small percentage of Medicare beneficiaries (4.1%) received medications for opioid use disorder (MOUD) or filled a naloxone prescription (6.2%) in the 12 months after a nonfatal drug overdose. “Efforts to improve access to behavioral health services; MOUD; and overdose-prevention strategies, such as prescribing naloxone and linking individuals to community-based health care settings for ongoing care, are needed,” the study noted.

Happy Independence Day from NABH!

NABH will not publish CEO Update on Friday, July 5 and will resume on Friday, July 12. The NABH team wishes you, your families, and your teams a happy and safe Independence Day weekend!

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

House Ways & Means Committee to Host Hearing Next Week on Strengthening 
Child Welfare

The House Ways and Means Committee is scheduled to conduct a hearing next Wednesday, June 26 focused on strengthening child welfare by reauthorizing Title IV-B, a program serving children and youth in foster care. Policymakers are expected to review youth Residential Treatment Facilities (RTFs) during the hearing.

Among witnesses invited to testify is Paris Hilton, who has spoken about her turbulent experience at a youth treatment center and is an advocate for S.1351/H.R.2955, The Stop Institutional Child Abuse Act. The bill establishes an interagency Federal Work Group on Youth Residential Programs to support and implement best practices regarding the health and safety, care, treatment, and appropriate placement of youth in youth residential programs.

The hearing is part of the Committee’s ongoing focus to reauthorize the Social Security Act’s Title IV-B programs. The Committee has previously held several hearings to examine various programs included in Title IV-B. The Title IV-B program provides flexible funding for states to support family preservation, reunification, adoption, and permanency for children in foster care; however, many consider the program outdated, and Congress has not reauthorized it since 2008.

NABH will submit comments to the Ways & Means Committee and will also share our new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs.

The hearing comes on the heels of last week’s Senate Finance Committee hearing about RTFs, “Youth Residential Treatment Facilities: Examining Failures and Evaluating Solutions” and a partisan report, Warehouse of Neglect: How Taxpayers Are Funding Systemic Abuse in Youth Residential Treatment Facilities, which cites limitations and problems at youth RTFs and fails to recognize the critical care, treatment, and educational support these programs provide to America’s youth. NABH sent this letter to the Senate Finance Committee last week in conjunction with the hearing.

CMS Announces Funding Opportunity Application Period for the Innovation in Behavioral Health Model

The Centers for Medicare & Medicaid Services (CMS) this week released its notice of funding opportunity application for the Innovation in Behavioral Health (IBH) model that focuses on improving the behavioral and physical health outcomes and quality of care for Medicare and Medicaid enrollees who experience moderate to severe behavioral health conditions.

The IBH Model is a state-based model that state Medicaid agencies (SMAs) lead with a goal of aligning payment between Medicaid and Medicare for integrated care.

CMS will select up to eight SMAs to participate in the IBH Model, and these agencies will use cooperative agreement funding to develop necessary infrastructure and capacity to implement the IBH Model. The SMAs will recruit “Practice Participants” to deliver care, and they will receive funding to support necessary upgrades to health information technology, electronic health records, practice transformation activities, and staffing to implement the model.

CMS will issue award notices to selected SMAs in mid-December. Learn more from this CMS IBH model overview fact sheet. For additional questions, you can reach the IBH Model team at IBHModel@cms.hhs.gov.

SAMHSA Announces New Way to Order 988 Print Materials

The Substance Abuse and Mental Health Services Administration has announced a new website to order 988 awareness printed materials.

“Over the past two years, we’ve heard your requests to simplify and improve the ordering process for 988 Suicide & Crisis Lifeline print materials,” SAMHSA said in an announcement. “We know that print materials are a critical need for all who are working to raise awareness about 988 across the country, and we have been working behind the scenes to improve this process.”

Providers and other partners will still be able to use the “order print materials” link from SAMHSA’s 988 Partner Toolkit.

CDC Reports 26% Drop in Uninsured Americans Since 2019

New data from the Centers for Disease Control and Prevention’s National Health Interview Survey (NHIS) show 7.6% of Americans did not have health insurance in 2023, compared with 10.3% of Americans without health insurance in 2019, reflecting a 26% decrease in the number of uninsured Americans.

Meanwhile, the NHIS reported that among adults ages 18–64 living in Medicaid expansion states, the percentage with public coverage increased to 25.2% in 2023 from 23.4% in 2019. A similar increase in public coverage was observed among adults living in non-Medicaid expansion states 18.1% in 2023 from 15.1% in 2019.

In a story this week, Behavioral Health Business highlighted how more Americans with health insurance could affect the behavioral healthcare segment.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Hospitals that report using AI to detect patterns of drug diversion – when drugs are stolen from hospitals – nearly doubled to 56% in 2023 from 29% in 2019, according to a Wolters Kluwer survey.

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

Senate Finance Committee Holds Hearing and Releases Report on Youth RTFs

In conjunction with a hearing Wednesday, the Senate Finance Committee released Warehouse of Neglect: How Taxpayers Are Funding Systemic Abuse in Youth Residential Treatment Facilities, a partisan report that cites limitations and problems at youth RTFs and fails to recognize the critical care, treatment, and educational support these programs provide to America’s youth.

Only members of the Committee’s minority staff developed the report, a two-year effort that focused on four operators of youth residential treatment facilities (RTFs), including three NABH system members.

“NABH is eager to work with federal leaders to develop policies that advance access to quality care in the appropriate settings for U.S. youth who struggle with mental health and substance use disorders,” NABH President and CEO Shawn Coughlin said in a statement Wednesday. “We also want to remind congressional leaders that if public discourse about youth RTFs is to benefit the common good, we need to ensure that policymakers, members of the media, worried parents, concerned teachers, and the general public share the same, clear understanding of the role that regulated, licensed RTFs play in the behavioral healthcare continuum.”

The report recommended three main points: 1) children placed in RTFs must be afforded safety, dignity, and homelike conditions and provided with the treatment and support that they need, 2) government funding should prioritize community-based services and placements to address children’s behavioral health needs, and 3) effective oversight mechanisms of RTFs require substantial investment at all levels of government.

At the hearing, several Democratic members joined Senate Finance Committee Chairman Ron Wyden (D-Ore.) and Ranking Member Mike Crapo (R-Idaho). Several witnesses, including a disabilities-rights advocate and a Government Accountability Office representative, painted an incomplete picture of the care and treatment that RTFs provide. While most acknowledged youth RTFs play a role in the behavioral healthcare continuum, senators and witnesses called for more home and community-based services and better state and federal oversight, among other recommendations.

Meanwhile, there were no statements that reflected the successful treatment in RTF programs and the increasing need for them in the United States today. Since 2010, the number of youth residential treatment programs has declined by 60.9%; the number of youth served has declined by 77%; and the number of beds has declined by 66.2%; according to a May 2024 study from the Manhattan Institute.

Also Wednesday, NABH sent a letter to the Senate Finance Committee and released a new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs. Please share the fact sheet with your teams and engage with NABH’s X and LinkedIn posts to spread the message about these facilities and the critical – and often life-saving – care that NABH members provide in RTFs every day.

Legal Action Center to Host Webinar Next Week on How SUD Providers Can Leverage Medicaid Reentry for People Leaving Prisons and Jails

Medicaid reentry is a new federal policy meant to strengthen access to health coverage and transitional services for people preparing to come home from prison or jail, with a primary goal to prevent overdose among reentering individuals.

The Legal Action Center, an Opioid Response Network training partner, will host Medicaid Reentry: How Substance Use Disorder Service Providers/Stakeholders Can Leverage This New Opportunity to Strengthen Equitable Health Outcomes for People Leaving Prison/Jail, a 75-minute webinar next Thursday, June 20 starting at noon ET.

Click here to add the event to your calendar.

National Academies Releases Publication on Adult ADHD

The National Academies has released Adult Attention-Deficit/Hyperactivity Disorder: Drug Development, Diagnosis, and Treatment, which is based on proceedings from a December 2023 workshop about the topic.

According to the National Academies, evidence suggests adults with ADHD may be more likely to develop an SUD, and there are concerns that non-medical use of prescription stimulants could lead to misuse, overdose, or toxicity.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials.

With guidance from our members, NABH has improved the portal by adding two elements:

1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
2. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.

We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

The number of individual pills containing fentanyl that law enforcement officer seized was 2,300 times greater in 2023 compared with 2017, with 115,562,603 pills seized in 2023 versus 49,657 in 2017, according to a recent announcementfrom the National Institute on Drug Abuse.

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

Senate Democrats Pressure Biden Administration to Complete Final Parity Rule

A group of Senate Democrats is pressuring the Biden administration to complete and release its final rule on the Mental Health Parity and Addiction Equity Act’s requirements.

In a letter to the leaders of HHS, the Internal Revenue Service, and the U.S. Labor Department’s Employee Benefits and Security Administration, Sens. Chris Murphy (Conn.), Peter Welch (Vt.), Alex Padilla (Calif.), Ed Markey (Mass.), Amy Klobuchar (Minn.), and Ben Ray Luján (N.M.) urged the Biden administration to stay the course on completing its work to finalize the 2023 proposed rule.

The letter noted: “…these rules will close existing loopholes in the law, expand narrow networks, and prohibit restrictive practices that prevent families from accessing care.”

Particularly important are the rules that combat the nonquantitative treatment limitations that are being used to deny mental health services to patients. These common-sense parity rules will help Americans suffering from mental health conditions or substance use disorder, reduce costs for taxpayers, and save lives.

NABH and leaders of mental health advocacy groups are also strongly urging these agency leaders to oppose efforts from insurance and employer groups to weaken the proposed rule’s strong protections.

Meanwhile, these communications come as a powerful group of employer organizations – the ERISA Industry Committee, the Partnership for Employer-Sponsored Coverage, and the U.S. Chamber of Commerce – have pushed back on the administration and the proposed rule, arguing that the regulations would be “unworkable” and undermine access to care.

Insurers have also slammed the proposed rule, saying it wouldn’t address underlying workforce shortages, which they say limit access to care. The Treasury Department has targeted June to finalize the rules, although it remains uncertain if that will happen.

HRSA Accepting STAR Loan Repayment Program Applications Through June 27

The Health Resources and Services Administration (HRSA) will accept applications from eligible
SUD treatment clinicians and community health workers for its Substance Use Disorder Treatment and Recovery (STAR) Loan Repayment Program through Thursday, June 27.

Click here for guidance about the STAR Loan Repayment program and here for information about the application process.

HRSA Adds Occupations to Guide for Licensure Portability

HRSA has announced that counseling and school psychologists have been added as new disciplines to the Multi-Discipline Licensure Resource Project that HRSA supports with the Association of State and Provincial Psychology Boards.

Previously the site provided guidance for psychology, social work, physical therapy, and occupational therapy. The new disciplines include counseling, dentistry, dieticians, emergency medical services, physician assistants, nursing, advanced practice nursing, and school psychologists.

SAMHSA Releases Issue Brief on Peer Support in Mental Health

The Substance Use and Mental Health Services Administration has released an issue brief for state mental health authorities about the benefits of peer support and inclusion of the peer workforce throughout the behavioral healthcare continuum.

The new resource highlights current standards and best practices for including peer support workers as an essential component of services delivery for mental and co-occurring disorders such as SUD.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials.

With guidance from our members, NABH has improved the portal by adding two elements:

1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
2. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.

We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Starting people with opioid use disorder on extended-release, injectable naltrexone (XR-naltrexone) within five to seven days of seeking treatment is more effective than the standard treatment method of starting within 10-15 days, but requires closer medical supervision, according to results from a National Institute on Drug Abuse-supported clinical trial.

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

NABH Comments on Fiscal Year 2025 IPF PPS Final Rule

This week NABH sent its public comment letter to the Centers for Medicare & Medicaid Services (CMS) about the agency’s fiscal year 2025 inpatient psychiatric facility prospective payment system (IPF PPS) rule.

In the letter, NABH emphasized that the proposed net update for FY 2025 – an increase of 2.6% percent relative to FY 2024 rates – does not adequately account for the nationwide cost pressures that IPFs continue to face.

“The update does not reflect the remaining healthcare cost inflation that was sparked by the COVID-19 pandemic and still persists in the form of workforce pressures and shortages and other elevated costs,” NABH wrote. “These include continued head-to-head wage competitions with other employers within and outside of local healthcare marketplaces, which are exacerbated by burnout among clinical and non-clinical personnel, and other factors that continually pressure IPFs to raise compensation levels.”

NABH offered its perspective and suggestions on a range of other topics, including the need for modern behavioral health information technology, a request to delay the requirement for ancillary-services reporting by two years, and proposed quality reporting changes.

“NABH urges CMS to delay implementing its proposed policy restriction on all-inclusive reporting. Given the complexity of transitioning from all-inclusive to traditional reporting of ancillary charges, the proposed effective date of Oct. 1, 2024 is impossible and should be changed to Oct. 1, 2026.”

The association thanks all its members who gave their time and recommendations in the last few months to help NABH prepare the letter to CMS.

FDA Launches ‘Prescribe with Confidence’ Campaign to Help Providers Treat OUD

The U.S. Food and Drug Administration (FDA) has launched Prescribe with Confidence, a campaign to help healthcare providers recognize and treat opioid use disorder (OUD), which the agency says affects 6 million people over the age of 12 in the United States.

“Research shows that OUD treatment is most effective when medications are used,” FDA Commissioner Robert Carliff, M.D. said in a brief video about the campaign.

In its announcement, the FDA noted that many primary care providers have found prescribing medications to treat OUD is easier than they thought it would be. The agency has provided firsthand testimonials, free training, and other resources to help providers. Click here to learn more.

ICYMI: 2024 NABH Annual Meeting Highlights

NABH thanks all who traveled to Washington earlier this month for the association’s 2024 Annual Meeting!

Photos from the meeting are now available. If you choose to use any of these pictures, please credit photographer Chris Ferenzi.

NABH has shared the Annual Meeting slide presentations and learned some attendees had trouble downloading them. We have re-posted the presentations as PDF documents on our 2024 Annual Meeting Speakers & Presentations page. David Wasserman’s presentation will be available until today, Friday, May 31.

We’ve received positive feedback about the NABH Education and Research Foundation’s workforce panel, and we urge you to share NABH’s Workforce Startup Guide with your teams. You can download the guide on NABH’s website homepage.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) on May 13 announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials.

With guidance from our members, NABH has improved the portal by adding two elements:

1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
2. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.

We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

A new analysis in JAMA highlights how a hospital cyberattack can affect neighboring facilities and an entire community’s care: researchers examined emergency department (ED) discharge data from the California Department of Health Care Access and Information between 2014-2020 and found a temporary decrease in ED visits and inpatient admissions at hospitals targeted by ransomware attacks and a temporary increase in ED visits at nearby, unaffected hospitals.

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

2024 NABH Annual Meeting & Hill Day Highlights

NABH thanks all who traveled to Washington last week for the 2024 Annual Meeting!

Photos from the meeting are now available. If you choose to use any of these pictures, please credit photographer Chris Ferenzi.

Last week NABH shared the Annual Meeting slide presentations and learned some attendees had trouble downloading them. We have re-posted the presentations as PDF documents on our 2024 Annual Meeting Speakers & Presentations page. David Wasserman’s presentation will be available until May 31.

We’ve received positive feedback about the NABH Education and Research Foundation’s workforce panel, and we urge you to share NABH’s Workforce Startup Guide with your teams. You can download the guide on NABH’s website homepage.

NABH also thanks all members who participated in Hill Day in conjunction with #NABH2024! Our members met with policymakers and their staff and highlighted the crucial need to secure the promise of parity between behavioral and physical healthcare, increase the behavioral healthcare workforce, and invest in behavioral health information technology to adopt electronic health records.

NABH members conducted more than 60 congressional meetings and prioritized key offices for policymakers who serve on committees of jurisdiction overseeing behavioral healthcare policy, including the Senate Finance Committee, Senate Health, Education, Labor and Pension Committee, House Energy and Commerce Committee, and House Ways and Means Committee.

Please save the date for next year’s Annual Meeting: May 12-14, 2025 at the Salamander Washington, DC!

House Committees Advance Telehealth Extension Bills

The House Energy & Commerce Health Subcommittee on May 16 unanimously advanced telehealth legislation to the full House Energy & Commerce Committee that would extend for two years key COVID-19 pandemic telehealth waivers scheduled to expire at the end of this year.

The bill that the Subcommittee advanced – similar to the bill the House Ways & Means Committee passed in the previous week – would delay the in-person requirement and originating site restrictions for mental health services and extend the provision for audio-only telehealth services for the next two years. Both bills also include a five-year extension of waivers for the Acute Hospital Care at Home program, allowing patients to receive hospital-level care in their homes until 2029.

The House Energy & Commerce’s bill includes payment parity for federally qualified health centers and rural health clinics, so they can bill the same amount for telehealth and in-person outpatient services. Under the House Ways & Means Committee’s bill, the centers would be reimbursed at lower rates for most virtual services.

Meanwhile, the Energy & Commerce panel also advanced a second telehealth bill that would establish a Medicare incident to modifier for mental health services furnished through telehealth. Both committees’ bills include offsets that impose new transparency requirements on pharmacy benefit managers and delay the upcoming changes to Medicare payment rates for clinical lab tests by one year.

The Senate has yet to take up a telehealth extension bill, although Senate Finance Committee Chair Ron Wyden (D-Ore.) is pushing to extend permanently some of the COVID-19-era telehealth flexibilities set to expire at the end of this calendar year. If Congress passes a short-term telehealth extension, lawmakers will have to restart the process after it expires.

Final Medicaid Rule Reduces Allowed Wait Times for Behavioral Healthcare Outpatient Appointments

The Centers for Medicare & Medicaid Services (CMS) recently published a Medicaid final rule that includes positive changes on several NABH priority issues.

NABH is pleased that beginning in June 2027, wait times for adult and pediatric outpatient mental health and substance use disorder (SUD) services will be subject to a 10-day maximum. Also, starting in 2028, states will be required to conduct annual “secret shopper” surveys to investigate whether managed care plans are meeting wait time requirements and the validity of provider directories.

In July 2027, states must survey Medicaid enrollees to assess their managed care experience. Finally, to help CMS understand and improve payment adequacy, beginning in July 2026, states must annually submit payment data that compare state Medicaid managed care plan rates with Medicare or Medicaid state plan rates, including specific data for mental health and SUD services.

This CMS fact sheet provides additional details about the final rule.

ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) on May 13 announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials.

With guidance from our members, NABH has improved the portal by adding two elements:

1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
2. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.

We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

A new study of more than 1.2 million people has identified 95 regions of the genome linked to PTSD, and 80 of those have not been identified previously. Researchers also identified 43 genes that seem to play a role in causing PTSD.

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

2024 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2024 Annual Meeting that starts Monday, May 13 in Washington, D.C.

This year’s Annual Meeting focuses on The Future of Behavioral Healthcare, and our presenters will explore this theme as it relates to behavioral health information technology, parity, workforce issues, and more.

To prepare for the meeting, please view our preliminary program, learn more about this year’s speakers, and see our list of exhibitors and sponsors attending the meeting.

Be Sure to Access the 2024 NABH Annual Meeting Mobile App!

Again this year, attendees will have access to all Annual Meeting programming and materials through NABH’s web-based app.

Early Monday, NABH will send all attendees an Annual Meeting alert with this link to the app that displays details about sessions, speakers, meeting room locations, NABH’s advocacy priorities, and more. Attendees can also access the link through a QR code near the Registration Desk at the Annual Meeting.

Deputy National Coordinator for Health IT Steven Posnack to Open Monday Sessions

NABH is pleased to welcome Deputy National Coordinator for Health Information Technology Steven Posnack, M.S., M.H.S. as our first 2024 Annual Meeting presenter on Monday, May 13 t 2:45 p.m. ET in the Salamander hotel’s Grand Ballroom.

Posnack advises the national coordinator, leads the execution of the Office of the National Coordinator for Health Information Technology’s (ONC) mission, and represents ONC’s interests at a national and international level.

Together with the national coordinator, Posnack also oversees ONC’s federal coordination, regulatory policy, public-private initiatives, and the overall implementation of statutory authorities and requirements, including those from the 21st Century Cures Act and HITECH Act. He will discuss behavioral health information technology at our Annual Meeting.

NABH Education and Research Foundation to Workforce Panel on Monday at 4 p.m. ET

Building on last year’s success, the NABH Education and Research Foundation will host a panel discussion featuring NABH members and workforce consultants on Monday from 4 p.m. – 5 p.m. ET.

This year’s panel will focus on NABH member best workforce practices, internships, apprenticeships, and other “grow your own” programs.

NABH Education and Research Foundation Vice President Jim Shaheen of New Season, who also serves on the NABH Board of Trustees, will moderate the panel that will feature Jason Brooks, Ph.D., senior vice president of Human Resources at New Season; Rhonda Ashley-Dixon, vice president of Strategic Partnerships & Engagement at Vanderbilt Behavioral Health; Beth Kuhn, principal at Stonegate Strategies and former commissioner, Kentucky Department of Workforce Investment; and John Pallasch, founder and CEO of One Workforce Solutions and former U.S. assistant secretary for employment and training at the U.S. Labor Department (DOL).

This year’s panel discussion will include poll questions for the audience, and we urge NABH members to attend and engage with panelists during the question-and-answer period!

DOL Official Timothy Hauser to Discuss Parity on Tuesday, May 14 at 10 a.m.

Timothy D. Hauser, deputy assistant secretary for program operations of DOL’s Employee Benefits Security Administration (EBSA) will discuss parity when he kicks off Day 2 of the NABH 2024 Annual Meeting on Tuesday, May 14 at 10 a.m.

Hauser, who serves as EBSA’s chief operating officer, joined DOL in 1991 as a trial attorney for the Plan Benefits Security Division (PBSD), where he represented the department in federal district court and appellate litigation. From November 2000 until November 2013, Mr. Hauser was the associate solicitor of the division. As the head of PBSD, he was responsible for all of DOL’s legal work under ERISA.

Before joining DOL, Mr. Hauser worked as a trial attorney for six years at Legal Aid of Western Missouri. Hauser graduated from Harvard Law School in 1985 and earned his undergraduate degree at the University of Illinois.

Election Analyst David Wasserman to Examine 2024 Elections at 11 a.m.

Following Hauser’s presentation Tuesday morning, election analyst David Wasserman will provide Annual Meeting attendees with an in-depth look at this year’s upcoming presidential and congressional elections.

Wasserman is the senior editor for the non-partisan newsletter The Cook Political Report with Amy Walter, which has analyzed U.S. presidential, Senate, House, and gubernatorial races since 1984. Referred to as “pretty much the only person you need to follow on Election Night” according to Meet the Press host Chuck Todd, Wasserman is also a contributor to NBC News.

Prior to joining the The Cook Political Report with Amy Walter in 2007, Wasserman served for three years as House editor of Sabato’s Crystal Ball, a widely respected political analysis newsletter and website founded by renowned University of Virginia professor Larry Sabato (a former NABH Annual Meeting presenter).  Wasserman graduated from the University of Virginia.

NABH President and CEO Shawn Coughlin to Address Attendees at Annual Meeting Luncheon

Please join us for this year’s Annual Meeting Luncheon on Tuesday at Noon to hear brief remarks from NABH President and CEO Shawn Coughlin.

Coughlin will provide updates on NABH’s work and help prepare attendees who will head to Capitol Hill for congressional visits following the luncheon.

Help Us Advocate Your Issue Priorities at Hill Day 2024!

NABH is eager to welcome its members and guests to Hill Day 2024 on Tuesday, May 14 from 1:30 – 5 p.m. ET!

As always, Hill Day is an excellent opportunity for NABH members to meet personally with Members of Congress and their staff to share our association’s advocacy priorities. It’s not too late to register if you’re interested!

If you registered for the Annual Meeting, are interested in Hill Day, and have not yet signed up, please contact e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

How it Works:

After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent your facility’s footprint.

On Hill Day, NABH will have our Advocacy Room open from 12:30 p.m. – 1:50 p.m. in the Renwick Room of the Salamander. Here NABH will help prepare you with materials and talking points to guide your conversations with Members of Congress and their staff. The Advocacy Room will reopen from 4:15 p.m. – 5:00 p.m. for you to debrief your meetings.

What We Need From You:

Please indicate in your Annual Meeting registration form that you are interested in Hill Day, and be sure to include all the states where your system has a footprint. If you have an existing relationship with a legislator, please let us know! This is very helpful when scheduling meetings.

Also, Hill Day participants—and all Annual Meeting attendees—can review the association’s 2024 Advocacy Priorities and Hill Day fact sheets before or during the Annual Meeting through our web-based meeting app.

Wednesday Policy Breakfast to Feature Remarks from Rep. Doris Matsui & NABH Consultant Meiram Bendat, J.D., Ph.D.

Join us for the Annual Meeting Policy Breakfast on Wednesday at 8 a.m. to watch a brief video from NABH Champion Rep. Doris Matsui (D-Calif.) and to learn about the ongoing Wit v. United Behavioral Health case from NABH consultant Meiram Bendat, J.D., Ph.D.

Matsui will highlight her legislation, the Behavioral Health Information Technology Coordination Act, and discuss why adopting BHIT is critical.

An attorney with a background in mental health, Bendat represented children and families in the Los Angeles child welfare system and treated patients before he founded Psych-Appeal, the country’s first private mental health insurance law firm, in 2011.

Since then, Bendat has helped patients and providers successfully challenge denials of mental health treatment through administrative appeals and impact litigation, recovering millions of dollars in wrongly withheld benefits.

The NABH team wishes everyone a safe trip to Washington, and we look forward to seeing you soon!

Please note: NABH will not publish CEO Update next week and will publish the next issue on May 24. For questions or comments about this CEO Update, please contact Jessica Zigmond

New Analysis Shows Opioid Crisis Cost the U.S. Economy $631 Billion Over Four Years

Gallup Reports Nearly Half of U.S. Adults Have Dealt with Substance Abuse in Their Family

National Addiction Treatment Week is October 21-27, 2019

NABH President and CEO Mark Covall to Speak at Treatment Center Investment & Valuation Retreat

Register Today for the NABH 2020 Annual Meeting!

Fact of the Week

CMS Releases FAQ on Qualified Residential Treatment Programs

• CMS has not made a determination that all QRTPs will be IMDs; rather, there are several options for states to consider regarding QRTPs.
• QRTPs may qualify as IMDs if they are primarily engaged in providing diagnosis, treatment, or care of persons with mental diseases including medical attention, nursing care, and related services, and have more than 16 beds.
• State Medicaid agencies must review each QRTP, if over 16 beds, to make a determination if the facility meets the definition of an IMD according to Medicaid statute, regulation and guidance in the State Medicaid Manual.
• QRTPs also likely would not meet the requirements to qualify as Psychiatric Residential Treatment Facilities (PRTFs), which have more stringent standards… If, however, a QRTP meets the applicable requirements and conditions of participation to qualify as a PRTF, then Federal Financial Participation (FFP) would be available.
• Medicaid managed care rules permit FFP for monthly capitation payments to managed care plans for enrollees that are inpatients in a residential setting that may qualify as an IMD when the stay is for no more than 15 days during the period of the monthly capitation payment and certain other conditions are met.
• States may consider an existing section 1115 option, which we further clarify in this document, for states to receive Medicaid reimbursement for services to individuals in QRTPs that would be considered IMDs.
• Under the 1115 waiver, FFP will not be available for room and board costs in QRTPs, unless they are also certified as PRTFs.
• States interested in including QRTPs in their section 1115(a) demonstrations will need to determine how best to include stays in QRTPs, recognizing that overall the state will be expected to achieve a statewide average of 30 days as part of these demonstrations.

CMS Awards Nearly $48.5 Million to State Medicaid Agencies for SUD Treatment Services

NABH Supports Senate Bill to Address Nation’s Shortage of Mental Health Professionals

ASAM Seeks Public Comment on Clinical Practice Guideline

National Addiction Treatment Week is October 21-27, 2019

Save the Date for the NABH 2020 Annual Meeting!

Fact of the Week

NABH Endorses Legislation For a 3-Digit Suicide Prevention Line

Labor Department Releases More Information on Parity

• FAQs about Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act.
• Final MHPAEA Disclosure Template.
• MHPAEA Enforcement Fact Sheet for FY 2018.
• Appendix to the MHPAEA Enforcement Fact Sheet for FY 2018.
• Introduction to the MHPAEA Enforcement Fact Sheet for FY 2018.

Suicide Rates Continue to Climb

New Publication on The Sequential Intercept Model

Federal Report on Achieving Population-Level Effects for Behavioral Healthcare in Children

• Federal agencies should collaborate with state and local agencies, as well as national and local foundations and the business community;
• Federal agencies should use their capabilities to promote healthy mental, emotional, and behavioral development and mitigate risks;
• Federal agencies should support rapid development and dissemination of effective mental, emotional, and behavioral interventions for delivery to large populations; and
• The U.S. Department of Health and Human Services should collaborate with states and local jurisdictions to conduct a comprehensive assessment of existing sources of data useful for tracking key population data on the mental, emotional, and behavioral health and development of children.

New Consumer Information on “Vaping Illnesses”

Save the Date for the NABH 2020 Annual Meeting!

Fact of the Week

HHS Announces $1.8 billion in Funding to States to Fight Opioid Crisis

HRSA and SAMHSA Team Up on Medication Assisted Treatment

SAMHSA Introduces New Logo to Commemorate National Recovery Month’s 30^thAnniversary

National Addiction Treatment Week is October 21-27, 2019

Save the Date for the NABH 2020 Annual Meeting!

New CEO Update Feature: Fact of the Week

SAMHSA Releases 2018 National Survey on Drug Use and Health

Report Shows Americans Spend Almost as Much on Illicit Drugs as Alcohol

Study Says Former Cigarette Smokers Are Smoking Marijuana and Binge Drinking More

HRSA Releases Dashboards on Health Professions Training Programs

HRSA Announces Funding Opportunity for Rural Health Network Development Program

National Consortium of Telehealth Resource Centers Webinar to Focus on Mental Health