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CEO Update 90

NQF Releases Opioids and Opioid Use Disorder: Quality Measurement Priorities

The National Quality Forum (NQF) this week released Opioids and Opioid Use Disorder: Quality Measurement Priorities, a 105-page report that examines issues related to acute and chronic pain management and substance use disorders (SUD). The report’s findings answer two questions: “What are the priority gaps in Quality Measurement (QM) science that need to be filled in order to reduce opioid use disorders (OUD) and opioid overdose deaths without undermining effective pain management?” and “What existing and conceptual measures should be deployed in the following types of federal medical payment programs to best address the opioid crisis moving forward: Merit-Based Incentive Payment System (MIPS), alternative payment models (APMs), the Medicare Shared Savings Program (SSP), the Hospital Inpatient Quality Reporting Program (IQR), and the Hospital Value-Based Purchasing Program (VBP)?” A 28-member Technical Assistance Panel, or TEP, composed of physicians, nurses, patients, pharmacists, and others with experience in pain management and OUD explored these questions. The TEP took a list of 32 priority gaps, prioritized those to a “top 15” list, and then further reduced that list to five priority gaps (see page 16 of the report). Included among the top five priority gaps were: short-term transition between inpatient and outpatient settings, and long-term follow-up of clients being treated for OUD across time and providers is important to assess even though data challenges exists, and pain management, OUD treatment, SUD treatment, and treatment of physical and mental health comorbidities are all important. “Ultimately, the guidance proffered here aims to achieve the application of the proper healthcare quality metrics across the U.S. healthcare system,” the report said. “Using the best metrics, in turn, aims both to continue to reduce opioid deaths verifiably, to encourage the implementation of best practices of pain management, to decrease the incidence of other SUDs, and to decrease illegal drug use by those unable to obtain prescription pain medication.”

SAMHSA Clarifies Mental Health Block Grants to Mental Health Commissioners

The Substance Abuse and Mental Health Services Administration (SAMHSA) has sent a letter to the nation’s mental health commissioners to clarify that Community Mental Health Services Block Grant (MHBG) funds can be used to treat people with serious mental illness who have interactions with the criminal justice system, including incarceration or pending criminal cases. The letter notes that the service providers for which MHBG funds can be used include community-based mental health centers, child mental health programs, psychosocial rehabilitation programs, mental/peer support services, and mental health primary consumer-directed programs. “Further, funding may be used to screen individuals who may be in need of state hospital services for psychiatric care,” wrote Assistant Secretary for Mental Health and Substance Use Elinore McCance-Katz, who also added a list of services for which funds may not be used, including inpatient care. “It is imperative that MHBG funds to the states be used to serve those in greatest need—the most vulnerable Americans with serious mental illness,” McCance-Katz wrote. “Jails and prisons for too long have been de facto mental health facilities, in part, because of a misunderstanding of how the mental health block grant funds can be used.”

SAMHSA Announces Pilot for Treatment for Pregnant and Postpartum Women

SAMHSA said it expects to issue up to five grants of up to $900,000 for up to three years for a pilot program that would provide treatment for pregnant and postpartum women. According to the announcement, the funds are designed to support family based services for pregnant and postpartum women with a primary diagnosis of a substance use disorder, including opioid use disorders; help substance abuse agencies address the continuum of care, including services provided to women in nonresidential-based settings; and promote a coordinated, effective, and efficient state system that state substance abuse agencies would manage. SAMHSA will accept applications through Monday, April 20. Click here to learn more and apply.

Visit Our Exhibitors and Sponsors at the 2020 Annual Meeting!

NABH appreciates the generous support of our Annual Meeting Exhibitors and Sponsors, whose valuable products and services help NABH members delivery quality behavioral healthcare every day to those who need it. Please be sure to visit our Chairman, President, and Executive Exhibitors, and our Platinum and Gold Sponsors at the 2020 Annual Meeting at the Mandarin Oriental Washington, DC from March 16-18. Before then, view a complete list of our Exhibitors and Sponsors and review our Preliminary Program to find the best time to visit with them. We look forward to seeing you next month in Washington!

Fact of the Week

The opioid crisis has been responsible for more than 400,000 deaths since 2000 and cost an estimated $665 billion in 2018. For questions or comments about this CEO Update, please contact Jessica Zigmond

CEO Update 89

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

White House Proposes Changes IMD Exclusion in 2021 Budget

The White House on Monday released a $4.8 trillion budget for 2021 that would modify Medicaid’s Institutions for Mental Diseases (IMD) exclusion to provide states with flexibility to provide inpatient mental health services to beneficiaries with serious mental illness (SMI). The budget requests $94.5 billion for HHS, a 10-percent decrease from the 2020 enacted level. Although Congress is likely to reject President Trump’s proposal, the budget is significant for outlining the president’s top policy priorities as he seeks re-election in November. Notably for NABH, those priorities address mental health and addiction treatment services. These provisions include changes to the IMD exclusion, which under current law states Medicaid cannot pay for certain inpatient stays at IMDs. The president’s budget would provide more than $5 billion in new federal funding to states to ensure the full continuum of care exists to provide help to people with SMI. These changes—which appear in summary tables at the end of the budget proposal—would exempt Qualified Residential Treatment Programs (QRTPs) from the IMD exclusion. The budget also includes $225 million for Certified Community Behavioral Health Clinics (CCBHC) expansion grants, and would extend, through 2021, the CCBHC Medicaid demonstration programs to improve community mental health services for the eight states participating currently in the demonstration. In addition, the White House has proposed $25 million to expand primary healthcare services to address homelessness. These provisions, together with the changes to the IMD exclusion, are “part of a comprehensive strategy that includes improvements to community-based treatment,” the budget proposal noted. Meanwhile, the president’s 2021 budget would continue 2020 funding to expand medication assisted treatment (MAT) from a small pilot program to half of all eligible Bureau of Prisons (BOP) facilities and provide an additional $37 million to complete MAT expansion to all eligible BOP facilities. NABH will continue to analyze the Trump administration’s budget proposal and keep NABH apprised of any additional details regarding the IMD exclusion, MAT funding, and other topics related to the association’s policy priorities.

CEO Update 88

ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan

The Office of National Drug Control Policy (ONDCP) this week issued its national 2020 National Drug Control Strategy (Strategy) and accompanying National Treatment Plan (NTP) that includes action items for federal agencies and external stakeholders to increase access to care and close the addiction treatment gap.    The Strategy is presented using the domains of prevention, treatment and recovery, and supply-side strategies for reducing the availability and consumption of illicit drugs. These domains are established as ‘pillars’ that undergird the following federal initiatives of “expanding the early intervention, treatment and recovery infrastructure; improving the delivery system; and improving quality.” Specifically, the NTP calls for treatment expansion and improved quality by:
  • Developing protocols for medically managed withdrawal including MAT to prevent relapse and promote stabilization;
  • Increasing emergency department use of addiction medicine specialty services;
  • Exploring the inclusion of stimulant disorder treatment in opioid treatment programs;
  • Increasing access to all medication and psychosocial services, promoting syringe exchange, interim methadone, mobile methadone vans, and peer outreach (one objective of the federal Performance and Reporting System is to make sure 100% of all specialty providers offer MAT by 2020);
  • Adopting model state specialty SUD treatment licensing laws;
  • Developing mobile and online platform with updated information on treatment slot availability with online appoint capacity;
  • Encouraging public and private payers to cover comprehensive services and improve reimbursement rates where out-of-network rates are higher;
  • Urging providers to subsidize and provide treatment scholarships; and
  • Exploring the idea of developing national consensus standards for addiction treatment to consolidate treatment quality standards.
Please contact Sarah Wattenberg, NABH’s director of quality and addiction services, if you have questions about the Strategy or NTP.

OIG Report Finds More Than One-Third of New Jersey’s Federal Medicaid Reimbursement for Providing Community-Based Treatment Services Was Unallowable

HHS’ Office of Inspector General (OIG) has recommended the state of New Jersey refund the federal government $14.8 million after the OIG concluded more than a third of the state’s federal Medicaid reimbursement for providing community-based treatment services was unallowable.   The OIG’s report said that of New Jersey’s 100 sampled claims for federal Medicaid reimbursements of payments for Programs of Assertive Community Treatment (PACT), 50 complied with federal and state requirements, but 50 did not. Meanwhile, of the 100 claims, 21 contained more than 1 deficiency.   “We found PACT program services provided were not adequately supported or documented (36 claims), plan of care requirements were not met (17 claims), PACT teams did not include staff from required clinical disciplines (8 claims), and providers did not obtain prior authorization for beneficiaries (5 claims), among other findings,” the report said.   The OIG’s other recommendations include the state improving procedures to identify deficiencies similar to those identified in the report, and considering regulations for periodic reassessments to determine whether beneficiaries enrolled in PACT continue to require PACT services. The National Academies Releases Report to Improve OUD and Infectious Disease Services The National Academies of Sciences, Engineering, and Medicine (NASEM) has released Opportunities to Improve Opioid Use Disorder and Infectious Disease Services: Integrating Responses to a Dual Epidemic, which identifies barriers to integrating opioid use disorder (OUD) and infectious disease services and recommendations to overcome those challenges.   The report notes that infectious diseases related to OUD today include human immunodeficiency virus (HIV) and hepatitis A, B, and C viruses, as well as bacterial fungal, and other infections. Barriers to integrating OUD and infectious disease prevention and treatment services include, but are not limited to, prior authorization policies, lack of data and integration sharing, inadequate workforce training, and a disconnect between the health and criminal justice systems.   “Integrating medical services—such as co-locating services, sharing a common vision, and aligning processes—is a well-recognized strategy for the delivery of comprehensive healthcare,” the report noted. “When SUD treatment is moved from a stand-alone clinic to a general medical setting, the emphasis may expand to encompass harm reduction tactics and principles, including strategies for safer drug use, minimizing risk of overdose, and preventing transmission of infectious disease.” JAMA Study Examines Comparative Effectiveness of Different Treatment Pathways for OUD New research in JAMA Network Open shows treatment with buprenorphine or methadone was associated with reductions in overdose and serious opioid-related acute care use, but only a few individuals were treated with these medications.   In the comparative effectiveness research study of 40,885 adults with OUD that compared six different treatment pathways, only treatment with buprenorphine or methadone was associated with reduced risk of overdose and serious opioid-related acute care use compared with not treatment during three and 12 months of follow-up.   “These findings suggest that opportunities exist for health plans to reduce restrictions on use for medication for opioid use disorder (MOUD) and the need for treatment models that prioritize access to and retention of MOUD treatment,” the study concluded.

Trump Administration Releases Tool to Help Rural Leaders Build Drug-Free Communities

The Trump administration has released the Rural Action Guide: Building Stronger, Healthy, Drug-Free Rural Communities, a nearly 100-page document meant to help rural community leaders build an effective, local response to addiction.   “The Rural Community Action Guide is an important tool to equip rural leaders with critical information from lessons learned on the frontlines of prevention, treatment, and recovery in rural America,” James Carroll, director of national drug control policy, wrote in the preface to the guide. “While no two rural communities are the same, there are promising practices gleaned from rural leaders in one town that can be replicated in another,” he added. “With this information, local leaders can then design a more effective strategy for deployment in their own community.”  The guide is divided into five sections: face of addiction, impact of addiction on a rural community, prevention, treatment, and recovery. SAMHSA to Host IDSUDCC Meeting on Friday, Feb. 28

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced the Interdepartmental Substance Use Disorders Coordinating Committee (ISUDCC) will meet on Friday, Feb. 28 at 9:30 a.m. ET.

Held at SAMHSA’s headquarters in Rockville, Md., the meeting is open to the public and will focus on both federal and non-federal advances to address substance use disorders.

Click here for more information.

Political Analyst Nathan L. Gonzales to Address NABH 2020 Annual Meeting Attendees

NABH is pleased to welcome Nathan Gonzales, editor and publisher of Inside Elections with Nathan L. Gonzales, as the 2020 Annual Meeting Luncheon speaker.

Inside Elections with Nathan L. Gonzales provides non-partisan analysis of campaigns for Senate, House, governor and president. Mr. Gonzales can be seen regularly on CNN discussing the latest in politics, and the New York Times, the Washington Post, the Wall Street Journal, and USA Today have all sought him out for his expertise. Mr. Gonzales will speak on Tuesday, March 17 at noon during the Annual Meeting Luncheon. Please learn more about our Annual Meeting speakers and register for the 2020 Annual Meeting if you haven’t done so already. Also, be sure to reserve your room before the hotel cut-off date on Friday, Feb. 14. We look forward to seeing you in Washington!

Fact of the Week

Only a small portion of clinicians in SAMHSA’s buprenorphine practitioner locator ultimately offered initial appointments, implying the database is only marginally useful for patients.   For questions or comments about this CEO Update, please contact Jessica Zigmond

ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan

The Office of National Drug Control Policy (ONDCP) has issued its 2020 National Drug Control Strategy (Strategy) and accompanying National Treatment Plan (NTP) that includes action items for federal agencies and external stakeholders to increase access to care and close the addiction treatment gap. The Strategy is presented using the domains of prevention, treatment and recovery, and supply-side strategies for reducing the availability and consumption of illicit drugs. These domains are established as ‘pillars’ that undergird the federal initiatives of expanding the early intervention, treatment and recovery infrastructure; improving the delivery system; and improving quality. Specifically, the NTP calls for treatment expansion and improved quality by:
  • Developing protocols for medically managed withdrawal including MAT to prevent relapse and promote stabilization;
  • Increasing emergency department use of addiction medicine specialty services;
  • Exploring the inclusion of stimulant disorder treatment in opioid treatment programs;
  • Increasing access to all medication and psychosocial services, promoting syringe exchange, interim methadone, mobile methadone vans, and peer outreach. One objective of the federal Performance and Reporting System is to make sure 100% of all specialty providers offer MAT by 2020;
  • Adopting model state specialty SUD treatment licensing laws;
  • Developing mobile and online platforms with updated information on treatment slot availability with online appointment capacity;
  • Encouraging public and private payers to cover comprehensive services and improve reimbursement rates where out-of-network rates are higher;
  • Urging providers to subsidize and provide treatment scholarships; and
  • Exploring the idea of developing national consensus standards for addiction treatment to consolidate treatment quality standards.
If you have questions about the Strategy or NTP, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.

CEO Update 87

CMS Announces Shift in Medicaid to Curb Program Spending Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma on Thursday announced a new way for states to receive a capped amount of federal dollars for part of Medicaid to help curb spending in the federal healthcare program. Called the Healthy Adult Opportunity (HAO), the new demonstration program in Medicaid would not be mandatory for states and would affect only Medicaid beneficiaries who are under age 65, not eligible for Medicaid due to a disability, and who are not eligible under a state plan. “This opportunity is designed to promote the program’s objectives while furthering its sustainability for current and future beneficiaries and achieving better health outcomes by increasing the accountability for delivering results,” Verma said in a news release. “We’ve built in strong protections for our most vulnerable beneficiaries and included opportunities for states to earn savings that have to be reinvested in strengthening the program so that it can remain a lifeline for our most vulnerable.” The agency noted in a fact sheet that states will be expected to apply certain beneficiary protections for people with HIV and behavioral health conditions, including coverage of substantially all drugs for mental health (antipsychotics and antidepressants) consistent with Medicare part D coverage, substantially all antiretroviral drugs consistent with Medicare part D, and all forms, formulations, and delivery mechanisms for drugs that the Food and Drug Administration has approved to treat opioid use disorders for which there are rebate agreements in place with the manufacturers. Click here to read Administrator Verma’s letter to state Medicaid directors about HAO.  CDC Reports U.S. Drug Overdose Death Rate Down, Opioid Overdose Death Rate Up in 2018 The age-adjusted rate of U.S. drug overdose deaths in 2018 was 4.6% lower than the rate in 2017, the Centers for Disease Control and Prevention reported Thursday. New data from the National Vital Statistics System also show there were 67,367 drug overdose deaths in the United States in 2018, 4.1% fewer than the 70,237 deaths reported in 2017. Despite the decline in overall drug overdose deaths, there was a 10% increase in the rate of drug overdose deaths involving synthetic opioids other than methadone, such as fentanyl, in 2018 compared with 2017. Furthermore, the age-adjusted rate of overdose deaths involving cocaine more than tripled from 2012 through 2018, while the rate of deaths involving certain psychostimulants, such as methamphetamine, increased nearly five-fold. The CDC also reported that decreases in life expectancy between 2014 and 2017 were driven mostly by deaths due to unintentional injuries, suicide, and Alzheimer’s disease. Improvements in life expectancy between 2017 and 2018, meanwhile, were driven by decreases in  mortality from cancer, unintentional injuries, and chronic lower respiratory diseases. The positive contributions to the change in life expectancy were offset, in part, by the rising number of deaths by suicide, chronic liver disease, and cirrhosis. Unintentional injuries and suicide remain in the top 10 leading cause of death in the United States. NABH to Participate in MAT Panel at Upcoming Opioid Management Summit Sarah Wattenberg, MSW, NABH’s director of quality and addiction services, will moderate a panel about overcoming the barriers to implementing medication assisted treatment (MAT) at the 3rd Annual Opioid Management Summit on Friday, Feb. 28 in A. The panel will include NABH members Joe Pritchard of Pinnacle Treatment Centers and Gregory Marotta of CleanSlate. Geetha Subramaniam, MD, who serves as deputy director of the Clinical Trial Network at the National Institute on Drug Abuse, and Shawn Ryan, MD, president and chief medical officer at BrightView, will round out the panel. Click here to learn more and register for the summit, which will be held at the Hilton Alexandria Mark Center in Alexandra, Va. on Feb. 27 and 28. SAMHSA Accepting Applications for Behavioral Health Clinic and CORC Grants  The Substance Abuse and Mental Health Services Administration (SAMHSA) has announced it will issue 98 grants of up to $2 million per year for up to two years for its Certified Community Behavioral Health Clinics (CCBHCs) expansion grants. The program is meant to improve the quality of community mental and substance use disorder treatment by expanding CCBHCs, which provide integrated services for individuals and families. Applications are due Tuesday, March 10. Click here to learn more and apply. SAMHSA also announced it will issue two grants of up to $850,000 for four years for its Comprehensive Opioid Recovery Centers (CORC) grants. The program is intended to operate centers that provide a full spectrum of treatment and recovery support services to address the nation’s ongoing opioid crisis. Applications are due Tuesday, March 17. Click here for more information and to apply.  HRSA Accepting Applications for 2020 Opioid-Impacted Family Support Program The Health Resources and Services Administration (HRSA) is accepting applications for its 2020 Opioid-Impacted Family Support Program (OIFSP) through April 13. OIFSP is intended to support training programs that would expand the number of peer support specialists and other behavioral healthcare-related paraprofessionals who work with integrated teams that provide services to children whose parents have opioid and other substance use disorders, as well as the family members who are in guardianship roles for those children. HRSA said it expects about $11.5 million to be available in fiscal 2020 to fund about 19 awards. Click here to learn more and apply. 2020 NABH Annual Meeting Hotel Cut-Off Date is Approaching! The cut-off date to reserve a room at the Mandarin Oriental Washington, DC for the 2020 NABH Annual Meeting is Friday Feb. 14. Please reserve your room today if you haven’t done so yet. NABH sold out its room block in 2019. And please visit our Annual Meeting homepage for registration, speaker, and preliminary program information. We look forward to seeing you in Washington! Fact of the Week  The age-adjusted rate of drug overdose deaths involving psychostimulants with abuse potential, which include drugs such as methamphetamine, amphetamine, and methylphenidate, increased from 0.2 in 1999 to 0.8 in 2012. From 2012 through 2018, the rate increased on average by 30% per year to a rate of 3.9 in 2018.      For questions or comments about this CEO Update, please contact Jessica Zigmond  

CDC Reports U.S. Drug Overdose Death Rate Down, Opioid Overdose Death Rate Up in 2018

The age-adjusted rate of U.S. drug overdose deaths in 2018 was 4.6% lower than the rate in 2017, the Centers for Disease Control and Prevention reported Thursday. New data from the National Vital Statistics System also show there were 67,367 drug overdose deaths in the United States in 2018, 4.1% fewer than the 70,237 deaths reported in 2017. Despite the decline in overall drug overdose deaths, there was a 10% increase in the rate of drug overdose deaths involving synthetic opioids other than methadone, such as fentanyl, in 2018 compared with 2017. Furthermore, the age-adjusted rate of overdose deaths involving cocaine more than tripled from 2012 through 2018, while the rate of deaths involving certain psychostimulants, such as methamphetamine, increased nearly five-fold. The CDC also reported that decreases in life expectancy between 2014 and 2017 were driven mostly by deaths due to unintentional injuries, suicide, and Alzheimer’s disease. Improvements in life expectancy between 2017 and 2018, meanwhile, were driven by decreases in  mortality from cancer, unintentional injuries, and chronic lower respiratory diseases. The positive contributions to the change in life expectancy were offset, in part, by the rising number of deaths by suicide, chronic liver disease, and cirrhosis. Unintentional injuries and suicide remain in the top ten leading cause of death in the United States.

CEO Update 86

CMS Announces New Survey and Certification Process for Psychiatric Hospitals

The Centers for Medicare & Medicaid Services (CMS) this week announced it has streamlined the process to survey the nation’s psychiatric hospitals to review for compliance with participation requirements in one comprehensive survey.   Beginning in March, CMS will send psychiatric hospitals one survey to evaluate their compliance with both general hospital and psychiatric hospital participation requirements. CMS is not making any changes to the special psychiatric Conditions of Participation (CoPs) in this process. Under this change, CMS will move the interpretive guidelines from State Operations Manual (SOM) Appendix AA, or the special psychiatric CoPs, into Appendix A, the CoPs for general hospitals. Subsequently CMS will delete Appendix AA. This change will allow CMS to issue a single survey and report to hospitals, rather than two. We appreciate CMS’ attention on the special psychiatric CoPs, which is long overdue,” NABH President and CEO Shawn Coughlin said in a news release NABH issued about the announcement. “At the same time, shifting these components into a single survey without reforming these CoPs does not provide relief to providers,” he added. “The special psychiatric CoPs are no longer appropriate in today’s environment of care. CMS should update the interpretive guidance to reflect modern methods of psychiatric services.” Click here to read the Jan. 13 announcement from CMS.

NABH Responds to CMS’ Request for Information on Reducing Administrative Burden

NABH on Friday submitted recommendations to CMS on how to reduce the administrative burden for behavioral healthcare providers. The letter to CMS Administrator Seema Verma was NABH’s response to CMS’ request for information as part of the agency’s Patients Over Paperwork initiative. In it, NABH made recommendations regarding special Conditions of Participation, B-Tags, and the Emergency Medical Treatment and Labor Act (EMTALA). “Adopting fewer burdensome requirements would benefit the healthcare system by reducing unnecessary costs and providing greater stability and predictability for providers as they navigate the regulatory environment,” NABH President and CEO Shawn Coughlin wrote in the letter. “In addition, patients would benefit as clinicians would be able to shift more of their attention, and facilities would be able to shift more of their resources, away from compliance for compliance’s sake and toward initiatives that meaningfully contribute to safe, high-quality care.”

NABH Sends Support Letter for Expanding Access to Inpatient Mental Health Act

NABH sent a letter this week to Rep. Tom Emmer (R-Minn.) supporting the Minnesota Republican’s Expanding Access to Inpatient Mental Health Act, a bill that would make changes to Medicaid’s 15-day cap for inpatient stays. In 2016 CMS changed how the Institutions for Mental Diseases (IMD) exclusion applies to managed Medicaid programs. Since then, that change has permitted Medicaid managed care states to receive payments for an enrollee in an IMD if the patient’s stay is no longer than 15 days in a month. While NABH is pleased this change has allowed thousands of new low-income patients to receive treatment, the arbitrary 15-day cap too often prevents patients from receiving the care they need if those patients lack coverage beyond 15 days. NABH strongly supports Expanding Access to Inpatient Mental Health Act because this legislation improves on the changes made in 2016 by removing the 15-day cap. Closing this coverage gap will allow patients and their treatment teams to decide on the appropriate length of stay.

NABH Welcomes NIMH Director Joshua Gordon, M.D., Ph.D. as Annual Meeting Speaker

NABH is pleased to welcome Joshua Gordon, M.D., Ph.D., director of the National Institute of Mental Health (NIMH) as an Annual Meeting keynote speaker on Tuesday, March 17 at 8:30 a.m. Gordon earned his M.D. and Ph.D. at the University of California, San Francisco, and completed his psychiatry resident and research fellowship at Columbia. He joined the Columbia faculty in 2004 as an assistant professor in the Department of Psychiatry, where he conducted research, taught residents, and maintained a general psychiatry practice. He has been director of the NIMH since September 2016. Please visit our Annual Meeting Speakers page to learn more. And please be sure to register for the Annual Meeting and reserve your hotel room if you haven’t done so yet. We look forward to seeing you in Washington!

Study Examines Relationship Between Community Care and Inpatient Services

Community care and inpatient psychiatric services are complements, not substitutes, in behavioral healthcare, according to a study published online in Psychiatric Services. Consequently, “Substantial resources should be allocated to services along a coordinated, balanced continuum of mental health care, where both psychiatric hospitals and community psychiatric services offer critical points of service,” author Isabel M. Perera wrote in the study. According to the findings, countries that provide high levels of psychiatric hospital services also tend to provide high levels of community-based care. Perera wrote that additional research is needed to examine this relationship and the mechanisms underlying it. “One hypothesis is that the hospital serves a coordinating role,” Perera wrote. “In the same way that general hospitals develop outpatient units, urgent care centers, and satellite clinics, so too do hospitals diversify their psychiatric services.”

Government Accountability Office Requests MedPAC Nominations

The Government Accountability Office (GAO) is requesting nominations for the Medicare Payment Advisory Commission, or MedPAC. GAO will accept letters of nomination and resumes until Friday, Feb. 14. NABH is pleased to help any NABH member who is interested in applying. Please contact Emily Wilkins, NABH’s administrative coordinator, if you have questions.

Save the Date: IPFQR Webinar Scheduled for Thursday, Jan. 30

CMS’ Quality Reporting Center will host a webinar for participants in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program on Thursday, Jan. 30 at 2 p.m. ET. The presentation will review updates to the latest version of the IPFQR Program Manual and optional paper tools to equip inpatient psychiatric facilities with program requirements. Click here to register.

Save the Date: O’Neill Institute’s Addiction Policy & Practice Summer Program

The O’Neill Institute for National and Global Health Law and Georgetown University’s Graduate School of Arts and Sciences will host an Addiction Policy & Practice Summer Program from June 10-12, 2020 at Georgetown University. The program will bring together policymakers, advocates, journalists, and academics to examine different aspects of drug law and policy, and topics will range from adverse childhood experiences and substance use disorders to international development and supply-reduction strategies. A detailed agenda and registration information will be available in February.

Fact of the Week

Persons with psychiatric disorders were approximately 3 to 4 times more likely than their siblings without psychiatric disorders to be either subjected to violence or to perpetrate violence.   For questions or comments about this CEO Update, please contact Jessica Zigmond

NABH Comments on CMS’ New Survey and Certification Process for Psychiatric Hospitals

WASHINGTONJan. 13, 2020 /PRNewswire/ — The Centers for Medicare & Medicaid Services (CMS) on Monday announced it has streamlined the process to survey the nation’s psychiatric hospitals to review for compliance with participation requirements in one comprehensive survey. Beginning in March, CMS will send psychiatric hospitals one survey to evaluate their compliance with both general hospital and psychiatric hospital participation requirements. CMS is not making any changes to the special psychiatric Conditions of Participation (CoPs) in this process. Under this change, CMS will move the interpretive guidelines from State Operations Manual (SOM) Appendix AA, or the special psychiatric CoPs, into Appendix A, the CoPs for general hospitals. Subsequently CMS will delete Appendix AA. This change will allow CMS to issue a single survey and report to hospitals, rather than two. Read more here

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CMS Releases Fact Sheet for Medicare-Enrolled OTPs The Centers for Medicare & Medicaid Services (CMS) has released an 18-page fact sheet about Medicare billing and payment for opioid treatment programs (OTPs) that participate in the federal program. CMS began paying for enrolled OTPs to deliver opioid use disorder (OUD) treatment services to Medicare beneficiaries on Jan. 1. The fact sheet includes information about a host of issues, including covered OUD treatment services, enrollment in Medicare Electronic Data Interchange, Medicare beneficiary eligibility, claims services, payment and remittance advice, payment issues, and other resources. The agency is now accepting and processing OTP enrollment applications. For more information, review the Medicare enrollment fact sheet. IPFQR Program Manual Version 5.1 Now Available CMS announced this week that the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program Manual version 5.1 and the Release Notes version 5.1 are now available. The manual, which provides an overview of the IPFQR program and measure specifications, offers detailed instructions to register on the QualityNet Secure Portal; submit data using the web-based measures application; and understand IPFQR program preview report processes. CMS also issued the Release Notes version 5.1, which describes changes to the manual compared with the previous version. These resources are available on the Quality Reporting Center’s IPFQR Program Resources and Tools webpage. MACPAC Releases Report to Congress on Oversight of IMDs Fulfilling a SUPPORT Act requirement, the Medicaid and CHIP Payment and Access Commission (MACPAC) has released its report to Congress on the oversight of Institutions for Mental Diseases (IMDs). “The IMD exclusion is one of the few instances in Medicaid where federal funding is not available for covered services based on the setting in which they are provided,” MACPAC noted in the 128-page overview. “It is important to note that, despite this longstanding payment exclusion, there are several other Medicaid authorities that states are using to make Medicaid payments for services provided in IMDs.” There were no recommendations in the report, which is intended instead to identify and describe IMDs in selected states—California, Colorado, Florida, Massachusetts, New Jersey, Ohio, and Texas—and provide a summary of state licensure, certification, or accreditation requirements, and Medicaid clinical and quality standards. Organized by five chapters, the report examines the history and federal policies related to the IMD exclusion, services provided in IMDs, regulation of facilities that are subject to the IMD exclusion, Medicaid standards for behavioral health facilities, and protections for patients in those facilities. SAMHSA Accepting Applications for Mental Health Grants The Substance Abuse and Mental Health Services Administration (SAMHSA) is accepting grant applications for programs that would address suicide prevention as well as planning and development to promote the mental health of children, youth, and families in American Indian/Alaska Natives (AI/AN) communities. SAMHSA plans to issue one grant of up to about $7.6 million each year for up to five years for its Suicide Prevention Resource Center grant. This program is intended to build national capacity for preventing suicide by providing technical assistance, training, and resources to assist states, tribes, communities, providers, practitioners, and members of the public on suicide-prevention strategies and best practices. The agency is also accepting applications for its Circles of Care grants, which would provide tribal and urban Indian communities with tools and resources to plan and design a holistic, evidence and community-based, coordinated system of care to support mental health for children, youth, and families in AI/AN communications. SAMHSA said it plans to issue 17 grants of up to $310,000 each year for up to three years. Grant applications for both programs are due by Monday, March 9. Click here for more information.  Nearly 60% of Rural Americans Say Opioid Addiction is a ‘Serious Problem’ in Their Community Almost 60% of Americans living in rural areas said opioid addiction is a “serious problem” in their community, according to a JAMA study published this week. The study examined the views of U.S. rural adults on serious health and economic concerns and found that 57% of rural adults reported opioid or other drug addiction or abuse as a serious problem in their community, while 49% of rural adults said they personally know someone who has died of an opioid addiction. “These findings suggest that in today’s economically stretched rural United States, opioid or other drug addiction or abuse has emerged as an equal problem with economic concerns,” researchers from Harvard and the Robert Wood Johnson Foundation noted in the study’s conclusion. “One in three rural adults still have problems paying their medical bills even after the passage and implementation of the Patient Protection and Affordable Care Act.” View the 2020 Annual Meeting Preliminary Program and Register Today! The NABH 2020 Annual Meeting preliminary program is now available online. Please take a moment to view the program and register for the meeting. NABH will update the preliminary program periodically with session and speaker information, and all attendees will receive a final printed program at the Annual Meeting on Monday, March 16. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC. We look forward to seeing you in March! Final Call to Update Your NABH Membership Information! NABH is preparing the association’s 2020 Membership Directory. If you did not submit your updates by the Jan. 9 deadline, please contact Emily Wilkins, NABH’s administrative coordinator, at emily@nabh.org. Thank you for your cooperation!  Fact of the Week Adults with mental health issues were 24% less likely overall to get screened for cancer compared with the general population. For questions or comments about this CEO Update, please contact Jessica Zigmond.

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Congress Agrees to $5.9 Billion for SAMHSA in FY 2020 Spending Bill Package

Federal lawmakers this week agreed to fund the Substance Abuse and Mental Health Services Administration (SAMHSA) at $5.9 billion in fiscal year (FY) 2020, $140 million above the 2019 enacted level and $205 million above the president’s budget request. The funding is part of the two legislative packages that include all 12 FY 2020 funding bills, which the House passed on Tuesday, Dec. 17. The Senate is scheduled to vote on the spending bills Friday. SAMHSA’s funding included $3.8 billion for substance abuse treatment, $206 million for substance abuse prevention, $16 million for suicide prevention, $19 million for the Suicide Lifeline, and an increase in funding for mental health resources for children. President Trump is expected to sign the full funding package.

NABH Participates in White House Mental Health Summit

NABH participated in the White House Mental Health Summit on Dec. 19, where President Trump underscored his administration’s commitment to addressing serious mental illness in the United States. Shawn Coughlin, NABH’s executive vice president for government relations and public policy, and Scott Dziengelski, director of policy and regulation, attended the summit, where attendees heard from HHS Secretary Alex Azar and SAMHSA Assistant Secretary Ellie McCance-Katz moderated a panel discussion with mental health advocates about the need for reform. NABH also submitted questions, and part of the discussion centered on Medicaid’s Institution for Mental Diseases (IMD) exclusion.

NABH Calls on Congress to Examine Insurers and Parity Following GAO Report 

NABH this week called on Congress to hold oversight hearings to examine whether the nation’s insurers are complying with parity following the release of a Government Accountability Office (GAO) report on Dec. 13. The GAO’s 67-page report evaluated the practices, policies, and guidance from the U.S. Health and Human Services (HHS) and the U.S. Labor Department (DOL), the two federal offices that oversee compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. In its review, GAO found that both HHS and DOL “conduct targeted reviews of certain employer-sponsored group plans when they receive information—such as consumer complaints—about possible noncompliance with MH/SU parity requirements or other federal healthcare requirements.” Consequently, NABH is urging federal lawmakers to hold congressional hearings early in the New Year to study the issue and learn more. “For years, NABH has heard from our members—who receive complaints from patients and withstand parity violations every day—that the current compliance process is woefully inadequate to determine whether health plans are following the law,” NABH’s Shawn Coughlin said in a news release. “This is unacceptable.”

CMS Releases Informational Bulletin on Dual Eligibles Receiving OTP Services 

The Centers for Medicare & Medicaid Services (CMS) this week released an Informational Bulletin that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services. Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time. To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved. CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare.

Federal Survey Shows Adolescent Marijuana Vaping Surged in 2019

The latest Monitoring the Future survey showed that increases in adolescent marijuana vaping from 2018 to 2019 ranked among the largest single-year increases the survey has observed in the past 45 years among all outcomes measured. In 2019, the percentage of adolescents who had vaped in the last 12 months was 21% in 12th grade, 19% in 10th grade, and 7% in 8th grade. Nicotine vaping also increased, as the survey showed 35% of 12th graders reported vaping nicotine in the last 12 months, an increase of 5.6 points from 2018. Similarly, 31% of 10th graders reported vaping nicotine in the last year, reflecting an increase of 6.1 percentage points from 2018. Also this week, SAMHSA released Substance Misuse Prevention for Young Adults, a guide to help healthcare providers, systems, and communities prevent substance misuse among young adults.

CMS Announces $50 Million in Funding to 10 States for Maternal Opioid Misuse Model

CMS on Thursday said 10 states will receive a total of $50 million over five years funding under the Maternal Opioid Misuse, or MOM, model to help pregnant and postpartum Medicaid beneficiaries with opioid use disorder. Colorado, Indiana, Louisiana, Maine, Maryland, Missouri, New Hampshire, Tennessee, Texas, and West Virginia were granted the awards, which they will use to transition into the model of care and then implement their plans. Click here to learn more.

New JAMA Study Shows Most Opioid Deaths Are Accidental; 4% Are Suicide

Accidental overdoses cause 90% of all U.S. opioid-related deaths while suicides account for 4% of all opioid-related deaths, according to a new study published in JAMA this week. In 2017, opioid-related deaths totaled about 47,500 and included 43,000 accidental deaths and 1,880 suicides. The cause of about 2,590 deaths could not be determined. Government researchers analyzed death certificates for people aged 15 and older, and the findings contrast with a 2018 article in the New England Journal of Medicine that estimated—based on emergency department data—that at least 20% to 30% of those deaths had been suicides. Understanding that most overdoses are accidental “puts the primary focus of care more squarely on the patient’s addiction,” although physicians should still evaluate their mental health, too, Dr. Mark Olfson, a psychiatrist at Columbia University and co-author of the study, told the Associated Press in a story about the analysis.

Please Update Your NABH Member Information Today!

NABH is preparing the association’s 2020 Membership Directory and asks all members to provide the most up-to-date information on their organizations. To help ensure we have the most accurate data on our members, please contact Emily Wilkins, NABH’s administrative coordinator, at emily@nabh.org for a personalized link to enter information about your organization’s facilities. The deadline to submit your information to NABH is Thursday, Jan. 9.

Register Today for the 2020 NABH Annual Meeting!

This week NABH sent members and Annual Meeting attendees the first in a series of weekly alerts about the 2020 Annual Meeting. Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance, learn about our speakers, and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020.   NABH will post the Annual Meeting’s online preliminary program in January. We look forward to seeing you in Washington!

Fact of the Week

Among U.S. 12th graders, the prevalence of marijuana vaping increased 7.7 percentage points in 2019, reflecting the second largest increase in 12-month substance use ever recorded in this grade.

Happy Holidays from NABH!

NABH will not publish CEO Update for the next two weeks and will resume on Friday, Jan. 10. The entire NABH team wishes you and your families a very happy holiday season!   For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Urges Oversight Hearings on Parity Following GAO Report

WASHINGTONDec. 18, 2019 /PRNewswire/ — A key finding in a new Government Accountability Office (GAO) report on government oversight of compliance with parity underscores the need for federal lawmakers to proactively investigate the work of employer-sponsored group plans and ensure they are complying with the landmark 2008 parity law. Late last week, GAO released a 67-page report that examined and evaluated the practices, policies, and guidance from the U.S. Health and Human Services (HHS) Department and the U.S. Labor Department (DOL), the two federal offices that oversee compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Read more at PR Newswire  

CMS Releases Guidance on Coverage Transition for ‘Dual Eligibles’ Receiving OTP Services

The Centers for Medicare & Medicaid Services (CMS) released an Informational Bulletin on Tuesday that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services. Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time. To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved. CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare. If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.

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White House to Host Mental Health Summit Next Week

The White House will host a mental health summit next week that is expected to highlight mass shootings in the United States. NABH staff will attend the summit, where mental health advocates, government officials, and other experts will discuss a host of other behavioral healthcare issues, including teen suicide, workforce issues, and low reimbursement rates for healthcare providers, according to news reports. The White House has not indicated whether President Trump will attend or if his administration will introduce any policy proposals. President Trump had proposed steps to address gun violence in the United States following the shootings in Dayton, Ohio and El Paso, Texas in August.

CDC Requests Priority Topics for Community Preventive Services Task Force

The Centers for Disease Control and Prevention (CDC) is seeking public comment to identify important public health topics that will form the basis of the Community Preventive Services Task Force’s (CPSTF) evidence-based recommendations. According to CDC’s notice in the Federal Register, the agency will use this information to support the CPSTF as it selects priority topics for the next five years. CDC will accept all written comments on or before Thursday, Jan. 23, 2020.

Please Update Your NABH Member Information Today!

Last week, all System Members received a link to update their System’s information. NABH is preparing the association’s 2020 Membership Directory and requests that all System members provide the most up-to-date information on their organizations. To help ensure we have the most accurate data on our members, please contact Emily Wilkins, NABH’s administrative coordinator, at emily@nabh.org for a personalized link to enter information about your organization’s facilities. The deadline to submit your information to NABH is Thursday, Jan. 9. As always, thank you for your time and for all you do to provide quality behavioral healthcare to those who need it most.

NABH Annual Meeting Exhibitor & Sponsor Information Now Available

General information, tips, and shipping details for exhibitors and sponsors at the 2020 Annual Meeting are now available on the association’s Annual Meeting homepage. Also, starting next week, NABH will send Annual Meeting Alerts to keep members, exhibitors, sponsors, and other attendees apprised of details about the meeting. If you haven’t done so yet, please visit the Annual Meeting homepage to register for the meeting and reserve your hotel room. We look forward to seeing you in March!

Fact of the Week

In 2017, 17.2% of behavioral office visits were to an out-of-network provider compared with 3.2% for primary care providers and 4.3% for medical/surgical specialists.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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Hospital Associations Sue Trump Administration to Block Price-Transparency Rule

Hospital groups sued the Trump administration this week over a new rule that would require hospitals to disclose their negotiated rates with insurers. The American Hospital Association, Federation of American Hospitals, Association of American Medical Colleges, and other groups sued HHS over the rule the department released in November as part of the Trump administration’s efforts to make healthcare markets more transparent to patients. Hospital groups argue that the rule—which would take effect in 2021—violates their First Amendment rights. “We make the case that the burden placed on our members to come up with this information is extensive,” Tom Nickels, executive vice president with the American Hospital Association, told The New York Times.

Buprenorphine Providers in Rural Areas Increase More Than 100% Since 2016

From 2016 to 2019, the number of waivered clinicians who prescribed buprenorphine per 100,000 population in rural areas increased by 111%, according to a study published this week in Health Affairs. As the article notes, the Comprehensive Addiction and Recovery Act in 2017 enabled nurse practitioners (NPs) and physician assistants (PAs) to obtain federal waivers that would allow them to prescribe buprenorphine, a medication that is used to treat opioid use disorder. The waiver expansion was meant to increase patients’ access to opioid use treatment, which was especially important in rural areas with few physicians. Researchers noted that NPs and PAs accounted for more than half of the increase and were the first waivered clinicians in 285 rural counties with 5.7 million residents. “The rapid growth in the numbers of NPs and PAs with buprenorphine waivers is a promising development in improving access to addiction treatment in rural areas,” the study said.

SAMHSA Applications for Community Services Program Grant Due Dec. 23

SAMHSA is accepting applications for its Recovery Community Services Program to provide peer recovery support services through recovery community organizations to individuals with substance use disorders or co-occurring substance use and mental health disorders. The agency said it plans to issue six grants of up to $300,000 per year for up to five years. Applications are due by Monday, Dec. 23. Click here to learn more and to register.

Register Today for the 2020 NABH Annual Meeting!

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance, learn about our speakers, and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

Primary care reimbursements were 23.8% higher than behavioral health reimbursements as of 2017, which is an increase from 20.8% higher in 2015. For questions or comments about this CEO Update, please contact Jessica Zigmond.

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FCC Chairman Proposes ‘988’ for National Suicide Prevention Hotline

Federal Communications Commission Chairman (FCC) Ajit Pai this week proposed rulemaking to establish 988 as a new, nationwide, three-digit phone number for a suicide prevention and mental health hotline. “The suicide rate in the United States is at its highest level since World War II and designating 988 as the suicide prevention and mental health hotline would be a major boost for our nation’s suicide prevention efforts,” Pai said at an event with federal agency partners on Nov. 19. “When it comes to saving lives, time is of the essence, and we believe that 988 can be activated more quickly than other possible three-digit codes,” he said, adding that 988 also “has an echo of the 911 number” that is universally recognized as an emergency number. In early June, NABH sent a letter to the FCC asking the agency to immediately repurpose a nationwide, three-digit phone number for suicide prevention. The Commission will vote on Pai’s proposal at its public meeting on Thursday, Dec. 12.

National Action Alliance for Suicide Prevention Releases ‘Best Practices in Care Transitions’

The National Action Alliance for Suicide Prevention has released Best Practices in Care Transitions for Individuals with Suicide Risk: Inpatient Care to Outpatient Care, a 25-page report intended to help health systems and providers close gaps in care, improve patient experience and outcomes, and prevent suicide deaths. Research shows that in the month after patients leave inpatient psychiatric care, their suicide death rate is 300 times higher in the first week and 200 times higher in the first month than in the general population, but nearly a third of these patients do not make it to outpatient care in this timeframe. The report aims to advance two goals of the Action Alliance’s National Strategy for Suicide Prevention: promote suicide prevention as a core component of healthcare, and promote and implement effective clinical and professional practices for assessing and treating those identified as being at risk for suicidal behaviors.

Milliman Disparities Report Highlights Need for NABH’s Access to Care Initiative

A report this week from Milliman, Inc. about disparities between physical and behavioral healthcare for both in-network access and provider reimbursement rates underscores NABH’s position that unnecessary barriers continue to deny access to behavioral healthcare for patients who need it. The Bowman Family Foundation commissioned Milliman to produce Addiction and Mental Health vs. Physical Health: Widening disparities in network use and provider reimbursement, a 140-page report that shows the gap in disparities for employees and their families seeking mental health and addiction treatment versus treatment for physical health conditions widened in 2016 and 2017. According to the report, inpatient out-of-network use for behavioral health was over five times more likely than for medical/surgical services, worsening from 2.8 times more likely in 2013 to 5.2 times more likely in 2017, reflecting an 85% increase in disparities over five years. Meanwhile, office visit disparities were already five times higher in 2013 and worsened to 5.4 times in 2017, the report said. In news releases from both Milliman and NABH, Mark Covall said the report’s findings emphasize what NABH members have said for years: unfair managed care practices too often create barriers for patients to access the care they need. Earlier this year, NABH launched its Access to Care initiative to inform policymakers, the media, patient advocates, and the general public about two major challenges—unjust managed care practices and countless regulations—that prevent behavioral healthcare providers from providing a full range of services to patients.

CMS Announces Reorganization to Improve Regional Office Functions and Structure

The Centers for Medicare & Medicaid Services (CMS) this week announced a host of changes to its regional office structure as part of the agency’s earlier-announced Modernizing CMS Strategic Initiative. Among the changes is a plan to bring together staff, regardless of their location, who work on quality improvement and who survey facility quality and safety as a way to ensure consistency. Another program change will combine the regionally based Medicare operations work, the local oversight of the federally facilitated exchange plans, and external affairs into a single office that reports directly to the Office of the Administrator by creating the Office of Program Operations and Local Engagement, or OPLE. CMS also said it will position the Medicaid program to better serve stakeholders by creating centers of excellence. The announcement will be published in the Federal Register on Monday, Nov. 25.

SAMHSA to Host Webinar on National Agenda for Behavioral Health in Youth Next Week

The Substance Abuse and Mental Health Services Administration (SAMHSA) will host a webinar titled Fostering Healthy Mental, Emotional, and Behavioral Health in Children and Youth: A National Agenda next Tuesday, Nov. 26 at 6 p.m. ET. The webinar will provide an overview of the newly released National Academies of Sciences, Engineering, and Medicine’s consensus report on this topic and will feature contributors to the report. They will recommend how to leverage the research to create a national agenda where children and youth thrive. The previous report on this topic was released 10 years ago. Click here to learn more about the webinar and here to register.

SAMHSA Applications for Community Services Program Grant Due Dec. 23

SAMHSA is accepting applications for its Recovery Community Services Program to provide peer recovery support services through recovery community organizations to individuals with substance use disorders or co-occurring substance use and mental health disorders. The agency said it plans to issue six grants of up to $300,000 per year for up to five years. Applications are due by Monday, Dec. 23. Click here to learn more and to register.

Register Today for the 2020 NABH Annual Meeting!

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance, learn about our speakers, and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

In 2017, a child’s out-of-network office visit for behavioral healthcare was 10.1 times more likely than for an out-of-network primary care office visit, which was more than twice the disparity seen for adults.

Happy Thanksgiving from NABH!

NABH’s office will be closed next Thursday, Nov. 28 and Friday, Nov. 29 for Thanksgiving.  CEO Update will resume on Friday, Dec. 6. The NABH staff wishes its members and their families a very happy Thanksgiving! For questions or comments about this CEO Update, please contact Jessica Zigmond.

Milliman Report Highlights Barriers to Accessing Behavioral Healthcare Services

WASHINGTONNov. 20, 2019 /PRNewswire/ — A report from Milliman, Inc. about disparities between physical and behavioral healthcare for both in-network access and provider reimbursement rates underscores NABH’s position that unnecessary barriers continue to deny access to behavioral healthcare for patients who need it. The Bowman Family Foundation commissioned Milliman to produce Addiction and Mental Health vs. Physical Health: Widening disparities in network use and provider reimbursement, a 140-page report that shows the gap in disparities for employees and their families seeking mental health and addiction treatment versus treatment for physical health conditions widened in 2016 and 2017. Read more at PR Newswire  

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2.2 Million Kids Impacted by the Opioid Crisis

2.2 million children experienced neonatal withdrawal, entered foster care, or were addicted to opioids themselves in 2017, according to a new report from the United Hospital Fund. The report found that 54 out of 1,000 children in West Virginia were impacted by the opioid crisis and 20 out of 1,000 children in California. If the course of the opioid crisis is not changed, the report concluded that by 2030, there will be 4.3 million children affected annually. “Increase the availability of family-based mental health services” was among the proposed strategies to help kids.

New Price Transparency Rule for Hospitals

Today the Centers for Medicare and Medicaid Services (CMS) issued new rules, effective January 2021, requiring facilities to disclose rates negotiated with insurers; what the hospital is willing to accept in cash from a patient, and the minimum and maximum negotiated charges. NABH commented in September on the proposed changes and questioned CMS’ legal authority to make these changes. Shortly following the rule, the American Hospital Association, the Federation of American Hospitals, Association of American Medical Colleges and the Children’s Hospital Association announced they intend to challenge the new rule in court.

CMS Proposes Regulations on Fiscal Integrity in Medicaid

CMS has proposed a Medicaid Fiscal Accountability Rule (MFAR) that focuses on eliminating impermissible financing arrangements. CMS stated in a press release that the “proposed rule aims to strengthen accountability, increase transparency of Medicaid payments, and improve program integrity to ensure the Medicaid program is sustainable for future generations.” Singled out in the proposal are “states that generate extra payments for private nursing facilities that enter into arrangements with local governments to bypass tax and donation rules, and the use of a loophole to tax managed care entities 25 times higher for Medicaid business than for similar commercial business. States can then use that tax revenue to generate additional payments, with no commiserate increase in state spending.” NABH is planning to submit comments on the proposal.

White House Meeting on “Addressing Overdose and Response at Colleges and Universities”

Sarah Wattenberg, NABH Director of Quality and Addiction Services, moderated a panel at the White House Office of National Drug Control Policy’s meeting, ‘Addressing Overdose and Response at Colleges and Universities.’ The panel focused on federal privacy laws that operate on campuses, which protect students’ privacy but will allow campus officials to inform parents and others when necessary. Panelists included HHS Assistant Secretary for Mental Health and Substance Use, Elinore F. McCance-Katz M.D. P.H.D, who spoke about the prevalence of mental health and substance use on campuses, and clarified that the substance abuse confidentiality law (42 CFR Part 2) did not typically apply to campus health care. Deputy Assistant Secretary for Higher Education Programs, Chris McCaghren, from the Department of Education, discussed how the Family Educational Rights and Privacy Act (FERPA) applies to student education and treatment records. He emphasized the importance of training all staff on how the law worked.

CMS Issues Final OTP Rule

CMS issued the final regulation on the CY2020 Physician Fee Schedule, which included detailed information about Medicare Enrollment for Opioid Treatment Programs (OTPs). OTPs that enroll may begin billing January 2020. NABH released an NABH Analysis that provides a summary of those provisions, which provide for the treatment of opioid use disorders with new bundled service codes for OTPs, and for telehealth and opioid use treatment services in office-based settings.

Senate Hearing on Alzheimer’s Awareness

NABH PAC Champions Senators Patrick Toomey (R-PA) and Debbie Stabenow (D-MI) will be holding a hearing next week on Alzheimer’s Disease. Witnesses for the hearing include Jason Karlawish, MD the Co-Director of the Penn Memory Center University of Pennsylvania; Janet Tomcavage, Chief Nursing Executive at Geisinger; Marc A. Cohen, Ph.D, Professor Research Director at the Center For Consumer Engagement In Health Innovation UMass Boston and Community Catalyst; and Lauren Kovach, and Alzheimer’s advocate from Brighton , MI.

Register Today for the 2020 NABH Annual Meeting!

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

The opioid crisis has contributed to the decline in U.S. overall life expectancy for 3 consecutive years; the first 3 year-on-year decline in U.S. life expectancy since the 1918 flu pandemic. For questions or comments about the Nov. 15 edition of CEO Update, please contact Scott Dziengelski.

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CMS Finalizes OTP Provisions in 2020 Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) finalized provisions for the nation’s opioid treatment programs (OTPs) in the 2020 Physician Fee Schedule regulation that the agency released on Nov. 1. NABH released an NABH Analysis that provides a summary of those provisions, which provide for the treatment of opioid use disorders with new bundled service codes for OTPs, and for telehealth and opioid use treatment services in office-based settings. The final rule will be published in the Federal Register on Nov. 15.

CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with AT Lease One SUD

CMS this week released guidance to state Medicaid directors that clarifies how section 5052 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act permits institutions for mental diseases (IMDs) to provide treatment to Medicaid beneficiaries with at least one substance use disorder (SUD). NABH released an NABH Issue Brief that summarizes the following five key areas that the CMS guidance focuses on: requirement for beneficiaries, requirements for IMDs, requirements for states, maintenance of effort, and interaction with existing IMD policies.

CDC Says Efforts to Prevent Adverse Childhood Experiences Could Potentially Prevent Adult Chronic Conditions

A new Vital Signs report from the Centers for Disease Control and Prevention (CDC) this week found that efforts to prevent adverse childhood experiences could also potentially prevent adult chronic conditions, depression, health risk behaviors, and negative socioeconomic outcomes. According to the CDC, nearly one in six adults in the study population (15.6 percent) reported four or more types of adverse childhood experiences, which were significantly associated with poorer health outcomes, health risk behavioral, and socioeconomic challenges. Meanwhile, nearly 61 percent of adults experienced at least one adverse childhood experience. Women, American Indian/Alaska Native, blacks, and the racial/ethnic group categorized as “Other” were more likely to experience four or more types of adverse childhood experiences than were men and whites, the report noted. In addition, younger adults reported exposure to more adverse childhood experience types than did other adults, particularly those aged 65 or older. “States can use comprehensive public health approaches derived from the best available evidence to prevent childhood adversity before it begins,” the Vital Signs report said. “By creating the conditions for healthy communities and focusing on primary prevention, it is possible to reduce risk for adverse childhood experiences while also mitigating consequences for those already affected by these experiences.”

JAMA Reports Cost-Sharing from Out-of-Network Care Among Those with Behavioral Health Conditions was Higher than Payments for Physical Conditions 

A study in JAMA this week reported that cost-sharing from out-of-network (OON) care among people with behavioral health conditions was significantly higher than for those with other prevalent chronic physical conditions. Researchers analyzed a large commercial claims database from 2012 to 2017 that included adults with mental health conditions, with alcohol disorders, with drug use disorders, with congestive heart failure, and with diabetes who were between the ages of 18 and 64 and enrolled in employer-sponsored insurance plans. “Although the parity law has improved access to OON care for patients covered by private insurance, obtaining care from OON providers can come with a price,” the study noted. “Steeper cost-sharing payments, such as higher deductibles and higher coinsurance rates, are typically required for care from OON providers,” it continued. “Although the maximum annual out-of-pocket cost-sharing in private plans is capped under the Patient Protection and Affordable Care Act, this cap applies only to in-network healthcare.”

World Congress to Host Opioid Management Summit in February 

SAMHSA is accepting applications for fiscal year 2020 Promoting Integration of Primary and Behavioral Healthcare (PIPHC) grants until Tuesday, Dec. 10. The program’s purpose is to promote full integration and collaboration in clinical practice between primary and behavioral healthcare, support integrated care models and improve the overall wellness and health of adults with serious mental illness or children with serious emotional disturbance, and promote and offer integrated care services related to screening, diagnosis, prevention, and treatment of mental and substance use disorders and co-occurring physical health conditions and chronic diseases.

Political Analyst Nathan Gonzales to Address Attendees at NABH Annual Meeting Luncheon 

NABH is pleased to announce Nathan Gonzales, editor and publisher of Inside Elections with Nathan L. Gonzales—which provides non-partisan analysis of U.S. political campaigns—will serve as the 2020 Annual Meeting Luncheon speaker. Members can learn more about Mr. Gonzales and NABH’s other featured speakers—folk singer Judy Collins and neuroscientist and psychiatrist Tom Insel—in the Speakers section of our Annual Meeting homepage. Please visit NABH’s Annual Meeting homepage today to register for the meeting and make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020.   We look forward to seeing you next March! Fact of the Week The journal Pediatrics reports that 20 percent of U.S. children live in counties without a child psychiatrist.

NABH Analysis: OTP Provisions in 2020 Physician Fee Schedule

OTP Provisions in 2020 Physician Fee Schedule

CMS finalized provisions for the nation’s opioid treatment programs (OTPs) in the 2020 Physician Fee Schedule regulation that the agency released on Nov. 1. This NABH Analysis provides a summary of those provisions, which provide for the treatment of opioid use disorders (OUDs) with new bundled service codes for OTPs, and for telehealth and opioid use treatment services in office-based settings. The final rule will be published in the Federal Register on Nov. 15. The regulations implement requirements that were included in last year’s Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act. NABH is pleased that the final rule addressed the following issues that NABH mentioned in its comment letter on Sept. 28:
  • CMS raised the non-drug bundle to 161.71, which aligns with NABH’s valuation. We used a building block methodology to demonstrate that the proposed non-drug bundle, based on the CMS PFS rates, was undervalued by 31-48 percent.
  • We also identified a range of indirect and direct services routinely performed by OTPs that CMS included in the final bundle.
  • NABH advocated for the elimination of the partial bundle and recommended a more gradual overall implementation of elements of the proposed rule. In the final rule, CMS temporarily eliminated the partial episode of care with the intent to engage in future rulemaking to more gradually phase in their bundled approach.
  • Comments and data were provided to CMS reflecting potential destabilization of the workforce relevant to the proposed service requirements. CMS addressed these issues through deference to state laws and scopes of service provisions, and a reduction of the number of services needed to bill the bundle.
  • In explanatory text, CMS made note of the NABH recommendation for a rural add-on rate of 17 percent and indicated it may be considered in future rulemaking to incentivize rural care.
  • NABH recommended consideration to permanently set a zero co-pay, and CMS indicated the intent to address the issue in future rulemaking.
  • We advocated to remove OTPs from the high-risk category. CMS finalized a compromise proposal that moves OTPs that have been fully and continuously certified by SAMSA since October 23, 2018 to moderate risk, while maintaining those without full and continuous certification in the high-level risk category, as they are newly-recognized Medicare providers.
  • NABH-supported telehealth codes were finalized.
  Final Rule Highlights: Opioid Treatment Programs
  • Definition of OUD Treatment Services
    • FDA-approved opioid agonist and antagonist treatment medications
    • Dispensing and administering of such medications (if applicable)
    • Substance use counseling
    • Individual and group therapy
    • Toxicology testing (both presumptive and definitive testing)
    • Intake activities
    • Periodic assessments
  • Bundled Rates/Episode of Care
    • Bundles reflect a weekly episode of care with no time limits.
    • Rates are a combination of a drug and non-drug component.
    • Full and partial episode construction was finalized to eliminate of partial episodes of care. Utilization will be monitored, intent is to create a partial bundle in the future.
    • One service must be furnished within a week to bill a weekly drug or non-drug bundle.
  • Drug component reflects drug dispensing/administration services; rates vary according to the specific drug (methadone-oral, buprenorphine-oral, buprenorphine-injection, buprenorphine-implant, naltrexone injection), and includes buprenorphine-only products.
    • Maintenance dosage and calculation for oral buprenorphine was increased from 10 mg to 16 mg daily.
    • Created an NOS code for new medications.
  • Non-drug component includes counseling, psychotherapy, toxicology testing and tracks with SAMHSA certification.
    • Does not require counseling and psychotherapy but defers to medical need and state laws relevant to scopes of practice.
    • Case/care management is not included as a bundled or add-on code. Intent to collaborate with OTPs to better understand services, with potential future rulemaking.
    • Rates were increased using building block methodology that values the services based on established Medicare PFS (non-facility) rates for similar services; the Medicare Clinical Laboratory Fee Schedule (CLFS); and state Medicaid programs.
    • Bundles include payment for presumptive and definitive drug testing, with no separate billing under CLFS. There is no add-on code in order to avoid incentive to test more frequently than needed.
  • Add-ons
    • Intake activities for new patients, including a physical examination
    • Periodic assessments during an episode of care, such as for pregnant or postpartum patients
    • Take homes for methadone/buprenorphine for up to 7 days of medication
    • Counseling 30-minutes when counseling or therapy substantially exceed the amount in the individual treatment plan
PFS Bundles for Office-based Services/Telehealth
  • Bundled Rates/Episode of Care
    • Codes for three new (monthly) OUD treatment bundles have been added to the telehealth list on a Category 1 basis for care coordination, individual and group therapy, and counseling through two-way interactive audio-video communication technology.
      • G2086, 70-minute psychotherapy, first month. Includes treatment planning, care coordination, individual and group psychotherapy and counseling
      • G2087, 60-minute psychotherapy, subsequent months. Includes care coordination individual and group psychotherapy and counseling
      • G2088, for each additional 30-minute service required beyond 120 minutes. Includes care coordination, individual and group psychotherapy, and counseling
    • To bill G2086 and G2087, one psychotherapy services must be furnished.
    • If no therapy is provided, the bundle may not be billed. Instead, existing CPT codes for care management 99484, 99492, 99493, 99494 and E/M codes may be used.
    • Psychotherapy codes 90832, 90834, 90837, 90853 may not be used by the same practitioner for the same beneficiary in same month that episode bundles are billed.
    • Rates do not include medications, as they are reimbursed under Medicare Part B or D or toxicology testing that is billed under CLFS.
    • Provider must be licensed in the jurisdiction/location of the patient.
    • The codes are not restricted to use by addiction specialists.
    • Additional telehealth services may be requested before February 10, 2020 for consideration for the following calendar year.
    • The rule notes the prior removal of geographic limitations for telehealth services for SUD or co-occurring mental health disorders.
    • The SUPPORT ACT permits services to be furnished at any originating site, including the patient’s home, and requires that no originating site facility fee is permitted when the individual’s home is the originating site.
    • OTP services are not considered physician/practitioner services, and as such may not bill these codes. Instead, services are covered through OTP bundled rates.
NABH will closely monitor and work with CMS and other stakeholders in the implementation of this benefit and provide updates to NABH members as necessary. If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.

NABH Issue Brief: CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD

CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD The Centers for Medicare & Medicaid Services (CMS) on Wednesday released guidance to state Medicaid directors that clarifies how section 5052 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act permits institutions for mental diseases (IMDs) to provide treatment to Medicaid beneficiaries with at least one substance use disorder (SUD). NABH was a driving force behind section 5052 becoming law and the NABH team has talked with CMS staff about the law’s implementation. The guidance from CMS covers five key areas: requirements for beneficiaries, requirements for IMDs, requirements for states, maintenance of effort, and interaction with existing IMD policies. This NABH Issue Brief provides a summary of each of those areas.

Requirements for Beneficiaries

An eligible individual for section 5052 (the new IMD authority) is a person who is:
  • a Medicaid enrollee,
  • between the ages of 21 and 64,
  • residing in an IMD primarily to receive withdrawal management or SUD treatment services,
  • diagnosed with at least one SUD, and
  • in an IMD primarily to receive treatment for a SUD (SUD must be the primary diagnosis).

Requirements for IMDs

Eligible IMDs must follow reliable, evidence-based practices and make available at least two forms of medication as part of medication-assisted treatment (MAT). The two drugs may be offered on site upon request or furnished off site by a qualified provider in the community that has an arrangement with the IMD. IMDs “should also offer behavioral health services alongside MAT,” CMS noted.

Requirements for States

States are required to:
  • ensure placement in an IMD will allow the beneficiary to successful transition to the community;
  • ensure that eligible IMDs provide services at lower levels of clinical intensity or establish relationships with providers offering those services;
  • notify CMS how it will ensure eligible individuals receive appropriate evidence-based clinical screening and periodic reassessments to determine the appropriate level of care;
  • cover outpatient SUD treatment services, including early intervention, outpatient services, intensive outpatient services, partial hospitalization, and at least two of the following residential and inpatient levels of care:
    • low-intensity residential services,
    • population specific, high-intensity residential services for adults,
    • medium-intensity residential services for adolescents,
    • high-intensity residential services for adults,
    • high-intensity inpatient services for adolescents,
    • intensive inpatient services withdrawal management for adults, and
    • intensive inpatient services.
Maintenance of Effort On an annual basis states must:
  • maintain or exceed the level of state and local funding for patients in eligible IMDs as well as services furnished to eligible individuals in outpatient, community-based settings;
  • report the total state and local expenditures, excluding the state share of Medicaid expenditures, for:
    • items and services provided while a patient in an eligible IMD,
    • outpatient and community-based SUD treatment,
    • evidence-based recovery and support services,
    • clinically-directed therapeutic treatment to facilitate recovery skills, relapse prevention and emotional coping strategies,
    • outpatient MAT, related therapies, and pharmacology,
    • counseling and clinical monitoring,
    • outpatient withdrawal management and related treatment, and
    • routine monitoring of medication adherence.
Interaction with Existing IMD Policies   States that add the new IMD authority (Section 5052) may also receive monthly capitation payments paid to managed care plans for beneficiaries age 21 through 64 who receive inpatient treatment in an IMD. Section 5052 does not prevent states from pursuing or conducting a section 1115 demonstration to improve access to, and the quality of, SUD treatment for eligible populations. Additional Information CMS is developing a state plan amendment and maintenance of effort reporting templates to assist states. Click here for specific guidance related to state plan amendment submission procedures, including guidance on developing comprehensive methodologies and bundled rates. If you have questions, please contact Scott Dziengelski, NABH’s director of policy and regulatory affairs.

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Psych-Appeal Files Class Action Complaint Against Health Care Service Corp. and MCG Health

The firm Psych-Appeal this week filed a class-action complaint in the U.S. District Court for the Northern District of Illinois alleging that Health Care Service Corporation (HCSC)—a mutual legal reserve company and an independent licensee of the Blue Cross and Blue Shield Association— is denying medically necessary residential mental health treatment based on overly restrictive guidelines that MCG Health developed. HCSC is the fourth largest U.S. health insurer operating through its Blue Cross and Blue Shield plans in Illinois, Montana, New Mexico, Oklahoma, and Texas. Psych-Appeal affiliates with the nation’s law firms, policy groups, and individuals to curb discrimination against mental illness and to expand access to meaningful treatment. Psych-Appeal filed the complaint, Smith v. Health Care Service Corporation, together with Zuckerman Spaeder LLP and Miner, Barnhill & Galland, P.C., on behalf of HCSC insureds. “In the mental health context, where regulatory oversight is lax, it is all too easy for insurers to discriminate against patients by denying medically necessary care based on clinical guidelines that reference authoritative sources yet distort or omit their content,” Meiram Bendat, Psych-Appeal founder, co-counsel for the plaintiff, and an NABH consultant, said in a news release about the complaint. “Psych-Appeal is committed to exposing and curbing this insidious practice.” Earlier this year, a federal court found that United Behavioral Health (UBH operating as Optum) developed and applied clinical guidelines to deny coverage for mental health and substance use treatment to more than 50,000 individuals. That case was also brought by Psych-Appeal and Zuckerman Spaeder.

CMS Analyzes Medicaid Coverage for SUD in New Report

NABH this week sent members an NABH Analysis of the Transformed Medicaid Statistical Information System (T-MSIS) SUD Data Book  that the Centers for Medicare & Medicaid Services (CMS) released on Oct. 24. The data book is the agency’s first annual report to Congress that is meant to improve analysis of Medicaid coverage and service utilization for individuals with substance use disorders (SUDs). Last year’s Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) required the report. The NABH Analysis provides an overall summary as well as highlights of the data book’s findings on beneficiaries treated, services/setting, length of stay, and funding mechanisms.

Partnership to Amend CFR 42 Part 2 Submits Comments to SAMHSA

NABH was one of nearly 50 organizations in the Partnership to Amend 42 CFR Part 2 (Partnership) that submitted comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) late last week about the agency’s Confidentiality of SUD Patient Records proposed rule. The six-page comment letter covers a host of provisions in the proposed rule, including consent requirements, disclosures for payment and healthcare operations, audit and evaluation, and non-Part 2 providers. “SAMHSA’s proposed change focuses on non-Part 2 providers, and we ask SAMHSA to clarify whether this would also apply to other entities such as health plans, healthcare clearinghouses and business associates that receive information from Part 2 providers for non-treatment purposes,” the letter noted. “For example, a payer entity may receive information for insurance claims, and then create their own records to process and pay the claim. Would these changes also apply to these types of records?” SAMHSA accepted all comments on the rule until last Friday, Oct. 25.

SAMHSA Announces Awards to Promote Behavioral Health in American Indian/Alaska Native Youth

SAMHSA has announced it will invest total funding of $9.2 million to promote mental and behavioral health among American Indian/Alaska Native (AI/AN) youth through the age of 24 years. SAMHSA said in an announcement that it expects up to 39 awards, funding programs up to $250,000 per year for five-year projects. Only federally recognized AI/AN tribes, tribal organizations, Urban Indian Organizations, or consortia of tribes or tribal organizations are eligible to apply.

Reminder: SAMHSA Grant Applications for Integrating Primary and Behavioral Healthcare Due Dec. 10

SAMHSA is accepting applications for fiscal year 2020 Promoting Integration of Primary and Behavioral Healthcare (PIPHC) grants until Tuesday, Dec. 10. The program’s purpose is to promote full integration and collaboration in clinical practice between primary and behavioral healthcare, support integrated care models and improve the overall wellness and health of adults with serious mental illness or children with serious emotional disturbance, and promote and offer integrated care services related to screening, diagnosis, prevention, and treatment of mental and substance use disorders and co-occurring physical health conditions and chronic diseases.

Register Today for the 2020 NABH Annual Meeting!

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March! Fact of the Week Although the proportion of facilities with Assertive Community Treatment (ACT) that offer all the required core services has increased in recent years, such programs remain a minority, and the overall number of facilities with ACT has declined.

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NABH, MHA, and NAMI Send Letter to Congress About Citizens Commission on Human Rights

NABH, Mental Health America (MHA), and the National Alliance on Mental Illness (NAMI) this week sent a letter to Congress about the work of the Citizens Commission on Human Rights (CCHR), an activist organization representing Scientology that questions the legitimacy of psychiatric categories, diagnostic practices, and common forms of behavioral healthcare treatment. News outlets have reported for years that the Scientology movement’s goal is to replace mental health treatment with rituals that adhere to Scientology’s beliefs and practices. The letter from NABH, MHA, and NAMI is meant to inform federal lawmakers and their staff members that CCHR represents Scientology, and also to make them aware that CCHR’s goal is to discredit the mental health segment and undermine public faith in this field of medicine. The letter is also intended to debunk CCHR’s claims and highlight the positive effects of behavioral healthcare treatment. “When behavioral healthcare conditions are compared with other chronic conditions, behavioral healthcare outcomes are similar, and, in some cases, slightly better,” the letter said. “Consider these statistics: 30 percent to 50 percent of adults with type 1 diabetes (a chronic condition) will experience recurrence of symptoms each year, and approximately 50 percent to 70 percent of adults with hypertension or asthma will have a recurrence requiring additional medical care each year. By comparison, “40 percent to 60 percent of patients treated for alcohol or other drug dependence return to active substance use within a year following treatment discharge.” NABH, MHA, and NAMI concluded the letter by offering to serve as trusted resources for policymakers, journalists, patient advocates, and the general public to ensure that America’s most vulnerable patients can access the high-quality, evidence-based behavioral healthcare they need.

MACPAC Examindes Access to Medication-Assisted Treatment Under Medicaid

Medicaid utilization management policies for medication-assisted treatment (MAT) vary widely nationwide and the extent to which these policies build barriers to addiction treatment is unclear, the Medicaid and CHIP Payment and Access Commission (MACPAC) concluded in its report to Congress this week. The Report to Congress: Utilization Management of Medication-Assisted Treatment in Medicaidis based on analysis of available data on how MAT utilization management is used nationally. It is also based on interviews with industry experts, clinicians, and state officials to study how eight states—Arkansas, Illinois, Maine, Missouri, Tennessee, Utah, Washington, and West Virginia—apply preferred status, prior authorization, step therapy, prescription limits, quantity or dose limits, and lifetime limits to their Medicaid fee-for-service and managed care programs. “Our review found a trend among states to eliminate prior authorization,” MACPAC Chair Melanie Bella said in an announcement about the report. “This is encouraging, since it removes one potential barrier to MAT access,” she added. According to the report, the number of states requiring prior authorization for MAT medications declined to 30 in 2018 from 48 in 2011-2013.

SAMHSA Releases First-Episode Psychosis and Co-Occurring SUD

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released First-Episode Psychosis and Co-Occurring Substance Use Disorders, a new guide to help healthcare providers, systems, and communities address first-episode psychosis and co-occurring substance use disorders (SUD). The resource describes relevant research; explores emerging and best practices; identifies knowledge gaps and implementation challenges; and offers resources.

SUD Increases Risk of Death from Heart Infection

Patients who suffer from infective endocarditis (IE) and struggle with SUD have a 240-percent increased risk of dying within 6 months to 5 years after valve surgery compared with other IE patients, according to a new study published online in The Annals of Thoracic Surgery. According to an announcement from the Society of Thoracic Surgeons (STS), IE is a life-threatening bacterial infection in the endocardium, the inner lining of the heart chambers and valves. Although this condition is often associated with heart defects or abnormal valves, the STS said it is also a “notorious complication after using unsanitary needles and syringes to inject drugs, as bacteria from the skin’s surface and injection equipment release directly into the bloodstream.” Despite medical advances, SUD-IE remains difficult to treat and has a high recurrence rate, the STS notes. The Centers for Disease Control and Prevention reports that people with SUD-IE are 10 times more likely than other patients with IE to require a second surgery or die months after leaving the hospital.

Behavioral Healthcare Providers Elected to National Academy of Medicine

Six behavioral healthcare providers were elected as new members to the National Academy of Medicine (NAM) this week. Election to the NAM is considered among the highest honors in the fields of health and medicine and recognizes individuals who have demonstrated both outstanding professional achievement and commitment to service. David Amaral, Ph.D., a distinguished professor in the department of psychiatry and behavioral sciences at the University of California, Davis; Colleen Barry, Ph.D., M.P.P., chair of health policy and management at the Johns Hopkins Bloomberg School of Public Health; Debra Elaine Houry, M.D., M.P.H., director of the National Center for Injury Control and Prevention at the Atlanta-based CDC; David Meyers, M.D., chief physician at the Agency for Healthcare Research and Quality in Baltimore; Scott Rauch, M.D., president and psychiatrist-in-chief at McLean Hospital and professor of psychiatry at Harvard Medical School; and Rachel Yehuda, Ph.D., professor and vice chair for veterans affairs for psychiatry and neuroscience at the Icahn School of Medicine at Mount Sinai in New York City were elected when the NAM announced the election of 90 regular members and 10 international members during its annual meeting on Oct. 21.

National Prescription Drug Take-Back Day is Oct. 26

The Drug Enforcement Agency under the U.S. Justice Department is sponsoring National Prescription Drug Take-Back Day on Saturday, Oct. 26. The day is meant to provide a safe, convenient, and responsible way of disposing prescription drugs, while also educating the public about the potential for medication abuse. Click here to learn more about the program and to identify drop-off sites.

IPFQR Program Webinar Scheduled for Oct. 31

The Quality Reporting Center will host a webinar for participants in the Inpatient Psychiatric Quality Reporting (IPFQR) Program next Thursday, Oct. 31 at 2 p.m. ET. The presentation—IPFQR Program FY 2020 Data Review is Thursday, Oct. 31 at 2 p.m. ET— will provide a review of the FY 2020 measure and non-measure data results. Click here to register and download the slides here from the Quality Reporting Center one day before the presentation.

SAMHSA Grant Applications for Integrating Primary and Behavioral Healthcare Due Dec. 10

SAMHSA has announced it is accepting applications for fiscal year 2020 Promoting Integration of Primary and Behavioral Healthcare (PIPHC) grants. The program’s purpose is to promote full integration and collaboration in clinical practice between primary and behavioral healthcare, support integrated care models and improve the overall wellness and health of adults with serious mental illness or children with serious emotional disturbance, and promote and offer integrated care services related to screening, diagnosis, prevention, and treatment of mental and substance use disorders and co-occurring physical health conditions and chronic diseases. Applications are due Tuesday, Dec. 10.

Judy Collins and Tom Insel to Serve as Keynote Speakers at NABH 2020 Annual Meeting

Grammy award-winning folk singer Judy Collins and neuroscientist Tom Insel, M.D., the former director of the National Institute Mental Health, will headline NABH’s 2020 Annual Meeting in Washington. Please visit NABH’s Annual Meeting homepage today to learn more and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

The last time a World Series was played in Washington, D.C. was 1933, the same year nine physicians established the National Association of Private Psychiatric Hospitals (NAPPH), the precursor to the National Association of Psychiatric Health Systems (NAPHS) and NABH. For questions or comments about CEO Update, please contact Jessica Zigmond.

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

America’s opioid crisis has cost the U.S. economy at least $631 billion from 2015 to 2018, according to a new analysis from the Society of Actuaries on non-medical opioid use. The report also projected future costs of the opioid crisis for 2019 based on three scenarios reflecting how the crisis may move forward, with a midpoint cost estimate of $188 billion and the low- and high-cost estimates ranging from $172 billion to $214 billion. Nearly one-third of the economic burden, or $205 billion, is attributable to excess healthcare spending for individuals with opioid use disorder (OUD), infants born with neonatal abstinence syndrome or neonatal opioid withdrawal syndrome, and for other family members of those diagnosed with OUD. Premature mortality, criminal justice activities, child and family assistance and education programs, and lost productivity accounted for the remainder of the economic toll.

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

Nearly half of U.S. adults, 46 percent, have dealt with substance abuse problems in their family, according to results from a Gallup poll released this week. The findings are based on 2018-2019 data from Gallup’s annual Consumption Habits poll that is conducted each July. Across the two polls, 36 percent of Americans reported that drinking has been a cause of trouble in their family, while 28 percent reported the same about drug abuse. Both questions are lifetime measures, meaning they asked Americans if drinking or drug abuse has ever been a problem in their family. The findings showed that reported family problems with drinking are similar among adults of all age groups—at or near 35 percent. Meanwhile, a higher percentage of adults under 55 (31 percent) than of those 55 and older (24 percent) said there has ever been a problem with drug abuse in their family. The study also highlighted some regional differences, as residents of the West are more likely than those in the East to report drinking problems. Westerners are also more likely than Easterners and Southerners to report family drug problems, the findings showed.

National Addiction Treatment Week is October 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week next week to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use #hashtag #TreatmentWeek to share your messages about addiction care and treatment.

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

NABH President and CEO Mark Covall will present on industry trends in the addiction treatment sector at the Treatment Center Investment & Valuation Retreat on Tuesday, Dec. 10 in Scottsdale, Ariz. Covall will also discuss federal policy changes that could affect addiction treatment centers, as well as collaborative opportunities with payers and employers. The three-day educational, business, and networking event will be held Dec. 9-11 at the Omni Scottsdale Resort and Spa at Montelucia. Other sessions include Inside a Behavioral Healthcare M&A Transaction: Lessons for All Executives, and Roadmap to Growth: Key Legal Issues, and Solutions, in the Expansion of Your Treatment Center. Click here to register and use the code NABH to receive a $100 discount on your registration.

Register Today for the NABH 2020 Annual Meeting!

The schedule At-a-Glance for the 2020 NABH Annual Meeting—Expanding Access: Right Care. Right Setting. Right Time.— is now available online. Please visit NABH’s Annual Meeting homepage today to register for the Annual Meeting and also make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

Youth who received mobile crisis services had a significant reduction in odds of a subsequent behavioral health emergency department visit. For questions or comments about CEO Update, please contact Jessica Zigmond.

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SAMHSA Releases Recovery Home Best Practices and Guidance

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week releasedbest practices and suggested guidelines for recovery housing. Last year’s Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act requires the HHS secretary to identify or facilitate developing best practices for recovery housing. SAMHSA’s report this week identifies 10 guiding principles to help states and federal policymakers both define and understand what comprises safe, effective, and legal recovery housing. In its guidance, SAMHSA noted the document is intended to provide a framework that builds on and extends the policy and practice work that has guided the development of recovery housing until now. The guidelines’ 10 areas include having a clear operational definition, recognizing that a substance use disorder (SUD) is a chronic condition that requires a range of recovery supports, promoting and using evidence-based practices, and ensuring quality, integrity, and patient safety.

MACPAC Releases Draft Report on Oversight of IMDs

The Medicaid and CHIP Payment Access Commission (MACPAC) recently released its draftreport on the oversight of Institutions for Mental Diseases (IMDs) a few months ahead of the commission’s January 2020 deadline for its final report to Congress. Divided into five chapters— 1) history and federal regulation, 2) services provided, 3) regulation and oversight of IMDs and outpatient behavioral health facilities, 4) Medicaid standards for behavioral health facilities, and protections for patients in IMDs, and 5) outpatient behavioral health facilities—the 24-page report includes key findings but does not offer recommendations. NABH sent MACPAC a letter about the regulatory environment at IMDs in late May as part of the commission’s process to develop the report.

Kaiser Permanente Pledges $2.75 Million in Research Funding to Prevent Childhood Trauma

Not-for-profit health plan Kaiser Permanente this week announced it will invest $2.75 million in new research to study childhood trauma and its effect on total health. In an announcement, Kaiser noted the study’s purpose is prevent and mitigate the health effects of adverse childhood experiences, or ACEs. ACEs are traumatic childhood events that occur before the age of 18 across multiple categories, including abuse, neglect, household dysfunction, systemic racism, and living in a high-crime neighborhood. “Our landmark research on ACEs brought new understanding to the long-term impacts of childhood trauma, and we are now expanding our work with the bold ambition to prevent and minimize ACEs— and create healthier and more resilient generations in the future,” Kaiser Permanente Chairman and CEO Bernard Tyson said in the announcement. One main goal for the new research effort is to provide insights for both clinical and community-based interventions to help address ACEs.

Health Affairs Examines the Effects of Violence on Health

In its latest issue, the journal Health Affairs this week examined the many ways violence affects health and concluded it is the “daily burden of violence in its many forms” that takes a greater toll on people. Introducing the Violence & Health issue, editor Alan Weil noted there were 2.3 million violence-related emergency department visits in 2017, of which 5 percent were due to firearms. He added that healthcare is the sector with the highest rate of workplace violence. The current issue includes two papers that examine the consequences of exposure to violence based on in-person surveys of 500 adults in two violent Chicago neighborhoods. From those findings, the authors concluded that exposure to violence relates to being in a state of hypervigilance, which carries with it negative health consequences. “Exposure to violence increases the odds of hypervigilance, with exposure to police violence associated with an almost 10-percentage-point increase,” Weil noted, adding that a separate paper in the issue found that exposure to neighborhood violence increases social isolation and loneliness. The issue also includes a paper that explores the relationship between alcohol misuse and subsequent arrest for intimate partner violence.

National Addiction Treatment Week is October 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week from October 21-27, 2019 to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use #hashtag #TreatmentWeek to share your messages about addiction care and treatment.

Register Today for the NABH 2020 Annual Meeting!

Registration has opened for the NABH 2020 Annual Meeting, Expanding Access: Right Care. Right Setting. Right Time. Please visit NABH’s Annual Meeting homepage today to register for the Annual Meeting and also make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We hope to see you next March!

Fact of the Week

A new study posted in Psychiatry Online shows any involvement between family members and inpatient staff was significantly associated with patients’ attending an outpatient appointment by seven days after discharge. For questions or comments about CEO Update, please contact Jessica Zigmond.

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NABH President and CEO Mark Covall to Retire; Shawn Coughlin Named as Successor

NABH President and CEO Mark Covall announced this week his plans to retire on Dec. 31, 2019 after more than 35 years with the association and 24 years as its president and CEO. The NABH Board of Trustees subsequently named Shawn Coughlin, the association’s executive vice president for government relations and public policy, as NABH’s next president and CEO, effective Jan. 1, 2020. “It has been a privilege to work closely for decades with people who manage and provide life-saving behavioral healthcare services to some of the most vulnerable citizens in our country,” Covall said in a news release this week about the transition. “For years, I’ve also enjoyed working with skilled and dedicated teams here in Washington who have helped expand our services and change U.S. public policy.” After he retires, Covall will serve as executive vice chairman of the NABH Board of Trustees for a two-year term. “I am honored to serve as NABH’s president and CEO after Mark’s long and impressive tenure,” Coughlin said in the news release. “Mark has been a mentor to me for nearly 20 years. His knowledge of—and passion for—improving mental health and addiction treatment services in the United States is unmatched.”

NABH Submits Recommendations to CMS on Bundled Rates for OTPs

NABH outlined a series of recommendations to the Centers for Medicare & Medicaid Services (CMS) in its Sept. 27 comment letter about the agency’s proposed physician fee schedule rule for 2020 that implements the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act. In the letter, NABH President and CEO Mark Covall highlighted that the value of a payment bundle is to simplify payment mechanisms in a way that treatment providers receive adequate compensation for treatment and patients receive the right care, in the right setting, at the right time. “Bundles that are highly prescriptive tend to disempower providers by directing medical decision-making,” Covall wrote. “At the same time, highly prescriptive bundles disempower patients by forcing them to engage in unnecessary and potentially burdensome care.” Covall also noted that because CMS’ proposed service model exceeds workforce capacity, “…the CMS proposal would put all OTPs at risk of not complying with the terms of the bundle and threaten the existing infrastructure and constrict treatment capacity at a time when more treatment is needed.”

NABH Submits Comments to CMS on PHP Rates and Price Transparency

NABH has recommended that CMS establish a task force to review and discuss improving the availability of partial hospitalization programs (PHPs) for Medicare beneficiaries. This suggestion was part of NABH’s Sept. 27 public comment letter to CMS on the agency’s proposed Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS) and Quality Reporting Programs for 2020. Currently, 47.9 percent of NABH members offer PHP services, and more than 32.5 percent offer PHP addiction services. “We recommend that CMS include NABH, the Association for Ambulatory Behavioral Healthcare, the National Council for Behavioral Health, a sampling of PHP providers from the membership of each organization, Mental Health America, and the National Alliance on Mental Illness in this task force,” Mark Covall wrote in NABH’s letter. “We believe that together, CMS and these organizations can produce actionable steps to ensure Medicare beneficiaries continue to have the necessary and appropriate access to PHP services.”

NAMI Releases First Free Online Class for Parents of Children with Mental Illness

The National Alliance on Mental Illness (NAMI) has announced NAMI Basics OnDemand, a free, six-session education program for parents, caregivers, and other family who provide care for youth aged 22 or younger who are experiencing mental health symptoms. For the last 10 years, NAMI Affiliates have offered NAMI Basics in an in-person, group setting, serving about 20,000 participants in 43 states nationwide. This new resource meets an increasing demand for the program. “We know parents face barriers to attending an in-person class, especially when a child may be experiencing mental health challenges, but that’s when this information is needed the most,” NAMI Acting CEO Angela Kimball said in a news release. “We hope by providing this free, online course of NAMI Basics OnDemand, we’ll reach more people when and where it’s easiest for them to access this vital information,” she added. “We want parents to get the resources they need and to realize they are not alone.” The program’s six sessions focus on basic elements of coping with mental health conditions; brain biology and getting a diagnosis; communication skills and crisis preparation; treatment and connecting with others by sharing your story; navigating the mental health and education systems; and self-care and advocacy.

ASAM Seeks Public Comment on Clinical Practice Guideline

The American Society of Addiction Medicine is seeking both member and public comment on the draft of the society’s latest clinical practice guideline on alcohol withdrawal management in both inpatient and outpatient settings. Click here to learn about the methodology and for a copy of the draft guideline. The deadline to submit all comments is Monday, Oct. 7.

National Addiction Treatment Week is Oct. 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week from Oct. 21-27, 2019 to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use #hashtag #TreatmentWeek to share your messages about addiction care and treatment.

Register Today for the NABH 2020 Annual Meeting!

Registration has opened for the NABH 2020 Annual Meeting, Expanding Access: Right Care. Right Setting. Right Time.   Please visit NABH’s Annual Meeting homepage today to register for the Annual Meeting and also make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We hope to see you next March!

Fact of the Week

The aggregate production quote of oxycodone (APQ) in the United States—which the U.S. Drug Enforcement Agency (DEA) establishes annually—increased more than 400 percent between 2002 and 2013. It wasn’t until 2017 that DEA significantly reduced the APQ for oxycodone, by 25 percent.   For questions or comments about CEO Update, please contact Jessica Zigmond.

2020 Annual Meeting

March 16-18, 2020

Mandarin Oriental Washington, DC

We invite you to use this annual opportunity to learn from, connect with, and influence the decision makers who determine the future of behavioral healthcare services in the United States.

The 2020 Annual Meeting will feature sessions on a variety of issues affecting the U.S. behavioral healthcare industry, with a special emphasis on the barriers to providing and access care.

Learn more and register for the 2020 Annual Meeting

Shawn Coughlin Named Next NABH President and CEO

Association’s Executive VP Succeeds Retiring NABH President and CEO Mark Covall WASHINGTON, Oct. 2, 2019 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) Board of Trustees has appointed Shawn Coughlin as its president and CEO beginning in January 2020. Coughlin succeeds Mark Covall, who is retiring after more than 35 years with the association and 24 years as its president and CEO. The Board announced the succession plan in conjunction with its Fall Board Meeting in Washington… Read more at PR Newswire

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NIH Has Awarded $945 Million to Address Nation’s Opioid Crisis in 2019

The National Institutes of Health (NIH) announced this week it has awarded $945 million in fiscal year 2019 to 41 states nationwide as part of its Helping to End Addiction Long-term Initiative, or NIH HEAL. NIH said its agency-wide research effort is meant to improve treatments for chronic pain; curb the rates of opioid use disorder (OUD) and overdose; and achieve long-term recovery from opioid addiction. The effort leverages the skills and expertise from nearly every NIH institute in the areas of translation of research to practice for opioid addiction, new strategies to prevent and treat opioid addiction, enhanced outcomes for infants and children exposed to opioids, novel medication options for OUD and overdose, clinical research in pain management; and pre-clinical and translational research in pain management. “It’s clear that a multi-pronged scientific approach is needed to reduce the risks of opioids, accelerate development of effective non-opioid therapies for pain, and provide more flexible and effective options for treating addiction to opioids,” NIH Director Francis Collins, M.D., Ph.D., said in an announcement. Collins launched the HEAL initiative in 2018.

VA Releases National Suicide Prevention Report

The number of U.S. Veteran suicide deaths per year rose to 6,139 in 2017 from 5,787 in 2005, increasing alongside the rise in suicide deaths in the United States broadly, according to the U.S. Veterans Affairs Department’s (VA) 2019 National Veteran Suicide Prevention Report. Released Sept. 20, the report includes findings from the VA’s most recent analysis of Veteran suicide data from 2005 to 2017. The analysis showed that the number of Veteran suicide deaths has exceeded 6,000 every year between 2008 and 2017. The report also noted 69 percent of all Veteran suicide deaths resulted in a firearm injury, and that males between the ages of 18 and 34 experienced the highest rates of suicide. Meanwhile, the VA reported that the rate of suicide was 2.2 times higher among female Veterans than non-Veteran adult women and 1.3 times higher among male Veterans than non-Veteran adult men. “VA is working to prevent suicide among all Veterans, whether they are enrolled in VA healthcare or not,” VA Secy. Robert Wilkie said in an announcement about the report. “That’s why the department has adopted a comprehensive public health approach to suicide prevention, using bundled strategies that cut across various sectors — faith communities, employers, schools and health care organizations, for example — to reach Veterans where they live and thrive.”

Study Shows Veterans with Mental Illness at Higher Risk for Cardiovascular Disease

A new study sponsored by the VA showed multiple mental illnesses were associated with an increased risk of cardiovascular disease (CVD) outcomes, which is consistent with the hypothesis that chronic stress leads to greater CVD. Published in the American Heart Association’s journal Circulation: Cardiovascular Quality and Outcomes, the study found that more severe mental illnesses—such as primary psychotic disorders—have the largest effect sizes even after controlling for other psychiatric diagnoses, conventional CVD risk factors, and psychotropic medication use. Among men, the study noted, depression, anxiety, psychosis, and bipolar disorder were all associated with an increased CVD risk, while among women, that link was found only for depression, psychosis, and bipolar disorder. “Surprisingly, a PTSD (post-traumatic stress disorder) diagnosis in men was tied to a lower risk, but in women, PTSD was not linked to any difference in CVD risk,” the study said.

Methadone Barriers Remain Despite Evidence of Effectiveness to Treat OUD

Despite evidence proving its effectiveness, methadone—one of three medications the U.S. Food and Drug Administration (FDA) has approved to treat OUD—continues to be one of the most heavily regulated drugs in the country at a time when additional methadone treatment capacity is needed, according to new Health Affairs blog post. Citing statistics from the 2018 National Survey of Substance Abuse Treatment Services (a survey of substance use disorder treatment facilities), the blog noted that about 383,000 people were treated with methadone in the past year. Meanwhile, opioid treatment programs (OTPs) are unavailable or inaccessible in many communities, with 88.6 percent of large, rural counties lacking a sufficient number of these programs. The blog offers recommendations for increasing access to methadone, including regulating mobile methadone vans; urging states to promote using medication units, which are dosing sites affiliated with an existing OTP; and revising policies that unnecessarily restrict the number of OTPs and the services they offer.

Mental Health Awareness Week: Oct. 6-12, 2019

The National Alliance on Mental Illness (NAMI) will recognize Mental Health Awareness Week with the theme WhyCare? between Oct. 6-12. In an overview about its campaign, NAMI noted there are too many myths surrounding mental illness, and that “with these myths comes stigma, misunderstanding, and discrimination.” NAMI will work to dispel a myth a day on the following topics: prevalence of mental illness (Oct. 6), obsessive-compulsive disorder (Oct. 7), PTSD (Oct. 8), children and mental illness (Oct. 9), anxiety and depression (Oct. 10), borderline personality disorder (Oct. 11), and mental health treatment (Oct. 12). NAMI will also highlight National Day of Prayer for Mental Illness Recovery and Understanding on Oct. 8 and World Mental Health Day on Oct. 10. Visit WhyCare? for statistics and resources.

Save the Date for the NABH 2020 Annual Meeting!

Please join us for the NABH 2020 Annual Meeting at the Mandarin Oriental Washington, D.C. from March 16-18, 2020. NABH will send Save-the-Date cards early next week with additional information about the Annual Meeting. Online registration and hotel booking information also will be available the week of Sept. 30. We look forward to seeing you in Washington!

Fact of the Week

The availability of opioid treatment programs (OTPs) varies widely by state. For example, the 4.7 million people in Louisiana have access to 10 OTPs in their state, while the 3.6 million residents of Connecticut have access to 41 OTPs. For questions or comments about CEO Update, please contact Jessica Zigmond.

NABH Board of Trustees Dinner and Meeting


Dinner

Monday, October 1, 2019 6 p.m. – 8:30 p.m. ET Concorde Room The Hay Adams 800 16th Street, NW, Washington, DC Hotel phone:  202-638-6600

Meeting

Tuesday, October 2, 2019 8 a.m. – 2 p.m. ET Hay Adams Room The Hay Adams 800 16th Street, NW, Washington, DC Hotel phone:  202-638-6600 Complimentary WiFi: Click on Hay Adams and connect.

Agenda

Download a PDF of the Agenda.
  1. Introductions
  2. Minutes Approval
  3. New Member Ratification
  4. President and CEO’s Report
  5. Board Priorities Update: Access to Care Initiative
    1. Managed Care Committee/Progress with Optum/Leavitt Partners Initiative
    2. Regulatory Overload/Ligature and EMTALA Guidance
    3. Next Steps
  6. 2020 Election Year Activities
    1. Member Engagement Strategy
    2. PAC-Focused Updates
  7. Medicare Opioid Treatment Provider (OTP) Coverage/Remedy Partners Analysis
  8. AHA/NABH Collaboration Action Plan
  9. Annual Meeting
    1. Exhibitor and Sponsor Opportunities
    2. Confirmed Speakers
  10. Youth Services
  11. Updates
    1. Scientology Letter
    2. LegitScript/Verisk G2
    3. Site-Neutral Payments
    4. IMD Claw Back
    5. Traumatic Events

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CMS Releases FAQ on Qualified Residential Treatment Programs

The Centers for Medicare & Medicaid Services (CMS) on Friday released a Frequently Asked Questions document that clarifies how the Institutions for Mental Diseases (IMD) Exclusion affects Qualified Residential Treatment Programs (QRTPs). CMS released the document following the Family First Prevention Services Act— included in theBalance Budget Act of 2018—which stipulated restrictions on room and board support for foster children in group care settings. The new law limited that support to 14 days unless the child was in certain settings, including the newly defined QRTP. Here are some important highlights from the agency’s FAQ on Sept. 20:
  • 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.
For questions about the FAQ, contact Scott Dziengelski, NABH’s director of policy and regulatory affairs.

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

CMS this week announced planning grant awards to 15 state Medicaid agencies to increase providers’ treatment capacity to offer substance use disorder (SUD) treatment and recovery services. The agency awarded nearly $48.5 million in awards to Alabama, Connecticut, Delaware, District of Columbia, Illinois, Indiana, Kentucky, Maine, Michigan, Nevada, New Mexico, Rhode Island, Virginia, Washington, and West Virginia as part of the Substance-Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act.

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

NABH was one of more than 50 organizations this week to support the Mental Health Professionals Workforce Shortage Loan Repayment Act of 2019, a bill intended to help build America’s mental and behavioral healthcare workforce. In a letter to Senators Kamala Harris (D-Calif.) and Cory Gardner (R-Colo.), the Mental Health Liaison Group cited statistics from a 2016 Health Resources and Services Administration report that projected the supply of personnel in selected behavioral and mental health fields to be 250,000 workers short of projected demand in 2025. Meanwhile, the National Institute of Mental Health has reported that nearly one in five adults in the United States experienced a mental or behavioral health problem in the last year alone, the letter noted. In addition to the Senate bill, there is a companion bill in the House of Representatives.

ASAM Seeks Public Comment on Clinical Practice Guideline

The American Society of Addiction Medicine is seeking both member and public comment on the draft of the society’s latest clinical practice guideline on alcohol withdrawal management in both inpatient and outpatient settings. Click here to learn about the methodology and for a copy of the draft guideline. The deadline to submit all comments is Monday, Oct. 7.

National Addiction Treatment Week is October 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week from October 21-27, 2019 to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use #hashtag #TreatmentWeek to share your messages about addiction care and treatment.

Save the Date for the NABH 2020 Annual Meeting!

Please save the date and plan to attend the NABH 2020 Annual Meeting at the Mandarin Oriental Washington, DC from March 16-18, 2020. NABH will send Save-the-Date cards with details in late September and will alert members when online registration and hotel reservations are available. We look forward to seeing you in Washington next March!

Fact of the Week

Those who abuse drugs are at an increased risk of infective endocarditis (IE), an infection of the heart. There has been a near doubling in prevalence of drug abuse-related IE from 2002 through 2016, as the condition increased alongside the nation’s opioid crisis.   For questions or comments about CEO Update, please contact Jessica Zigmond.

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NABH Endorses Legislation For a 3-Digit Suicide Prevention Line

NABH joined nearly 50 mental health organizations in endorsing The National Suicide Hotline Designation Act (HR 4194), which would establish a national 3-digit suicide prevention line. The legislation has nearly 70 congressional co-sponsors and a bipartisan Senate companion bill is currently being drafted. NABH previously sent a letter to FCC Secretary Marlene Dortch asking the agency to establish a hotline. “Based on the urgency of the suicide crisis and the nature of suicidal ideation, the potential positive outcomes outweigh any costs associated with changing an existing N11 number,” Mark Covall wrote. “This is why we strongly encourage the FCC to move forward immediately and repurpose an existing N11 number for a national suicide prevention and mental health crisis hotline system.”

Labor Department Releases More Information on Parity

Recently the U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) released a series of documents designed to help stakeholders understand the parity provisions included in the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), the 21st Century Cures Act, the SUPPORT for Patient and Communities Act, and the Employee Retirement Income Security Act (ERISA). The documents do not provide a new interpretation of those laws but do provide examples and illustrations of how the laws work. Here are the documents that were released:
  • 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

A Journal of the American Medical Association (JAMA) report on trends in suicide found that rates have “increased across the nation and most rapidly in rural counties.” Of those who died by suicide (from 1999 to 2016) 77 percent were male and primarily between the ages of 45 to 54 years. The report also found that suicide rates were higher and increased more rapidly in rural counties.

New Publication on The Sequential Intercept Model

The Sequential Intercept Model (SIM) is a “strategic planning tool that helps communities better understand the gaps and resources they have in helping those with mental illness or substance use disorders who are in the criminal justice system.” This week SAMHSA released a newbrochure that provides an overview of SIM. SAMHSA has been working to expand the use of SIM and previously released Data Collection Across the Sequential Intercept Model (SIM): Essential Measures, a manual for using data to improve outcomes for people with behavioral healthcare conditions in the criminal justice system.

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

In a follow up to their 1994 and 2009 reports, the National Academies of Sciences, Engineering, and Medicine released a new report this week: Fostering Healthy Mental, Emotional, and Behavioral Development in Children and Youth. The report made a series of recommendation including the development of a national agenda on youth behavioral health. Additional recommendations include:
  • 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”

In response to the recent reports of respiratory illnesses following the use of vaping products, the U.S. Food and Drug Administration (FDA) has provided information to help protect consumers. The FDA is also in the process of investigating the issue more thoroughly and has encouraged the public to submit detailed reports of any unexpected tobacco- or e-cigarette-related issues to the FDA via the online Safety Reporting Portal.

Save the Date for the NABH 2020 Annual Meeting!

Please save the date and plan to attend the NABH 2020 Annual Meeting at the Mandarin Oriental Washington, DC from March 16-18, 2020. NABH will send Save-the-Date cards with details in late September and will alert members when online registration and hotel reservations are available. We look forward to seeing you in Washington next March!

Fact of the Week

The percentage of Americans that “did not have health insurance at any point during the year” increased in 2018 to 8.5 percent (27.5 million people) from 7.9 percent (25.6 million people) in 2017.   For questions or comments about CEO Update, please contact Jessica Zigmond.

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

HHS this week announced more than $1.8 billion in funding to states to combat America’s deadly opioid crisis by expanding access to treatment and supporting near real-time data on the drug overdoses. As part of the funding, the Centers for Disease Control and Prevention (CDC) announced more than $900 million in new funding for a three-year cooperative agreement with states, territories, and localities to better understand the opioid crisis and build prevention and response activities. The Atlanta-based CDC will release $301 million in the first year. The funding will support the work of 47 states, Washington, D.C., two territories, and 16 counties and cities. Awardees will use these funds to strengthen prescription drug monitoring programs, improve state-local integration, establish links to care, and support healthcare providers and health systems. HHS said it will have awarded more than $9 billion in grants to states and local communities by the end of 2019 to help increase access to treatment and prevention services.

HRSA and SAMHSA Team Up on Medication Assisted Treatment

The Health Resources and Services Administration’s (HRSA) National Health Service Corps (NHSC) and the Substance Abuse and Mental Health Services Administration (SAMHSA) are partnering to connect qualified clinicians with free medication assisted treatment (MAT) training and professional development resources. The new partnership will provide the opportunity to obtain the DATA 2000 waiver, which is meant to increase access to quality substance use disorder or opioid use disorder treatment in rural and underserved areas. Click here to learn more about the new partnership, MAT training, and the DATA 2000 waiver.

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

This year marks the 30th anniversary of National Recovery Month, which SAMHSA commemorates each September. As part of the anniversary, SAMHSA unveiled a new logo featuring an “r” symbol to represent Recovery and the need to support the millions of individuals who are living in recovery—as well as their family members and loved ones. The 2019 National Recovery Month theme is Join the Voices for Recovery: Together We Are Stronger, and SAMHSA has created resources for providers to use and share. September is also Suicide Prevention Awareness Month, with National Suicide Prevention Week kicking off this Sunday, Sept. 8 and ending on Saturday, Sept. 14. The National Alliance on Mental Illness (NAMI) has developed its own set of resources, including social media posts, for providers and advocates to share. NABH will be tweet and post our messages about access to care—as well as important messages from NAMI and SAMHSA—during National Recovery Month and Suicide Prevention Awareness Month to build awareness around suicide prevention and the need for effective care to help patients on the road to recovery. Please be sure to follow us on Twitter and LinkedIn and share our messages with others. Thank you for your cooperation.

National Addiction Treatment Week is October 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week from October 21-27, 2019 to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use hashtag #TreatmentWeek to share your messages about addiction care and treatment.

Save the Date for the NABH 2020 Annual Meeting!

Please save the date and plan to attend the NABH 2020 Annual Meeting at the Mandarin Oriental Washington, DC from March 16-18, 2020. NABH will send Save-the-Date cards with details in late September and will alert members when online registration and hotel reservations are available. We look forward to seeing you in Washington next March!

New CEO Update Feature: Fact of the Week

Starting with this edition, NABH will provide a “Fact of the Week” as the last item in NABH’s weekly CEO Update. Some of these facts may be new, while others may have appeared as news items in previous editions of the CEO Update and are important enough to highlight. If you have an item to share with fellow NABH members, please contact Jessica Zigmond, NABH’s director of communications. This week’s fact: The risk of a suicide attempt doubles among the children of opioid users. For questions or comments about CEO Update, please contact Jessica Zigmond.

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SAMHSA Releases 2018 National Survey on Drug Use and Health
The United States saw a significant decrease in prescription opioid use among all age groups and a significant increase in serious mental illness last year, according to the 2018 National Survey on Drug Use and Health that the Substance Abuse and Mental Health Services Administration (SAMHSA) released this week. In the report, SAMHSA said the total number of Americans with opioid use disorder decreased to 2.0 million in 2018 from 2.1 million in 2017. The agency found that the majority of people continue to obtain prescription opioids from friends, relatives, and healthcare providers/prescribers, which the agency said underscores the need for ongoing education of practitioners, appropriate pain management, and partnerships with states to monitor opioid analgesic prescribing. Heroin use disorder also dropped significantly compared with 2017, but remained steady among people aged 26 and older, the study showed. Meanwhile, serious mental illness rose among both young adults (ages 18-25) and adults (ages 26-49) last year, and SAMHSA reported significant increases in suicidality in the 18-25 group. SAMHSA found that use of one substance—alcohol or other illicit substances—is strongly correlated with polysubstance use and with major depression and serious mental illness, which SAMHSA said highlights the need to screen for all substances and mental disorders.
Report Shows Americans Spend Almost as Much on Illicit Drugs as Alcohol
Researchers from RAND Corp. estimate that Americans spent between $120 billion and $145 billion on cocaine, heroin, marijuana, and methamphetamine between 2006 and 2016, while another analysis showed U.S. spending on alcohol in 2017 was about $158 billion. Released this week, What America’s Users Spend on Illegal Drugs, 2006-2016 examines how many people use cocaine, heroin, marijuana, and methamphetamine in the United States; how much they’re using; how much money they’re spending on these substances; and how the quantities have changed over time. “To better understand changes in drug use outcomes and the effects of policies, policymakers need to know what is happening in markets for these substances,” Greg Midgette, the study’s lead author and assistant professor at the University of Maryland, said in an announcement about the study. “But it is challenging to generate these estimates, and given that critical data sources have been eliminated, it will likely be harder to generate these figures in the future.”
Study Says Former Cigarette Smokers Are Smoking Marijuana and Binge Drinking More
Rates of cigarette smoking have decreased, but new research shows that cannabis and alcohol use among former smokers has increased, according to a new study in the American Journal of Preventive Medicine. According to the findings, about 44 percent of people who smoked previously were no longer smoking in 2002, and that number rose to 50 percent in 2016. Data from more than 67,000 former smokers between 2005 and 2016, meanwhile, show that marijuana use over the previous year nearly doubled to about 10 percent from a little more than 5 percent. Similarly, rates of binge drinking during the previous month also increased to more than 22 percent from about 17 percent. “It is conceivable that the prevalence of depression and substance use problems may shift over time among former smokers,” the study said. “If people who stop smoking cigarettes substitute other forms of substance use, the overall health benefits of cigarette cessation may be decreased owing to the negative consequences of use of these drugs as well as consequent relapse to smoking cigarettes.”
HRSA Releases Dashboards on Health Professions Training Programs
The Health Resources and Services Administration (HRSA) this week released interactive dashboards that show aggregated performance data for HRSA-awarded health professions training grants from the academic year 2012-2013 to the present. These data are meant to provide insight into the distribution of HRSA’s healthcare providers who help and work in underserved communities. The dashboards offer information on training programs, demographics, health professional shortage areas, medically underserved areas, and more
HRSA Announces Funding Opportunity for Rural Health Network Development Program
HRSA said this week it expects to spend about $13 million on nearly 50 public or not-for-profit, private organizations to support integrated, rural healthcare networks. The agency’s Rural Health Network Development Program has previously funded networks that focused on coordinated care for patients, chronic disease management, telehealth, and behavioral health improvement. Details about the program and requirements for applications are available here, and the deadline is Nov. 25.
National Consortium of Telehealth Resource Centers Webinar to Focus on Mental Health
Speakers from the Telehealth Resource Centers and a rural federally qualified health center will present a webinar next week about how telehealth can help deliver mental and behavioral health services. Specifically, the presentation will explain how to integrate telemental/behavioral health into organizations and will provide stories from clinics that have done this successfully. The webinar is scheduled for Tuesday, Aug. 27 at 4 p.m. ET. Click here to register. For questions or comments about CEO Update, please contact Jessica Zigmond.

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Task Force Recommends Physicians Ask Adult Patients About Illicit Drug Use The U.S. Preventive Services Task Force this week recommended that physicians ask all U.S. adults aged 18 or older about possible illicit drug use—including opioid painkillers—as part of the federal government’s ongoing effort to address America’s opioid crisis. The recommendation from the independent panel of medical experts marks the first time the task force has determined there is enough evidence to support screening adults. According to the recommendation, an estimated 11.5 percent of Americans aged 18 or older reported current illicit drug use in a national survey. Illicit drug use is more commonly reported in young adults between the ages of 18-25 (24.2 percent) than in older adults (9.5 percent), or in adolescents between the ages of 12 and 17 (7.9 percent), the announcement noted. In a story about the recommendation, The Washington Post said the guidance is also important because the 2010 Patient Protection and Affordable Care Act requires that services recommended by the task force should be covered for free or with very small co-payments. Public comments on the task force’s draft recommendation are due Sept. 9. HHS Offers Resources to Providers During and After Mass Violence Events HHS has released tip sheets and other resources to help U.S. healthcare providers prepare for and respond to mass violence events. The resources are from HHS’ Assistant Secretary for Preparedness and Response’s (ASPR) Technical Resources, Assistance Center, and Information Exchange (TRACIE) and include tip sheets on topics such as emergency medical system considerations, expanding traditional roles, fatality management, non-trauma hospital considerations, and more. Additional information includes topic collections on crisis standards of care, mental health, explosives, surge capacity, and information sharing. HRSA Awards About $400 Million to Fight Opioid Crisis HHS’ Health Resources and Services Administration (HRSA) recently released nearly $400 million in awards to combat the nation’s deadly opioid crisis. The investments are intended to help HRSA-funded community health centers, rural organizations, and academic institutions establish and expand access to integrated substance use disorder and mental health services. “HRSA programs play a key role in the Trump Administration’s efforts to battle the nation’s opioid crisis,” said HRSA Acting Administrator Tom Engels said in an announcement about the funding. “From implementing and expanding substance use disorder services at HRSA-funded health centers to increasing support and training to our nation’s behavioral health workforce to improving access to treatment in rural areas, today’s announcement demonstrates the administration’s commitment to ending this crisis.” According to HRSA, the agency is awarding more than $200 million to 1,208 health centers nationwide to increase access to high-quality, integrated behavioral health services, including the prevention or treatment of mental health conditions and/or substance use disorders, including opioid use disorder through the Integrated Behavioral Health Services (IBHS) program. NIMH Director Highlights Effects of Ketamine for Treatment-Resistant Depression The director of the National Institute of Mental Health (NIMH) this week examined the effects of the medication ketamine to reduce depressive symptoms. In his NIMH director’s column, Joshua Gordon, M.D., Ph.D noted previous research showing ketamine’s effectiveness in having “strong, rapid effects” on treatment-resistant depression (TRD) and bipolar disorder. He also highlighted what he called the “robust antidepressant effects” of the drug esketamine but called for more research into both medications. “The job is not done for TRD,” Gordon wrote. “Ketamine and esketamine work, but both have significant drawbacks. Many patients experience uncomfortable dissociate symptoms, hypertension, or other side effects for a few hours after administration,” he added. “Because of these symptoms, as well as the potential for abuse, both need to be administered in a doctor’s office.” Study Shows More Than One Tenth of Older Americans Are Binge Drinkers More than a tenth of older U.S. adults are estimated to be current binge drinkers and a large proportion of them have chronic diseases that are exacerbated by binge drinking, according to a new study published in the Journal of American Geriatrics Society. The study used data from the U.S. National Survey on Drug Use and Health (2017) and provides information on the prevalence of binge drinking in individuals 65 years and older. It found that between 2001 and 2013, there was a 22.4 percent increase in past-year alcohol use; a 65.2 percent increase in high-risk drinking; and a 106.7 percent increase in alcohol use disorder among adults aged 65 years and older. “Excessive alcohol use, including binge drinking, is a risk factor for a range of health problems, including injury,” the study concluded. “This is especially true for older adults due to physiological changes related to aging and increasing comorbidity,” it continued. “Binge drinking, even episodically or infrequently, may negatively affect comorbid conditions by exacerbating disease and complicating disease management.” IPFQR Program Webinar to Examine 2020 IPF PPS Final Rule on Aug. 28 The Quality Reporting Center will host a quality and education webinar for those who participate in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program on Wednesday, Aug. 28 at 2 p.m. ET. Titled the IPFQR Program: FY 2020 IPF PPS Final Rule and APU Determination, the webinar will feature Jeffrey Buck, Ph.D., program leader and senior advisor for behavioral health at the Center for Clinical Standards and Quality at the Centers for Medicare and Medicaid Services (CMS); and Lauren Lowenstein, a program specialist at the Center for Clinical Standards and Quality. Webinar slides will be available to download from the Quality Reporting Center under “Upcoming Events” one day before the presentation. Click here to register. For questions or comments about CEO Update, please contact Jessica Zigmond.

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SAMHSA Highlights Disaster Distress Line Following Recent Spate of Shootings Following mass shootings in California, Texas, and Ohio within one week, the Substance Abuse and Mental Health Services Administration (SAMHSA) urged survivors and first responders to use the agency’s Disaster Distress Hotline Helpline for immediate crisis counseling. The helpline is available 24 hours a day, seven days a week, to anyone dealing with the traumatic effects of a natural or human-caused disaster. “People who have been through a traumatic even can experience anxiety, worry, or insomnia,” Elinore McCance-Katz, M.D., Ph.D., assistant secretary for mental health and substance use and the head of SAMHSA, said in a statement. “People seeking emotional help in the aftermath of a disaster can call 1-800-985-5990 or can text ‘TalkWithUs’ to 66746—and can begin the process of recovery.” NABH thanks its members and their teams for providing life-saving, behavioral healthcare services during and after disasters. Medical and Public Health Groups Urge Policymakers to Take Action on Gun Violence Seven medical and public health organizations this week called on policymakers to implement specific policy recommendations they say can reduce firearm-related injuries in the United States. The American Academy of Family Physicians, the American Academy of Pediatrics, the American College of Surgeons, the American Medical Association, the American Psychiatric Association, and the American Public Health Association—which together represent 731,000 U.S. physicians and 25,000 public health professionals—outlined their requests online in the Annals of Internal Medicine on Aug. 7. In it, the groups covered a range of issues, including background checks for firearm purchases, research on firearm injury and death, safe storage of firearms, and improved access to mental healthcare services. “The great majority of those with a mental illness or substance use disorder are not violent,” the article notes. “However, screening, access, and treatment for mental health disorders play a critical role in reducing risk for self-harm and interpersonal violence,” it continues. “This is particularly of concern for adolescents, who are at high risk for suicide as a consequence of their often impulsive behavior.” New Poll Examines Public Perception of Link Between Gun Violence and Mental Health A new Morning Consult/Politico poll this week found that of 1,960 registered voters, 48 percent place “a lot” of blame on mental illness for mass shootings, while another 35 percent place “some” blame on mental illness. The poll came days after back-to-back shooting sprees in El Paso, Texas, and Dayton, Ohio, and after President Trump referred to the shooters as “mentally ill monsters.” According to the results, the share of voters who blamed mental illness “a lot” is down from 54 percent in a survey taken a year ago, while the share who said mental illness plays “some” roll grew from 28 percent last year, which indicates a significant majority of the U.S. electorate sees a strong connection between mental health and mass shootings. A story about the poll in the Morning Consult said the slight change from last year is driven by a 12-point decrease in the share of Democrats and 9-point decrease in the share of Independents who heavily attribute mass shootings to mental illness. Among Republicans, about three in five place “a lot” of blame on mental illness for mass shootings, making it the No. 1 factor Republicans believe drive mass shootings. “This is a repeated message that is being put out there,” Bandy Lee, a Yale University psychiatrist and specialist in violence prevention programs, told the Morning Consult. “When a president says it, it has far-reaching cultural consequences.” NABH Recommends CMS Rewrite Special Conditions of Participation NABH on Thursday sent CMS a comment letter requesting the agency help reduce the administrative burden for providers. The letter is a response to CMS’ Request for Information (RFI) last month that seeks ideas on how to enhance the agency’s Patients Over Paperwork initiative. Launched in 2017, Patients Over Paperwork has worked to streamline regulations in healthcare that often take clinicians away from their primary purpose of caring for patients. NABH’s comment letter focuses on the psychiatric hospital Conditions of Participation (CoP) and the 60 distinct compliance elements referred to as “B-tags”. “These rules are intended to serve the important goal of ensuring patient safety and high-quality care. However, some of these requirements are now outdated,” NABH President and CEO Mark Covall writes in the letter.” In addition, many surveyors apply these criteria indiscriminately in the field, exposing providers to unpredictable citations and requiring costly alterations in their procedures, equipment, and facilities.” NABH also submitted a copy of The High Cost of Compliance, the association’s report that assesses the regulatory burden on the nation’s inpatient psychiatric facilities. The report, which address the B-tags, ligature risk and the Emergency Medical Treatment and Labor Act, found that these three regulatory areas impose $1.7 billion in compliance costs each year nationwide, which represent 4.8 percent of an average facility’s annual revenue for all inpatient psychiatric services from all sources. Click here to read NABH’s letter to CMS. CDC Highlights How Naloxone Can Help End the Opioid Crisis in Vital Signs Report The Centers for Disease Control and Prevention said this week the overdose-reversing drug naloxone saves lives—but only if it’s readily available when an overdose happens. CDC researchers reported in the latest Vital Signs study that despite a huge increase in naloxone prescribing in recent years, far too little naloxone is being dispensed in many areas of the United States that need it most. “Moreover, too few doctors are prescribing naloxone to patients receiving high-dose opioids or opioids plus benzodiazepines or to those with a substance use disorder as recommended by CDC’s Guideline for Prescribing Opioids for Chronic Pain,” the Atlanta-based agency said in a news release. According to the study, the number of naloxone prescriptions dispensed doubled from 2017 to 2018, and only one naloxone prescription is dispensed for every 70 high-dose opioid prescriptions nationwide. Meanwhile, about 71 percent of Medicare prescriptions for naloxone required a copay, compared with 42 percent for commercial insurance. O’Neill Institute Reviews How States Support OUD Treatment Medication in Jails and Prisons A blog post from the O’Neill Institute for National and Global Health Law at Georgetown University Health Center this week explored recent state laws and appropriations on how different states are supporting opioid use disorder (OUD) treatment in their jails and prison systems. According to the blog, state legislators passed laws expanding access to treatment medications for OUD. In some states, legislators targeted their efforts to populations most at risk, including those who are incarcerated. “Upon leaving incarceration, an individual’s overdose risk skyrockets. Despite this, too few correctional institutions provide OUD treatment medications,” researchers Regina LaBelle (a 2019 NABH Annual meeting speaker) and Shelly Weizman, director and associate director, respectively, of the Addiction and Public Policy Initiative at Georgetown University Law Center, wrote. “In some cases, policymakers and jail administrators fear misuse of opioid treatment medications.” In Connecticut, Ohio, and Oklahoma, legislators have appropriated new funds to establish treatment programs using OUD medications for their incarcerated populations, while states such as Colorado and Maryland also passed legislation requiring county jails to phase in OUD medication treatment programs, LaBelle and Weizman noted. For questions or comments about CEO Update, please contact Jessica Zigmond.

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CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule The Centers for Medicare and Medicaid Services (CMS) announced a Medicare payment increase of 1.5 percent next year for inpatient psychiatric facilities in the final Inpatient Psychiatric Facilities Prospective Payment Systems (IPF PPS) rule the agency released earlier this week. Compared with the 2019 payment rate, the increase reflects a total increase of $65 million for Medicare-participating inpatient psychiatric facilities in fiscal year 2020. The payment update aligns with the agency’s proposed rule earlier this year. The rule also adds one new claims-based measured starting in fiscal year 2021 payment determination and continuing in subsequent years. The measure—Medication Continuing Following Inpatient Psychiatric Discharge (National Quality Forum #3205)—assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder, schizophrenia, or bipolar disorder filled at least one evidence-based medication within two days before discharge or during the 30-day, post-discharge period.   CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020 The CMS has proposed a hospital-based partial hospitalization program (PHP) payment rate of $228.20 for 2020, up from the 2019 rate of $220.86, in the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS/ASC) proposed rule the agency released on July 29. CMS also proposed an increase for community mental health centers (CMHCs), which could see a payment rate of $124.59 in 2020 if the rule is made final. By comparison, CMHCs received a payment rate of $120.58 in 2019. The rates set in the proposed CY 2020 rule are not based on the most recent average cost data from the PHP program, a deviation from CMS’ long-standing policy. When CMS calculated the average PHP program cost for the CY 2020 proposed rule, the agency found it had decreased by nearly 15 percent for CMHCs and 11 percent for hospitals-based PHPs. After finding this decrease, CMS reviewed the data sets and found that a single provider in the CMHC set and a single provider in the hospital-based set had such dramatically lower reported costs that it significantly skewed the average cost for both data sets. Because the lower average costs were the result of single providers and could significantly reduce access for beneficiaries, CMS decide to use the CY 2019 cost average as a floor for both type of PHP rates in the CY 2020 rule. If not for this change, the rate for both types of PHPs would have been significantly lower than what CMS proposed in the rule. It is important to note that CMS stressed that it does not intent to carry this policy forward: “To be clear, this policy would only apply for the CY 2020 rate setting,” the agency said in the rule. CY 2020 Rates Level 1 Health and Behavior Services                                                     $28.59 Level 2 Health and Behavior Services                                                     $81.06 Level 3 Health and Behavior Services                                                     $130.27 Partial Hospitalization (3 or more services) for CMHCs                            $124.59 Partial Hospitalization (3 or more services) for Hospital-based PHPs        $228.20   NABH will submit comments on the proposed rule to CMS by the Sept. 27 deadline.   CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule  Also this week, CMS issued a proposed rule for establishing a Medicare Part B benefit and payment bundles for opioid use disorder (OUD) treatment services in opioid treatment program (OTP) settings and new HCPCS codes and bundled rates for office-based treatment of OUD.   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.
  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, permitting a patient’s home as a telehealth originating site; and
  • No changes to cost-sharing.
  In addition, 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. CMS Releases Informational Bulletins as Part of the SUPPORT Act CMS late last week released two informational bulletins as part of last year’s SUPPORT Act to provide states with guidance on treatment for infants, expectant mothers, and post-partum women.   In the first bulletin, the agency explains that neonatal abstinence syndrome (NAS) is a “constellation of symptoms in newborn infants exposed to any of a variety of substance in utero, including opioids.” The SUPPORT Act added an optional provider type, a residential pediatric recovery center, defined as a facility that offers items and services for which medical assistance is available under the state plan to infants who have NAS. This brief provides additional information about this condition and the impact of these recovery centers.   Meanwhile, the agency’s second bulletin provides background information about Medicaid coverage for pregnant and post-partum women and examines a new, limited exception to the IMD exclusion.   A section of the SUPPORT Act states that a woman who is eligible on the basis of being pregnant (and up to 60 days post-partum) who is a patient in an IMD for SUD treatment, and who is either enrolled under the state plan immediately before becoming an IMD patient, or who becomes eligible to enroll while a patient in an IMD, the exclusion cannot prohibit federal financial participation for medical assistance for items and services that are provided outside the IMD.   MACPAC Releases Issue Brief on Recovery Services for Medicaid Beneficiaries with SUD The Medicaid and CHIP Payment Commission (MACPAC) this week released an issue brief about recovery support services for Medicaid beneficiaries with SUD.   MACPAC documented coverage for clinical SUD services in the fourth chapter of its Report to Congress on Medicaid and CHIP in June 2018. This week’s issue brief complements that information by presenting results from the commission’s 50-state policy review of coverage for clinical SUD services.   The brief also describes how Medicaid programs pay for recovery support services and discusses opportunities to coordinate clinical treatment and recovery support services.   For questions or comments about CEO Update, please contact Jessica Zigmond.

NABH Issue Brief: CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020

The Centers for Medicare and Medicaid Services (CMS) has proposed a hospital-based partial hospitalization program (PHP) payment rate of $228.20 for 2020, up from the 2019 rate of $220.86, in the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS/ASC) proposed rule the agency released on July 29. CMS also proposed an increase for community mental health centers (CMHCs), which could see a payment rate of $124.59 in 2020 if the rule is made final. By comparison, CMHCs received a payment rate of $120.58 in 2019. The rates set in the proposed CY 2020 rule are not based on the most recent average cost data from the PHP program, a deviation from CMS’ long-standing policy. When CMS calculated the average PHP program cost for the CY 2020 proposed rule, the agency found it had decreased by nearly 15 percent for CMHCs and 11 percent for hospitals-based PHPs. After finding this decrease, CMS reviewed the data sets and found that a single provider in the CMHC set and a single provider in the hospital-based set had such dramatically lower-reported costs that it significantly skewed the average cost for both data sets. Because the lower average costs were the result of single providers and could significantly reduce access for beneficiaries, CMS decided to use the CY 2019 cost average as a floor for both type of PHP rates in the CY 2020 rule. If not for this change, the rate for both types of PHPs would have been significantly lower than what CMS proposed in the rule. It is important to note that CMS stressed that it does not intent to carry this policy forward: “To be clear, this policy would only apply for the CY 2020 rate setting,” the agency said in the rule. CMS will accept comments on the CY 2020 proposed rule until September 27. CY 2020 Rates Level 1 Health and Behavior Services                                                         $28.59 Level 2 Health and Behavior Services                                                         $81.06 Level 3 Health and Behavior Services                                                         $130.27 Partial Hospitalization (3 or more services) for CMHCs                               $124.59 Partial Hospitalization (3 or more services) for Hospital-based PHPs         $228.20

NABH Issue Brief: CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) on Monday issued a proposed rule for establishing a Medicare Part B benefit and payment bundles for opioid use disorder (OUD) treatment services in opioid treatment program (OTP) settings and new HCPCS codes and bundled rates for office-based treatment of OUD.
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.

NABH Alert: CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule

The Centers for Medicare and Medicaid Services (CMS) announced a Medicare payment increase of 1.5 percent next year for inpatient psychiatric facilities in the final Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) rule the agency released today. Compared with the 2019 payment rate, the increase reflects a total increase of $65 million for Medicare-participating inpatient psychiatric facilities in fiscal year 2020. The payment update aligns with the agency’s proposed rule earlier this year. The rule also adds one new claims-based measured starting in fiscal year 2021 payment determination and continuing in subsequent years. The measure—Medication Continuing Following Inpatient Psychiatric Discharge (National Quality Forum #3205)—assesses whether patients admitted to IPFs with diagnoses of Major Depressive Disorder, schizophrenia, or bipolar disorder filled at least one evidence-based medication within two days before discharge or during the 30-day, post-discharge period.

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Threat of Sequestration Ends with Bipartisan Budget Act White House and Congressional leaders agreed to large increases in base funding for defense and nondefense spending on Thursday, with the expectation of support by the Senate in a vote next week. The budget deal establishes a funding base above spending cap levels that could trigger mandatory automatic spending cuts, referred to as sequestration. The bipartisan compromise suspends the federal debt ceiling and spending caps for two years, thus marking the end of sequestration that was due to sunset in 2021. Defense spending was increased by $22 billion and nondefense spending was increased by $27 billion. As part of the negotiations, Congressional leadership agreed to avoid the inclusion of any contentious measures that do not have bipartisan support during the FY2020 appropriations process. This agreement will allow for a budget process that will avoid a government shutdown. Medicare Plans Dramatically Reduce Prior Authorization Rates A recent study published in a JAMA Research Letter found large reductions in the percentage of Medicare Part D and Medicare Advantage Plans using prior authorization for buprenorphine medications for opioid use disorder (OUD). In the two years between 2017 and 2019, the percentage of plans using preauthorization for generic buprenorphine-naloxone medications dropped from 96 percent to zero, and for brand buprenorphine-naloxone medication rates dropped from 88 percent to 3 percent. These findings follow two federal policy initiatives: a 2017 buprenorphine labeling change by the Food and Drug Administration, and a 2018 announcement by the Centers for Medicaid and Medicare Services (CMS) that they would no longer approve Medicare Part D formularies that preauthorize buprenorphine products more than once per year. Looking forward, the study states the importance of the data “because Medicare policy is often viewed as a standard that is subsequently adopted by private health plans and Medicaid.” Tami Mark, lead author of the study said, “Although Medicare has significantly reduced prior authorization for opioid use disorder medications, it is still in common use in Medicaid and private health plans.” Legal Action Center Calls for Removal of Prior Authorization in Medicaid The Legal Action Center (LAC) in a new report calls for Medicaid programs to adopt the successful “Medicare Model” of eliminating prior authorization for medications to treat opioid use disorder (OUD) and expanding coverage of all FDA-approved medications. Citing the success of a 2018 federal policy that virtually eliminated prior authorization for buprenorphine products in Part D and Medicare Advantage programs (see previous article), LAC reports that most Medicaid plans continue to require prior authorization for OUD medications. Specifically, buprenorphine-naloxone medication requires prior authorization in 40 Medicaid programs, and buprenorphine medication requires authorization in 35 Medicaid programs. Formulary restrictions and dose limitations also pose barriers to medication assisted treatment (MAT). MAT can reduce mortality by almost half. Medicaid covers four out of 10 adults with OUD and thus “plays a significant role in delivering effective OUD treatment and reducing barriers to FDA-approved medications,” the report states.  The Report recommends that CMS issue a guidance letter to State Medicaid Directors to increase the use of all medications for OUD. Arnold Ventures Funds Research on Insurance Fraud Arnold Ventures is funding a new two-year study to develop methods for identifying fraudulent opioid use disorder treatment and recovery services. Led by Boston University researchers and in collaboration with a former federal health-fraud investigator, the study intends to provide a broader view of fraudulent practices, including excessive medical testing, patient brokering, and the geographic scope of such practices. Through a review of insurance data for more than 50 million individuals and the deployment of secret shoppers, the study seeks to provide insurance companies with tools to improve detection and support policymakers in developing procedures to improve oversight. Fair Health Sheds Light on Rapid Growth of Telehealth A new white paper from FAIR Health found that provider-to-patient telehealth grew by 1,293 percent for non-hospital-based providers between 2014 and 2018, accounting for 84 percent of all telehealth claim lines. Telehealth for all providers grew by 624 percent. In a review of over 29 billion private claim records for 2018, the analysis found that mood disorders (six percent) and anxiety and other nonpsychotic mental disorders (five percent), were the second and third most common conditions for which individuals sought telehealth services. Upper respiratory infections were the most common reason. Telehealth gains were larger for urban providers, increasing 1,227 percent, with rural providers increasing by 897 percent. Rural areas, however, showed stronger gains than urban areas for telehealth after hospital discharge, with an increase of 407 percent. A previous FAIR Health study found that between 2016 and 2017, telehealth grew more than any other place of service, including emergency rooms and retail clinics. According to FAIR Health, the findings suggest “important implications for improving healthcare quality and lowering costs by reducing avoidable hospitalizations, readmissions and urgent/emergent care visits.” National Institutes on Drug Abuse to form Justice Community Opioid Innovation Network Ten research institutions and two centers have been funded by the National Institutes on Drug Abuse (NIDA) to support research on treatment for opioid use disorder (OUD) in criminal justice settings. Twelve grants were awarded to develop a Community Opioid Innovation Network (JCOIN) to shore up the response capacity of the justice system to the opioid epidemic. Awards total approximately $155 million for a multi-year initiative in which research investigators will collaborate with justice and behavioral health stakeholders to identify promising interventions on adoption of new medications, retention of individuals in treatment, and preventing relapse after community re-entry. JCOIN is part of the National Institute of Health grants called HEAL (Helping to End Addiction Long-term Initiative). SAMHSA Suicide Prevention Resource Center Hosts Webinar The Suicide Prevention Resource Center (SPRC) will host a webinar on the intersection between serious mental illness (SMI) and suicide Monday, July 29 at 4:30 p.m. ET. Webinar panelists will present an overview of approaches to addressing suicide risk for patients diagnosed with SMI who are seen in health and behavioral health organizations. Individuals with SMI are at higher risk of dying by suicide. Informational resources will be shared, as well as tailored interventions, methods of engagement, and supporting family and friends. SPRC is funded under a grant by the Substance Abuse and Mental Health Services Administration to advance the implementation of the National Strategy for Suicide Prevention. For questions or comments about CEO Update, please contact Jessica Zigmond.

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House Energy and Commerce Committee Advances No Surprises Act The House Energy and Commerce Committee this week approved legislation to end “surprise” medical bills with the addition of third-party arbitration. House Energy and Commerce Committee Chairman Frank Pallone (D-N.J.) and Rep. Greg Walden (R-Ore.), the panel’s ranking member, co-sponsored the No Surprises Act, which advanced through the committee as part of the Reauthorizing and Extending America’s Community Health Act with amendments. Under the bill, healthcare facilities would be required to notify patients at least 24 hours before an elective treatment that an out-of-network provider would be involved in their care. The bill also would prohibit healthcare facilities and providers from balance-billing patients for that care and would establish rates for payments from commercial health plans to providers based on the local market. The initial bill did not include a process for providers and payers to challenge the basic median reimbursement, while the amended version that passed this week includes such a process. Overall hospital groups responded both favorably and cautiously to the news, suggesting that while the bill is significant for offering an arbitration option, the legislation could also set a precedent for the federal government to set private rates. The legislation now moves to the full House for a vote. JAMA Pediatrics Study Shows Parental Drug Use Has Led to Increase in Foster Care Cases A new JAMA Pediatrics study suggests that greater parental drug use has contributed to a rise in foster care caseloads and coincides with increasing trends in opioid use and overdose deaths. Researchers from Weill Cornell Medical College and Harvard Medical School examined data from the Adoption and Foster Care Analysis and Reporting System, a federally mandated collection system that receives case-level information on all children in foster care in the United States. They found that after more than a decade of declines in U.S. foster care caseloads, cases have risen steadily since 2012. Meanwhile, the number of foster care entries attributable to parental drug use rose substantially to 96,672 home removals from 39,130 removals between 2000 and 2017, reflecting a 147-percent increase during that period, according to the findings. “These findings suggest that greater parental drug use has contributed to increases in foster care caseloads and coincide with increasing trends in opioid use and overdose deaths nationwide during this period,” the study said. The authors noted the study’s limitations include potential reporting inconsistencies in parental drug use, and that it’s possible that factors other than drug use influenced entries for parental drug use. “Policymakers must ensure that the needs of this new wave of children entering foster care because of parental drug use are being met through [sic] high-quality foster care interventions,” the study said. “These have been shown to mitigate some of the adverse effects of early childhood deprivation and disruptions in attachment.” NQF Convenes Opioid Use Disorder TEP and Seeks Comment The National Quality Forum (NQF) will convene a Technical Expert Panel (TEP) to oversee a review of measures and concepts related to opioid use, opioid use disorder prevention, treatment, and recovery. In its announcement, the NQF said the move is meant to “further identify measure gaps and priorities relevant to the United States opioid overdose epidemic and the broad healthcare quality challenges that surround it.” The TEP will provide guidance on the environmental scan of current measures; identify and prioritize measure gaps in quality measurement to inform future measure development efforts; and provide recommendations on the use of opioids and opioid use disorder measures in federal programs. The NQF will accept comments on this process through July 26. Also this week, the NQF together with the Blue Cross Blue Shield Association releasedEnhancing Access to Medication-Assisted Treatment, a guide that provides strategies, implementation examples, tools, and resources to help healthcare delivery systems, practitioners, and payers expand using MAT. Netflix Removes Suicide Scene from ‘13 Reasons Why’ Netflix Inc. has removed a suicide scene from an episode in the first season of its teen drama “13 Reasons Why” after some debate over whether the show increased the risk of teen suicide. The Wall Street Journal reported this week that although a Netflix spokesman declined to comment, the company tweeted on July 16 that, based on advice from medical experts, the company decided to edit the scene from the episode. The National Institutes of Health released a study in late April that suggested “13 Reasons Why”—which premiered in March 2017—was a factor in increased teen suicides in the United States (see CEO Update, May 3, 2019). HRSA Awards $20 million to 27 Organizations to Increase Rural Workforce HHS’ Health Resources and Services Administration (HRSA) awarded about $20 million in Rural Residency Planning and Development Program (RRPD) grants to help boost the nation’s rural healthcare workforce. Recipients across 21 states will receive up to $750,000 over a three-year period to develop new rural residency programs. The funding is part of HRSA’s multi-year initiative to expand the physician workforce in rural areas by developing new, sustainable residency programs in family medicine, internal medicine, and psychiatry. Grant recipients include rural hospitals, community health centers, health centers that the Indian Health Service operates, Indian tribes or tribal organizations, and schools of medicine. Click hereto the see the list of grant awards. SAMHSA Releases Guidance to States on Using MAT in Criminal Justice Settings The Substance Abuse and Mental Health Services Administration (SAMHSA) has released a guide to states on using medication assisted treatment (MAT) in criminal justice settings. Use of Medication-Assisted Treatment for Opioid Use Disorder in Criminal Justice Settings is a 76-page resource that focuses on using MAT for opioid use disorder in the nation’s jails and prisons during the reentry process when justice-involved persons return to the community. It provides an overview of policies and evidence-based practices that reduce the risk of overdose and relapse. SAMHSA to Host Virtual Learning Series on Recovery SAMHSA will host a three-part virtual learning series focused on recovery supports for people considering using MAT for opioid use disorder or co-occurring disorders. Held on consecutive Wednesday afternoons — July 24, July 31, and August 7 — each hourlong session will feature presenters who will address common misperceptions about MAT; offer up-to-date, accurate information; and suggest ways to learn more and educate others about opioid use disorders, co-occurring disorders, and MAT. These free events will take place from 2 p.m. to 3 p.m. ET. Click here to register. For questions or comments about CEO Update, please contact Jessica Zigmond.

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New Quality Summit to Assess HHS’ Quality Programs HHS Deputy Secretary Eric Hargan this week announced the department’s new Quality Summit, which will join government leaders and healthcare industry stakeholders to discuss how to adapt and streamline HHS’ current quality programs in a way that improves outcomes for patients. Hargan will co-chair the Quality Summit with Peter Pronovost, M.D., Ph.D., an internationally renowned expert on healthcare quality and patient safety. In March, Hargan discussed the regulatory barriers that often hinder treatment during his presentation at the 2019 NABH Annual Meeting in Washington. “Over the last decade we have seen efforts by HHS to incentivize the provision of quality care, only to be met with limited success,” Hargan said in a news release. “This is in part because patients have not been empowered with meaningful or actionable information to inform their decision making. At the same time, important quality programs across the department have remained uncoordinated among the various agencies and inconsistent in their demands on healthcare providers,” he added. “We believe the Quality Summit will not only strengthen the protections these programs afford patients, but also improve value by reducing costs and onerous requirements that are placed on providers and ultimately stand between patients and the high-quality care they deserve.” Late last month, President Trump signed the Improving Price and Quality Transparency in American Healthcare to Put Patients First executive order, which directs federal agencies to develop a Health Quality Roadmap intended to align and improve reporting on data and quality measures across federal health programs. OIG Report Finds Opioid Use Decreased and MAT Increased Among Medicare Part D Beneficiaries A new report from HHS’ Office of Inspector General (OIG) found a significant decrease in the number of Medicare Part D beneficiaries who received opioids in 2018 and a steady increase in the number of beneficiaries who received drugs for medication assisted treatment (MAT). Nearly three in 10 Medicare part D beneficiaries received opioids in 2018, the OIG reported, while at the same time the number of beneficiaries who received MAT for opioid use disorder reached 174,000. Meanwhile, about 354,000 beneficiaries received high amounts of opioids in 2018, with about 49,000 of them at serious risk of opioid misuse or overdose—which was also fewer than in the previous two years. “Progress has been made in decreasing opioid use in Part D, increasing the use of drugs for medication assisted treatment, and increasing the availability of naloxone,” the OIG reported noted. “It is imperative for the Department of Health and Human Services— including CMS (Centers for Medicare and Medicaid Services) and OIG— to continue to implement effective strategies and develop new ones to address this epidemic.” O’Neill Institute Evaluates Democratic Candidates’ Views on Addiction and Opioid Crisis The O’Neill Institute at Georgetown Law this week released an analysis of the 2020 Democratic presidential candidates’ plans to address America’s continued opioid crisis. In a post on the O’Neill Institute’s webpage this week, authors Regina LaBelle—a 2019 NABH Annual Meeting speaker—and Leigh Bianchi noted that most all of the presidential candidates have not issued detailed policy proposals on the topic. Instead, their positions on the issue were taken from statements at campaign events and from their record in public office. LaBelle and Bianchi categorized the candidates’ positions by federal officials, state and local officials, and other candidates. Click here to read their analysis. SAMHSA and CMS Issue Joint Bulletin on Addressing Mental Health and SUD in Schools The Substance Abuse and Mental Health Services Administration (SAMHSA) and CMS this week issued a joint information bulletin that describes Medicaid mandatory and optional state plan benefits and other Medicaid authorities states may use to cover mental health and substance use disorder (SUD) treatment for children in schools. The bulletin includes tools and resources to help states, educational agencies, and healthcare providers work together to identify and treat students’ mental illness or substance-related challenges in school-based settings. It also outlines best practices to help implement quality, evidence-based, and comprehensive mental illness and substance use-related services for students. Included in the 28-page bulletin are specific examples of state-level strategies for Medicaid and other financing of school-based mental health services. Study Examines Association of Nonmedical Prescription Opioid Use with Heroin Use Initiation in Adolescents A study published in JAMA Pediatrics this week found that nonmedical prescription opioid use was prospectively associated with subsequent heroin use initiation during four years of adolescence among youth in Los Angeles. Researchers conducted an eight-wave cohort study of 14-year-old and 15-year-old high school students in Los Angeles who had never used heroin at baseline and found that youth reporting no, prior, and current nonmedical prescription opioid use during high school showed estimated “cumulative probabilities” of subsequent heroin use initiation by the end of the 42-month follow-up of 1.7 percent, 10.7 percent, and 13.1 percent, respectively. The reason for the study stemmed from the concern that nonmedical prescription opioid use is associated with increased risk later of heroin use initiation among adolescents but that longitudinal data addressing this topic are lacking. The study’s authors noted that future research is needed to determine whether this association is causal. House Energy and Commerce Subcommittee Hearing Will Examine Spread of Illicit Fentanyl The House Energy and Commerce Subcommittee on Oversight and Investigations will host a hearing next Tuesday, July 16 to examine the increasing threat of illicit fentanyl. The hearing announcement noted recent statistics from the Centers for Disease Control and Prevention that show there were more than 47,000 drug overdose deaths involving opioids in 2017, of which 28,000 involved synthetic opioids such as fentanyl—a nearly 47-percent increase from the prior year. Tuesday’s hearing will feature witnesses from the key federal agencies responding to the nation’s opioid crisis. CMS to Host Webinar on QIOs and IPFs Working Together to Reduce Readmissions Quality experts from CMS and quality improvement organization MPRO will lead a webinar for participants in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program next Thursday, July 18 at 2 p.m. ET. Christina Goatee, M.S.N., R.N. from CMS and Barbra Link, L.M.S.W., CIRS-A/D from MPRO will lead the hourlong webinar, Quality Improvement Organizations and Inpatient Psychiatric Facilities Working Together to Reduce Readmissions, to provide an overview of the Quality Improvement Organization (QIO) program and show how collaborative relationships with QIOs can reduce inpatient psychiatric facility readmissions and enhance outcomes. Click here to register.   For questions or comments about CEO Update, please contact Jessica Zigmond.

CMS Releases Emergency Medical Treatment and Labor Act (EMTALA) Memorandum

The Centers for Medicare & Medicaid Services (CMS) on July 2 released Frequently Asked Questions on the Emergency Medical Treatment and Labor Act (EMTALA) and Psychiatric Hospitals, a six-page memo addressing common concerns psychiatric hospitals and hospital emergency departments have regarding compliance with EMTALA. EMTALA has been a top regulatory priority for NABH and our team has worked closely with CMS on this issue. In March, NABH released The High Cost of Compliance: Assessing the Regulatory Burden in Inpatient Psychiatric Facilities, a detailed report that quantifies the compliance costs related to EMTALA for inpatient psychiatric care providers. The analysis—which NABH commissioned Manatt Health to produce—also addresses ligature risk, a topic CMS addressed this past April in draft guidance. Here are key excerpts from CMS’ July 2 FAQ Memo:
  • 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.
Read the full memo here.

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CDC Provisional Data Show Opioid Deaths Likely to Fall for First Time Since 1990 Provisional data from the Centers for Disease Control and Prevention (CDC) show drug-overdose deaths are on the brink of declining, but researchers are quick to caution the nation’s deadly opioid crisis is far from over. The CDC’s data predict there were nearly 69,100 drug deaths in the 12-month period ending in November 2018, down from almost 72,300 predicted deaths for the same 12-month period ending in 2017. If the trend continues through December— those data likely will be available next month—then annual drug deaths will fall for the first time since 1990, when about 8,400 people died from overdoses. “I think we’re probably looking at a decline,” Robert Anderson, Ph.D. chief of the Mortality Statistics branch at the CDC’s National Center for Health Statistics, told the Wall Street Journal this week. “We shouldn’t say oh, we’ve won and we’ve defeated the drug-overdose epidemic.” The story reported that health officials and epidemiologists say there is little cause for celebration, especially as the death rate remains “swollen by powerful synthetic opioids like fentanyl.” Meanwhile, the story noted one driving factor for the downward trend has been broadened access to the overdose-reversal drug naloxone, often known by the brand-name Narcan, according to officials in Ohio, Pennsylvania, and Rhode Island. Jim Hall, an epidemiologist at Nova Southeastern University in Florida, echoed Anderson’s measured optimism in his interview with the Wall Street Journal. “I’m ready to say that the opioid crisis in in early remission, yet at a high risk of relapse,” Hall said. CMS Announces Funding Opportunity for State Medicaid Agencies to Address SUD The Centers for Medicare & Medicaid Services (CMS) announced this week that up to $50 million is available to help increase capacity for Medicaid providers to deliver substance use disorder (SUD) treatment and recovery services. The Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act authorized the planning grant funding, which is available to at least 10 states for 18 months, CMS announced in the funding opportunity notice. Meanwhile, up to five states that receive planning grants will be chosen to implement 36-month demonstration projects and receive enhanced federal reimbursement for increased expenditures for SUD treatment and recovery services. Click here to learn more and apply for a grant. Veterans with PTSD More Likely to Die from Suicide, Hepatitis Veterans with post traumatic stress disorder (PTSD) have a higher risk of dying from mental illness and other diseases than the general population, according to a new study published in the American Journal of Preventive Medicine. The study’s researchers analyzed mortality data from nearly 500,000 veterans who started treatment for their PTSD at a Veterans Affairs (VA) medical center between 2008 and 2013 and found that veterans with PTSD were about twice as likely to die from suicide, accidental injuries, and hepatitis than the general population. The study acknowledged a few limitations related to both the sample selection and follow-up. For one, the study’s approach did not account for relevant confounders, including race/ethnicity, psychiatric and medical comorbidity, and treatment. “Although the cohort was started in 2008 to account for changes in the VA delivery of evidence-based PTSD care, this study did not address patient-level treatment characteristics and was not designed to determine whether PTSD care affects mortality.” NABH Supports BETTER Act to Expand Medicare Telehealth Benefits NABH was one of more than a dozen organizations this week that signed a letter supporting the bipartisan Beneficiary Education Tools Telehealth Extender Reauthorization (BETTER) Act of 2019, a House bill intended to improve Medicare’s telehealth benefits for patients who need mental health services. In a letter to Reps. Richard Neal (D-Mass.) and Kevin Brady (R-Texas), the chairman and ranking member, respectively, of the House Ways and Means Committee, NABH and 13 other groups this week noted that CMS reports mental disorders are at the top of diagnoses for Medicare beneficiaries receiving telehealth services in 2016. “However, current law restrictions prohibiting the receipt of telehealth services in the home and limiting coverage to specific geographic areas hamper the accessibility of effective mental health services to treat Medicare beneficiaries,” the letter said. “We are very pleased that H.R. 3417 removes these barriers and allows Medicare patients to access psychotherapy services through telehealth no matter where they live and in their own homes. NABH Supports CREATE Act to Expand MAT Programs for Incarcerated Individuals with OUD NABH and other member organizations of the Coalition to Stop Opioid Overdose (CSOO) sent a letter this week to the federal lawmakers who introduced the Community Re-entry through Addiction Treatment to Enhance (CREATE) Opportunities Act, which is intended to expand Medication Assisted Treatment (MAT) programs for individuals with opioid use disorder (OUD) who are incarcerated. Specifically, the legislation from Rep. Ann Kuster (D-N.H.) and Sen. Ed Markey (D-Mass.) would provide $50 million each year from fiscal year 2020 through fiscal year 2023 for the U.S. Attorney General to make grants and enter into cooperative agreements with states and local governments to develop, implement, or expand programs to provide MAT to individuals who have OUD and are incarcerated. The bill also includes requirements for the covered programs. Click here to read the letter from the CSOO. CEO Update Will Publish Next on Friday, July 12 NABH’s office will be closed on July 4 and 5 for Independence Day and will not publish CEO Update next week. CEO Update will publish next on Friday, July 12. The entire NABH team wishes you a happy and safe Independence Day weekend!   For questions or comments about CEO Update, please contact Jessica Zigmond.

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NABH Submits FY 2020 IPF PPS Rule Comments to CMS NABH this week urged the Centers for Medicare & Medicaid Services (CMS) not to include any new measures in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) program, but instead work with the behavioral healthcare provider community to improve existing measures. That was the broad message in NABH’s comment letter to CMS about the agency’s proposed fiscal year (FY) 2020 inpatient psychiatric facility prospective payment system (IPF PPS) rule. Commenting on CMS’ proposal to develop a new measure for a standardized patient perception of care, NABH President and CEO Mark Covall explained that the majority of NABH members participating in the IPFQR program use some version of a patient perception of care measure; however, there is not one single measure that all providers or a majority of providers use. “Therefore, we have strong concerns that CMS will make it mandatory for behavioral healthcare providers to adopt something such as the Hospital Consumer Assessment of Healthcare Provider and Systems (HCAHPS) survey,” Covall wrote. NABH also recommended CMS work closely with the behavioral healthcare provider community to develop a safety-planning measure for patients who have suicidal ideation. Click here to read NABH’s letter. SAMHSA Releases The Behavioral Health Barometer, Volume Five The Substance Abuse and Mental Health Services Administration (SAMHSA) has released volume five of The Behavioral Health Barometer, one of a series of national, regional, and state reports that offer a glimpse of behavioral health in the United States. “Behavioral Health Barometers for the nation, 10 regions, and all 50 states and the District of Columbia are published as part of SAMHSA’s behavioral health quality improvement approach,” Elinore McCance-Katz, M.D., Ph.D., assistant secretary for mental health and substance use at SAMHSA, wrote in the report’s foreword. “Most importantly, the Behavioral Health Barometers provide critical information in support of SAMHSA’s mission of reducing the impact of substance abuse and mental illness on America’s communities.” The 74-page report examines youth, young adult, and adult mental health and substance use as well as adult mental health and mental health service use. SAMHSA also included a special focus on the misuse of prescription pain relievers, heroin use, and medication assisted therapy for opioid addiction. AMA Passes Opioid Policies that Address Barriers to Effective Treatment The American Medical Association (AMA) has approved several opioid-related policies meant to shift the focus of pain treatment back on patients and away from what the association referred to as “arbitrary third-party controls.” Physicians accepted the resolutions at the Chicago-based association’s annual meeting last week. In a news release, the AMA said the measures take aim at barriers to treatment that state and federal authorities, insurers, pharmacy benefit management (PBM) companies, and national pharmacy chains have enacted. ““The barriers include tactics such as prior authorization and step therapy – which can delay treatment – and misguided laws and other policies setting hard thresholds for prescriptions,” the announcement said. One proposal recommends developing treatment plans based on individual needs, rather than a one-size-fits-all approach of hard thresholds. Another measure opposes pharmacies, PBMs, and insurers using “high prescriber lists,” without due process, to keep physicians from writing prescriptions for controlled substances and preventing patients from filling prescriptions at their pharmacy of choice. Opioid Crisis Increases Number of Organs Available for Transplant Taken together, America’s opioid crisis and organ shortage have led the nation’s surgeons to consider transplanting organs deemed less than “perfect” in an effort to expand the donor pool and save more lives, according to new research published in The Annals of Thoracic Surgery. Nader Moazami, M.D. of NYU Langone Health in New York and his colleagues evaluated trends in organ donation and transplants among drug overdose deaths using data from the Scientific Registry of Transplant Recipients between 2000 and 2017. They found that of the 15,904 isolated heart transplants from adult donors during this period, opioid overdoses (10.8 percent) were the fourth common cause of death, behind blunt injury (30.5 percent), hemorrhage/stroke (22.1 percent), and gunshot wound (18.3 percent). “The opioid epidemic has increased the proportion of hearts transplanted from overdose death donors (ODD),” Moazami said in a news release from the Society of Thoracic Surgeons. “One of the roles of the transplant community is to at least partially mitigate the tragedy of this exponentially growing problem by maximizing the utilization of organs from ODD.” JAMA Psychiatry Study Finds Fewer Psychiatrists Accepting Medicaid Patients Post Expansion Fewer psychiatrists are accepting Medicaid patients even as more patients have gained coverage under the federal insurance program, according to a recent research letter published in JAMA Psychiatry. Although Medicaid is the principal payer of behavioral health services in the United States, little is known about recent trends in psychiatrists’ acceptance of Medicaid patients, the letter said. For this analysis, researchers used data from the 2010-2015 National Ambulatory Medical Care Survey (NAMCS), a nationally representative survey of physicians who were not federally employed, based in offices, and primarily engaged in patient care. The study found the number of psychiatrists accepting Medicaid patients fell to 35 percent between 2014-2015 from nearly 48 percent between 2010-2011. “This study was limited by the relatively small physician sample size in the NAMCS and only 2 years’ post expansion data in most expansion states,” the research letter said. “Furthermore, low Medicaid participation among primary care physicians has been attributed to low Medicaid physician fees, reimbursement delays, and administrative burden,” it added. “However, we lacked data to explore the relative importance of these potential factors in psychiatrists’ decision to accept Medicaid patients.” A Reuters story about the findings quoted the study’s co-author Adam Wilk, who said he suspects the nation’s shortage of psychiatrists is the reason why they haven’t expanded their capacity to accept Medicaid patients. “Market deficiencies allow psychiatrists to make more money by taking patients who have private insurance,” Wilk, an assistant professor of health policy and management at Emory University’s Rollins School of Public Health, told Reuters. “In fact, there’s a rising trend among psychiatrists of opting out of insurance altogether.”  JAMA Pediatrics Study Suggests Sexting Associated with Sexual Behaviors and Mental Health Risk Factors in Adolescents A meta-analysis of 23 studies has found that adolescent sexting is significantly associated with sexual activity, multiple sexual partners, lack of contraception use, delinquent behavior, internalizing problems, and substance use. Published in JAMA Pediatrics, the analysis comprising 41,723 participants found the association between sexting and multiple sexual partners, drug use, smoking, and internalizing problems were stronger in younger compared with older adolescents. “Results of this study suggest that sexting is associated with various sexual behaviors and mental health risk factors,” the authors noted in the study. “Moving forward, education campaigns should focus on providing youth with comprehensive information about sexting and digital citizenship.” Justice Department Releases Grant Solicitation for Rural Communities to Address Opioid Crisis The U.S. Justice Department’s Bureau of Justice Assistance (BJA) has announced the Rural Responses to the Opioid Epidemic Grant solicitation, which is intended to build local capacity, foster cross-sector collaboration, and support innovation to address the nation’s deadly opioid crisis. BJA is sponsoring the initiative with the Centers for Disease Control and Prevention and the State Justice Institute and will select up to eight rural communities or regions for grant awards up to $750,000, each for a 24-month period. BJA has scheduled a webinar to discuss the grant application process for Wednesday, June 26 at 2:30 p.m. ET. Applications are due by Friday, July 26. National Consortium of Telehealth Resource Centers Announces Webinars on Telehealth for SUD The National Consortium of Telehealth Resource Centers will explore what type of substance use disorder services a community health center can offer via telehealth in a webinar next Friday, June 28 at 9 a.m. ET. Click here to register. For questions or comments about CEO Update, please contact Jessica Zigmond.

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Representatives Porter, Bilirakis, and Norcross Introduce Mental Health Parity Compliance Act Reps. Katie Porter (D-Calif.), Gus Bilirakis (R-Fla.), and Donald Norcross (D-N.J.) this week introduced the Mental Health Parity Compliance Act, the House version of the bill that Sens. Bill Cassidy, M.D. (R-La.) and Chris Murphy (D-Conn.) introduced last week. The legislation is based on a best-practice approach that state legislatures in Delaware, Illinois, New Jersey, and Washington, D.C. have enacted and ensures that health insurance providers are following the 2008 Mental Health Parity and Addiction Equity Act. “As part of removing the stigma for treating mental illness, we must ensure that mental health needs are recognized as legitimate healthcare issues,” Bilirakis said in a news release. “One way to do that is to ensure parity between coverage for healthcare and mental healthcare services—which happens to be the law.” NABH, a Mental Health Liaison Group member, signed on to letters supporting both the House and Senate bills. CMS Issues Request for Information for its Patients Over Paperwork Initiative The Centers for Medicare & Medicaid Services (CMS) recently issued a Request for Information (RFI) seeking new ideas from the public about how to continue the agency’s Patients over Paperwork initiative. Launched in 2017, Patients over Paperwork has worked to streamline regulations in healthcare that often take clinicians away from their primary purpose of caring for patients. The new RFI provides an opportunity for the public to share ideas that were not suggested during the first RFI period two years ago. Specifically, CMS is looking for ways to improve reporting and documentation requirements; coding for Medicare and Medicaid payments; prior authorization procedures; policies and requirements for rural providers, clinicians, and beneficiaries; policies and requirements for dually enrolled beneficiaries; beneficiary enrollment and eligibility determination; and CMS processes for issuing regulations and policies. In its comments to CMS, NABH will highlight The High Cost of Compliance, the association’s report that assessed the regulatory burden on the nation’s inpatient psychiatric facilities. Released in March, the report found that three specific regulatory areas impose $1.7 billion in compliance costs each year nationwide, which represent 4.8 percent of an average facility’s annual revenue for all inpatient psychiatric services from all sources. NABH will continue to work with CMS to address the report’s key findings and recommendations. Comments are due by Monday, August 12. HHS’ Office of Adolescent Health Releases Updated Data on Nation’s Teens New data from HHS’ Office of Adolescent Health (OAH) show 31 percent of U.S. high school students in 2017 reported they felt sad or hopeless almost every day for at least two weeks in a row in the past year. The findings are part of OAH’s updated national and state data sheets, which OAH released June 10 to provide estimates on a range of measures related to adolescent health and behavior. The analysis draws on large, nationally representative surveys, and measures include physical activity and nutrition, mentorship, family meals, cigarette and e-cigarette use, driving under the influence, depression systems, bullying, dating violence, and more. ASPE and RTI Recruiting Organizations to Participate in Telehealth Case Studies HHS’ Office of the Assistant Secretary for Planning and Evaluation (ASPE) and RTI International are recruiting organizations to participate in case studies as part of their new assessment of telehealth to treat mental and substance use disorders in youth and adolescent patients. According to ASPE, the goal of the project is to better understand how telehealth is used for these populations; what challenges providers and patients face; and what innovations are happening. This project will especially focus on understanding what policies influence the use of telehealth, including the role of Medicaid in promoting access to telehealth programs. RTI is recruiting organizations to participate in case studies, which will consist of RTI staff conducting in-person discussions with individuals involved in providing, coordinating, and supporting telehealth services (such as administrators, clinicians, and peer support specialists), and a walk-through of the site’s general telehealth model and the technology that is used for it. Discussions during the site visits will focus on challenges the organization may have encountered, strategies employed to overcome these challenges, and overall lessons learned in implementing telehealth to support the delivery of behavioral healthcare. Please e-mail Sarah Wattenberg, NABH’s director of quality and addiction services, if you would like your organization to participate. SAMHSA Accepting Applications for Mental and Substance Use Disorder Practitioner Data Grant The Substance Abuse and Mental Health Services Administration (SAMHSA) is accepting applications for its fiscal year 2019 Mental and Substance Use Disorder (SUD) Practitioner Data grant, which is intended to provide comprehensive data and analysis on individuals who address these conditions. According to the funding notice, the program’s goal is to provide valid data on existing practitioners and usable information to SAMHSA that the agency can use to make policy and planning decisions. SAMHSA said total available funding is $1 million, and applications are due by Monday, Aug. 12. Click here to learn more and apply. CDC Study Examines Connection Between Prescription Opioid Misuse and Binge Drinking More than half of the 4.2 million people who misused prescription opioids during 2012-2014 were binge drinkers, and binge drinkers had nearly twice the odds of misusing prescription opioids, compared with non-drinkers, according to a new study published in the American Journal of Preventive Medicine. Binge drinking is consuming four or more drinks for women and consuming five or more drinks for men, according to the Centers for Disease Control and Prevention (CDC), which conducted the study. The CDC’s analysis shows that people who binge drank were nearly twice as likely to misuse prescription opioids as non-drinkers, even after accounting for other factors that could affect the relationship between prescription opioid misuse and binge drinking, such as age and sex. For this report, CDC researchers analyzed data from the National Survey on Drug Use and Health for 2012, 2013, and 2014 on self-reported binge drinking and prescription opioid misuse during the past 30 days. Scientists found that while young people who binge drank and had higher rates of prescription opioid misuse, two in three people who binge drank and misused prescription opioids were age 26 years and older. Study Finds Association Between Medical Cannabis Laws and Opioid Overdose Mortality Has Reversed Over Time Claims that enacting medical cannabis laws will reduce opioid overdose death should be met with skepticism, researchers noted in a new study in the Proceedings of the National Academy of Sciences (PNAS). Published earlier this week, the study explains that medical cannabis has been touted as a solution to the nation’s opioid overdose crisis since an earlier study found that from 1999 to 2010 states with medical cannabis laws experienced slower increases in opioid analgesic overdose mortality. This recent study used the same methods to extend that analysis through 2017 and concluded that not only did the findings from the original analysis not hold over the longer period, but the association between state medical cannabis laws and opioid overdose mortality reversed direction from -21 percent to +23 percent and remained positive after accounting for recreational cannabis laws. “A more plausible interpretation is that this association is spurious,” the researchers noted. “Moreover, if such relationships do exist, they cannot be rigorously discerned with aggregate data,” they added. “Research into therapeutic potential of cannabis should continue, but the claim that enacting medical cannabis laws will reduce opioid overdose death should be met with skepticism.” NABH Submits Comment Letters to CMS and FCC Extending an Electronic Health Record (EHR) incentive to behavioral healthcare providers and repurposing a national “N11” number for a suicide hotline were the topics of two comment letters that NABH sent recently to CMS and the Federal Communications Commission (FCC). In a letter to CMS, NABH said only a small portion of behavioral healthcare providers are using EHRs. According to data from CMS’ IPFQR program, about 30 to 40 percent of psychiatric hospitals use EHRs, a level that has remained constant. The fiscal year 2019 (FY19) Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) rule emphasizes this, noting: “performance on this measure [use of and electronic health record] has remained relatively static for the past two program years.” NABH urged CMS to establish a program—perhaps within the Innovation Center— that would extend EHR incentives to the behavioral healthcare providers who were excluded from the Health Information Technology for Economic and Clinical Health Act. Extending this funding to behavioral healthcare providers will do far more to improve care for Medicare beneficiaries than any change to conditions of participation, NABH President and CEO Mark Covall noted. The association also sent a letter this month to FCC Secretary Marlene Dortch asking the agency to establish a national number, or N11 number, for a national suicide prevention and mental health crisis hotline system. “Based on the urgency of the suicide crisis and the nature of suicidal ideation, the potential positive outcomes outweigh any costs associated with changing an existing N11 number,” Mark Covall wrote. “This is why we strongly encourage the FCC to move forward immediately and repurpose an existing N11 number for a national suicide prevention and mental health crisis hotline system.” Call for Presentations Now Open for Rx Drug Abuse & Heroin Summit 2020 The Rx Drug Abuse & Heroin Summit is now accepting submissions for its meeting in Nashville, Tenn. from April 13-16, 2020. The Summit will accept presentation proposals in two formats: breakout sessions lasting 75 minutes (including a question-and-answer period), and posters, which will be featured in the exhibit hall. All submissions are due by midnight ET on Friday, August 23. Click here for submission details. Learn about Recovery Centers of America in NABH’s Latest Member Profile! NABH member Recovery Centers of America has created a specialized program called Promoting Recovery through Intensive Support and Education, or PRISE, at its facility in Devon, Pa. to address the problem of multiple relapses for patients seeking addiction treatment. PRISE relies on a three-pronged, therapeutic, evidence-based approach to help patients who have relapsed. Click here to learn more. For questions or comments about CEO Update, please contact Jessica Zigmond.