Author: Administrator
House of Representatives CHAMPVA Letter to VA
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CEO Update | 66
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- A definition of OUD treatment services and OTPs, including an explanation that services include access to all FDA-approved medications, counseling and therapy, and toxicology testing;
- Enrollment policies that align with SAMHSA OTP regulation and that do not have additional conditions of participation;
- Bundled payment methodologies that separate drug from non-drug treatment components, account for different medications and variable intensity of services, provide for service add-ons and partial- and full-billing for weekly episodes;
- Use of audio-video communication technology; and
- Zero beneficiary cost-sharing requirement for a time-limited period.
- Coverage of OUD management, care coordination, psychotherapy, and counseling; medication to be billed and reimbursed under existing Medicare Part B or D; toxicology testing to be billed under Clinical Lab Fee Schedule;
- Bundled payment methodologies that are based on monthly billing cycles to better align with office-based practices; one bundle for the initial month of treatment that is more service-intensive; and a second bundle for subsequent “maintenance months,” service add-on codes, and not restricted to addiction specialists;
- Three new HCPCS codes to Category I of the list of Medicare telehealth services for office-based substance use disorder (SUD)/OUD services, permitting a patient’s home as a telehealth originating site; and
- No changes to cost-sharing.
NABH Issue Brief: CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020
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NABH Issue Brief: CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule
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OTP Bundled Payment
The proposal implements Section 2005 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act. The rule proposes:- A definition of OUD treatment services and OTPs, including an explanation that services include access to all FDA-approved medications, counseling and therapy, and toxicology testing;
- Enrollment policies that align with SAMHSA OTP regulation and that do not have additional conditions of participation;
- Bundled payment methodologies that separate drug from non-drug treatment components, account for different medications and variable intensity of services, provide for service add-ons and partial- and full-billing for weekly episodes;
- Use of audio-video communication technology; and
- Zero beneficiary cost-sharing requirement for a time-limited period.
Office-based Care Bundled Payment
The agency also proposed a bundled payment for office-based OUD treatment services, to encourage the expansion of access to OUD care, including:- Coverage of OUD management, care coordination, psychotherapy, and counseling; medication to be billed and reimbursed under existing Medicare Part B or D; toxicology testing to be billed under Clinical Lab Fee Schedule;
- Bundled payment methodologies that are based on monthly billing cycles to better align with office-based practices; one bundle for the initial month of treatment that is more service-intensive; and a second bundle for subsequent “maintenance months,” service add-on codes, and not restricted to addiction specialists;
- Three new HCPCS codes to Category I of the list of Medicare telehealth services for office-based substance use disorder (SUD)/OUD services, permits a patient’s home as a telehealth originating site; and
- No changes to cost-sharing.
Emergency Departments
Also of interest, the proposed rule requests information on emergency department practice patterns related to the initiation and use of MAT, and referral or follow-up care, for developing such bundles in future rulemaking. Comments are due September 27, 2019. NABH has engaged a consulting firm to help analyze the proposed bundled payment methodology and payment rates, and the association will submit comments.MHLG Letter of Support on Mental Health Professionals Workforce Shortage Loan Repayment Act of 2019
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NABH Alert: CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule
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CEO Update | 65
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CEO Update | 64
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CEO Update | 63
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CMS Releases Emergency Medical Treatment and Labor Act (EMTALA) Memorandum
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- How do surveyors evaluate whether a staff person is qualified to perform a Medical Screening Exam?
- The surveyor can review state scope of practice as well as hospital bylaws or rules and regulations to determine if the medical screening exams being performed are within a professional’s scope of practice.
- What is the expectation of a psychiatric hospital when a medical emergency presents in terms of who can conduct a medical screening exam?
- EMTALA requires hospitals to perform medical screening examinations within their capabilities. If the psych hospital doesn’t have the ability to perform a comprehensive medical screening exam (or provide stabilizing treatment), but the screening exam it performs indicates that the patient may have an emergency medical condition, the hospital is required to arrange an appropriate transfer to a facility for further evaluation and treatment. The hospital is expected to use its resources to perform the exam and provide care within its capabilities prior to transfer. This might be as simple as performing ongoing assessments with repeat vital signs and ensuring the patient is in a safe environment.
- What is required in terms of stabilization and transfer for non-psychiatric emergencies?
- There is no expectation that a psych hospital with basic clinical services would be expected to provide the same level of comprehensive medical assessments or treatment as an acute care hospital.
- How does EMTALA intersect with admission?
- If the hospital has the staff and facilities to stabilize the emergency medical condition, it is expected to do so. This includes inpatient admission, as appropriate. Having an empty inpatient bed does not always translate to having the capability or capacity to stabilize the emergency medical condition.
- Can an ER physician in a facility that does not provide psychiatric care conduct the mental health screening?
- It is within the scope of practice for ED physicians and practitioners to evaluate patients presenting with mental health conditions, same with any other medical, surgical, or psychiatric presentation. The ED practitioner may utilize hospital resources to assist with the examination and treatment or arrange appropriate transfers if additional resources are needed.
CEO Update | 62
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Support Letter: CREATE Act
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Support Letter: BETTER Act
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CEO Update | 61
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FY 2020 IPPS Rule Comments
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CEO Update | 60
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MHLG Letter: Mental Health Parity Compliance Act of 2019 (Senate)
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MHLG Letter: Mental Health Parity Compliance Act of 2019 (House)
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Behavioral Health Information Technology Letter to CMS
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Suicide Hotline Letter to FCC
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PIC Mental Health Parity Compliance Act
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CEO Update | 59
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MACPAC RFI – IMD Regs
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CEO Update | 58
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MHLG Letter: Behavioral Health Coverage Transparency Act (Senate)
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MHLG Letter: Behavioral Health Coverage Transparency Act (House)
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CEO Update | 57
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NABH Analysis: Telebehavioral Health in Medicare
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CEO Update | 56
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Behavioral Health Update: May 7th, 2019
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CEO Update | 55
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CEO Update | 54
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CEO Update | 53
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Shatterproof Rating System for Addiction Treatment Programs
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NQF Quality Innovation: Measuring Quality of Care in Substance Use Disorder (SUD) Treatment Programs
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CEO Update | 52
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The National Action Alliance for Suicide Prevention: Recommended Standard Care for People with Suicide Risk
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CEO Update | 51
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CMS April 2019 Patients Over Paperwork Newsletter
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GAO Report: Research on Healthcare Costs of Untreated Conditions is Limited
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Partnership to Amend 42 CFR Part 2 Applauds House and Senate Bills
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2019 NABH Annual Survey Link
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CEO Update | 50
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Vista Research Group Releases “The State of Addiction Treatment”
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Center on Addiction Reviews and Compares Addiction Benefits in ACA Plans
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CEO Update | 49
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NABH Releases The High Cost of Compliance: Assessing the Regulatory Burden on Inpatient Psychiatric Facilities
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NABH Board Adopts Access to Care Resolution
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- Prevent, diagnose, and/or treat behavioral health conditions;
- Promote age-appropriate growth and development;
- Minimize the progression of disability;
- Facilitate, maintain, and/or restore functional capacity; and
- Support long-term recovery.
The High Cost of Compliance
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CEO Update | 48
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CEO Update | 47
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NABH Applauds Landmark Behavioral Healthcare Coverage Ruling
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NABH Applauds Landmark Behavioral Healthcare Coverage Ruling
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CEO Update | 46
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HHS: Assessing the Impact of Parity in the Large Group Employer-Sponsored Insurance Market
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AAP: Nonmedical Prescription Opioid Use by Parents and Adolescents in the United States
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JAMA: Assessment of Changes in the Geographical Distribution of Opioid-Related Mortality Across the United States
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CEO Update | 45
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Pew Research Center Report: Most U.S. Teens See Anxiety and Depression as a Major Problem Among Their Peers
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CEO Update | 44
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CEO Update | 43
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CEO Update | 42
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