Author: Administrator
CEO Update 105
SAMHSA Offers Guidance and Forms for Medicaid/CHIP Provider Relief Fund Payments
HHS’ Substance Abuse and Mental Health Services Administration (SAMHSA) is providing guidance, instructions, and application forms after HHS announced this week it will distribute $15 billion to eligible Medicaid and Children’s Health Insurance Program (CHIP) providers during the Covid-19 pandemic. HHS said the payment to each provider will be at least 2% of reported gross revenue from patient care. The department also said the final amount each provider receives will be determined after the data is submitted, including information about the number of Medicaid patients providers serve. According to SAMHSA, before applying to the enhanced provider relief portal, applicants should read the Medicaid provider distribution instructions and download the Medicaid provider distribution application form.Independent Task Force Recommends Screening All Adults for Unhealthy Drug Use
The U.S. Preventive Services Task Force (USPSTF) this week recommended that all adults 18 and older be screened regularly for unhealthy drug use, which is defined as using illegal drugs or taking medications not specified for a medical reason. Previously the agency did not issue a recommendation on the subject, saying there was insufficient evidence to suggest regular screening. This new guidance follows a review of studies that evaluated the sensitivity of screening tools—most of which were moderately or highly accurate in identifying unhealthy drug use. Established in 1984, USPSTF is an independent, volunteer panel of national experts in prevention and evidence-based medicine. The group works to improve the health of all Americans by making evidence-based recommendations about clinical preventive services such as screening, counseling services, and preventive medications. The task force’s views are not meant to be construed as those of HHS or HHS’ Agency for Healthcare Research and Quality (AHRQ).AHRQ Requests Information on Older Adult Opioid Use and Misuse in Primary Care Settings
AHRQ this week issued a notice requesting public comments on identifying and testing strategies for management of opioid use and misuse in older adults in primary care practices. According to the notice, this project is meant to assess and describe the current prevalence, awareness, and management of opioid use, misuse, and abuse in older adults, and identify the gaps and areas of needed research. “Additionally, this project will support primary care practices in developing and testing innovative strategies, approaches, and/or tools for opioid management within the context of facilitated learning collaboratives, culminating in a compendium of strategies for opioid management in older adults in primary care settings,” the notice said. Click here to learn more about the project and how to submit comments within 60 days of the June 8 notice.ONDCP to Launch Rural Community Toolbox Website on June 24
The White House Office of National Drug Control Policy and senior Trump Administration officials will virtually launch the Rural Community Toolbox website, a resource for rural communities affected by addiction, on Wednesday, June 24. The Rural Community Toolbox is intended to serve as a clearinghouse for funding and resources in more than a dozen different federal agencies to help rural leaders build healthy, drug-free communities. Click here for more information when it becomes available and to register for the virtual launch, which will begin at 3 p.m. ET.NABH President and CEO Shawn Coughlin Participates in Project Wake Up Panel Discussion
NABH President and CEO Shawn Coughlin was one of seven panelists to participate in an in-depth panel discussion about mental health stigma and suicide in America. Project Wake Up led the June 11 panel as a follow-up to the world premiere last week of Wake Up, a documentary about suicide, ending mental health stigma, and making sure people who need treatment receive it. Former U.S. Rep. Patrick Kennedy (D-R.I.), Craig Bryan, Psy.D. of the Ohio State University’s psychology department, Morissa Henn of InterMountain Healthcare, and Michael Zibilich, whose son died by suicide in 2012, were among the other panelists.Fact of the Week
Buprenorphine treatment rates by primary care providers increased from 12.9 people per 10,000 population in 2010 to 27.4 in 2018. For questions or comments about this CEO Update, please contact Jessica Zigmond.
HHS Announces Relief Funding for Medicaid & CHIP Providers, Safety Net Hospitals
HHS said Tuesday it expects to distribute about $15 billion through the department’s Health Resources and Services Administration (HRSA) to eligible providers who participate in state Medicaid and CHIP programs and have not received a payment from the Provider Relief Fund General Distribution.
HRSA will also distribute about $10 billion from the Provider Relief Fund to the nation’s safety-net hospitals, which is expected to happen this week.
HHS said it will launch an enhanced Provider Relief Fund Payment Portal on Wednesday that is intended to allow eligible Medicaid and CHIP providers to report their annual patient revenue, which will be used as a factor for HHS to determine their Provider Relief Fund payment.
According to an announcement, the payment to each provider will be at least 2% of reported gross revenue from patient care. HHS said it will determine the final amount that each provider receives after data is submitted, including information about the number of Medicaid patients providers serve.
To be eligible for this funding, healthcare providers must not have received payments from the $50 billion Provider Relief Fund General Distribution and either have directly billed their state Medicaid/CHIP programs or Medicaid managed care plans for healthcare-related services between January 1, 2018, to May 31, 2020.
On Monday, HHS contacted all hospitals, asking them to update information on their COVID-19 positive-inpatient admissions for the period January 1, 2020, through June 10, 2020. This information will be used to determine a second round of funding to hospitals in COVID-19 hotspots to ensure they are equitably supported in the battle against this pandemic. To determine their eligibility for funding under this $10 billion distribution, hospitals must submit their information by June 15, 2020 at 9:00 PM ET.
HHS said close to 1 million healthcare providers may be eligible for these patients. Click here for more information about eligibility and the application process.
CEO Update 104
Psych Hub Releases Race, Racism & Mental Health Resources During Week of Protests
Mental health educational platform Psych Hub released Race, Racism, & Mental Health Resources for individuals and communities amid a week of national and global protests against racism and police brutality following the death of George Floyd. Psych Hub compiled the list of resources on antiracism and Black mental health that includes links to organizations, online resources, books, and social media. “Experiencing and witnessing racism in any of its forms has traumatic effects that can build up with time and repetition,” the resources page noted. Also this week, NABH President and CEO Shawn Coughlin made a statement on Twitter and LinkedIn that included a link to the Substance Abuse and Mental Health Services Administration’s (SAMHSA) behavioral health equity page. “Racism and all acts of discrimination cause suffering, fear, anxiety, and depression,” Coughlin said. “We must advocate for behavioral health equity: the right to access quality healthcare for all populations, regardless of a person’s race, ethnicity, gender, socioeconomic status, sexual orientation, or geographical location.” NABH joined Psych Hub as a partner this year.NABH Sends CMS Recommendations on Additional CoP
NABH this week sent a letter to the Centers for Medicare & Medicaid Services (CMS) outlining the association’s concerns with additional conditions of participation (CoP) for behavioral healthcare providers and recommendations to provide some regulatory relief. The letter also urged continued expanded coverage of behavioral healthcare services via telehealth. “The additional Conditions of Participations (CoP) for psychiatric hospitals and accompanying sub-regulatory guidance in the State Operations Manual (known as the B-tags) impose more than $625 million in additional costs annually, according to a recent study,” NABH President and CEO Shawn Coughlin wrote in the letter to CMS Administrator Seema Verma. “The Covid-19 pandemic has added to the strain on these facilities with additional financial losses and unexpected costs, including those related to greatly increased personal protective equipment, screening everyone coming into the facility, additional staffing needs for screening, and other infection control measures, including isolation rooms and units, software and hardware purchases to facilitate telework for administrative staff and telehealth for patients, and lost revenue due to decreased patient volume because of infection concerns and reduced referrals,” he added. NABH’s Covid-19 task force contributed to and reviewed the final letter, which is available on the association’s homepage and Covid-19 resources page.HRSA Awards $20.3 Million to Expand Addiction Workforce in Underserved Communities
HHS’ Health Resources and Services Administration (HRSA) this week announced it awarded $20.3 million to 44 recipients to increase the number of fellows at accredited addiction medicine and addiction psychiatry fellowship programs. HRSA’s Addiction Medicine Fellowship program is part of the agency’s effort to fight the nation’s ongoing opioid crisis. The awardees will train addiction specialists at facilities in high-need communities that integrate behavioral and primary care services. “The need for physicians with the expertise and skills to provide substance use prevention, treatment, and recovery services is essential,” HRSA Administrator Tom Engels said in a news release. “Addiction specialists can respond to patients’ specific behavioral health needs and help communities that are hit hardest by the opioid epidemic.” Click here to view the list of award recipients.Health Affairs Study Explores OUD Treatment of Commercially Insured Adults
A research article published in the journal Health Affairs this week explored treatment provided to people with opioid use disorder (OUD), rather than efforts to reduce prescriptions and misuse. Analyzing claims data representing 12 million to 15 million nonelderly adults covered through commercial group insurance during the period 2008-2017, researchers examined rates of OUD diagnoses, treatment patterns, and spending, and they identified three essential patterns. “The rate of diagnosed OUD nearly doubled during 2008-19, and the distribution has shifted toward older age groups; the likelihood that diagnosed patients will receive any treatment has declined, particularly among those ages 45 and older, because of a reduction in the use of medication-assisted treatment (MAT), and despite clinical evidence demonstrating its efficacy; and treatment spending is lower for patients who chose MAT,” the article noted. The researchers noted these patterns suggest that policies supporting MAT use are “critical to addressing the undertreatment of OUD among the commercially insured” and that additional research is needed.JAMA Commentary Examines Treating Patients with OUD in Their Homes
A late May commentary in JAMA examined an emerging treatment model for OUD in recent years that uses telehealth to provide medication treatment to patients in their homes. The article notes that about 50,000 deaths from OUD overdose occur each year in the United States, and the prevalence of heroin use is increasing. And while more than 2 million people with an OUD need treatment and a rising number of individuals are receiving treatment, still less than 20% receive effective medications such as buprenorphine. According to researchers, some telehealth companies have advertised the convenience of their model in leveraging telehealth services for OUD treatment. Meanwhile, the article suggests another potential benefit. “By minimizing the need to travel and increasing privacy for patients who may not want to be seen seeking care,” the article noted, “these programs also could address the access challenges that are especially problematic for underserved patients.”NABH System Members: Please Submit Your Annual Dues!
NABH thanks its members for the excellent work they do each day to advance NABH’s mission, most especially during this unprecedented, difficult time in our nation’s history. Our mission has never been more important than it is today. This is a reminder to all NABH system members to please submit their annual dues payments if they have not done so already. NABH members’ active involvement and prompt payment are critical in helping our association achieve its vision and ensure that NABH remains the leading advocate for our nation’s behavioral healthcare providers. As we continue to navigate the Covid-19 pandemic together, we want to be sure you receive information about the work we do and the resources we provide. Please visit our website at www.nabh.org and follow us on Twitter (@NABHbehavioral), LinkedIn, and YouTube. Also, please be sure to visit our Covid-19 webpage for important guidance, external links, and other resources. Please contact NABH Director of Operations Maria Merlie if you have questions about your organization’s dues payment.Fact of the Week
More than 88,000 additional people have developed anxiety or depression due to the Covid-19 pandemic, according to new data from Mental Health America’s online screening program. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 103
HHS Extends Compliance Deadline for Providers to Receive Covid-19 Relief Funds
HHS late last week announced a 45-day, compliance deadline extension for healthcare providers who receive payments from the Provider Relief Fund to accept the department’s required terms and conditions. The extension means HHS has granted providers a total of 90 days from the time they receive payments—made available through the CARES Act and the Paycheck Protection Program and Health Care Enhancement Act— until the time they accept the department’s terms and conditions. If providers do not meet the terms and conditions, they must return the funds. Visit HHS’ Provider Relief Fund webpage for more information.The Joint Commission to Resume Surveys Next Month
The Joint Commission said this week it will resume regular surveys and reviews in June and will contact organizations due for a survey to assess the effects the coronavirus has had on their operations. The Oakbrook Terrace, Ill.-based accrediting organization said it is reviewing a variety of factors and criteria to determine which organizations will be surveyed—including identifying and prioritizing low-risk areas. In its announcement, The Joint Commission said the survey process will include changes to protect safety. For instance, the surveys will limit the number of individuals in group sessions and minimize the number of people who accompany the surveyor on tracer activities. In addition, using masks will be a routine practice, and The Joint Commission said it expects “the organization to provide masks and/or other personal protective equipment to surveyors and reviewers while on-site.” “Our survey will focus on a thorough assessment but will not retroactively review compliance,” the announcement said. “The implementation of an organization’s emergency operations plan will not be the focus of return survey activity considering the Centers for Medicare and Medicaid Services (CMS) waivers and other extensions,” it continued. “Rather, we will work to understand how you have adapted to the pandemic and review your current practices to assure you are providing safe care and working in a safe environment.” Click here to view The Joint Commission’s resources for healthcare staff fighting the Covid-19 pandemic.Recording of HHS’ Webinar on Ensuring Safety During Covid-19 Available Next Week
HHS’ Assistant Secretary for Preparedness and Response (ASPR) Technical Resources, Assistance Center, and Information Exchange (TRACIE) will host a webinar on Tuesday, June 2 featuring how healthcare providers in the field have planned and implemented operational changes during Covid-19. Registration for the 90-minute webinar is full, so HHS announced that a recording will be available 24 hours after the event. The webinar will include officials from HHS’ Health Resources and Services Administration (HRSA) and Agency for Healthcare Research and Quality (AHRQ), as well as leaders from health systems in Louisiana, Massachusetts, New York, and Washington, D.C. ONDCP Director to Lead Stakeholder Call Next Week on Supporting SUD Care in Rural America James Carroll, director of the White House Office of National Drug Control Policy (ONDCP), and other senior agency officials will host a rural stakeholder call on Tuesday, June 2 at 3 p.m. ET to discuss the changes that have been made to increase access to substance use disorder (SUD) care in rural America during the global pandemic. Leaders from the Centers for Medicare & Medicaid Services, the Substance Abuse and Mental Health Services Administration, the Centers for Disease Control and Prevention, the Department of Agriculture, and other organizations will serve as speakers during the hourlong call. Click here to learn more and to register, as space is limited.AHRQ to Host Webinar on the Role of Telehealth in Increasing Access to Care on June 9
HHS’ AHRQ will host a 90-minute webinar on Tuesday, June 9 to highlight how telehealth can increase access to care and improve healthcare quality. Presenters—including a clinical professor of psychiatry and behavioral sciences at the University of California at Davis—will discuss their work on the effectiveness of telepsychiatry, the effect of telemedicine on chronic disease management, and the facilitators and barriers to adopting urban telemedicine. Click here to learn more and to register.Fact of the Week
A joint Census Bureau-National Center for Health Statistics survey during Covid-19 global pandemic found that 24% of Americans are showing clinically significant symptoms of major depressive disorder and 30% are showing symptoms of generalized anxiety disorder. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 102
Healthcare Providers Must Act by June 3 to Receive Additional Relief Fund Payment
Eligible healthcare providers have until Wednesday, June 3 to submit their revenue information and accept all terms and conditions to receive an additional payment from the Provider Relief Fund’s $50 billion general distribution, HHS said this week. HHS’ notice said all providers who automatically received an additional general distribution payment before Friday, April 24 must provide HHS with “an accounting of their annual revenues by submitting tax forms or financial statements.” Providers must also agree to program terms and conditions if they want to keep the funds. The CARES Act and the Paycheck Protection Program and Health Care Enhancement Act provide $175 billion in relief funds to hospitals and other healthcare providers during the Covid-19 global pandemic. Previously HHS said $50 billion of the Provider Relief Fund was allocated for general distribution to facilities and providers who bill Medicare and were affected by Covid-19, based on providers’ net revenue. Of that funding, $30 billion was distributed immediately, proportionate to providers’ share of Medicare fee-for-services reimbursements in 2019. Then HHS began distributing an additional $20 billion on April 24. According to HHS, every healthcare provider who has provided treatment for uninsured Covid-19 patients on or after Feb. 4 can request claims reimbursement through HHS’ Health Resources and Services Administration portal and will be reimbursed at Medicare rates, subject to available funding. The required steps include enrolling as a provider participant, checking patient eligibility and benefits, submitting patient information, submitting claims, and receiving payment via direct deposit. Click here for more information.GAO Recommends CMS Include Detailed Information About SUD Coverage in “Medicare & You”
A new Government Accountability Office (GAO) report recommends the Centers for Medicare & Medicaid Services (CMS) include “explicit information” on the services Medicare covers for beneficiaries with substance use disorders (SUDs) in the agency’s Medicare & You publication. The GAO’s analysis of Medicare claims data in 2018 shows that almost 5 million beneficiaries used services for behavioral health services, which represented about 14% of the more than 36 million fee-for-services Medicare beneficiaries. About 96% of all behavioral health services accessed in 2018 (the year for which the latest data are available) were for a primary diagnosis in one of the following five behavioral health disorder categories: mood disorders (42%), anxiety and stress-related disorders (22%), schizophrenia and other non-mood, psychotic disorders (15%), disorders due to known physiological conditions (10%), and SUDs (7%). For this study, researchers also examined how CMS provides information to Medicare beneficiaries about coverage for behavioral health services. In doing so, they learned CMS mails Medicare & You—the most widely disseminated source of information on Medicare benefits—to all Medicare beneficiaries every year. “GAO reviewed the fall 2019 and January 2020 editions of Medicare & You,” the study noted. “While the January 2020 edition describes a new coverage benefit for beneficiaries with opioid use disorders, neither edition includes an explicit and broader description of the covered services available for substance use disorders,” it continued. “Both HHS and CMS have stated that addressing substance use disorders is a top priority. Given that coverage for substance use disorders is not explicitly outlined in Medicare’s most widely disseminated communication, Medicare beneficiaries may be unaware of this coverage and may not seek needed treatment as a result.” This finding led the GAO to recommend that CMS include “explicit information” on SUD coverage. “HHS reviewed a draft of this report,” the GAO study said, “and concurred with the recommendation.” Mental Health Survey Analysis Shows How People Worldwide Respond to Depression Treatment A new JAMA study shows that of more than 80,000 respondents surveyed in 16 countries, 68.2% of adults with a lifetime history of major depressive disorder obtained treatment they considered helpful. The findings showed that other patients stopped seeking treatment after early unhelpful treatment. Meanwhile, the findings showed that most patients (93.9%) were helped if they persisted through 10 treatment professionals, but only 21.5% of patients were that persistent. This led researchers to conclude “many more patients with major depressive disorder might obtain helpful treatment if they persist after early unhelpful treatment.”SAMHSA Covid-19 Emergency Response for Suicide Prevention Grant Applications Due Today
The deadline to apply for the Substance Abuse and Mental Health Services Administration’s (SAMHSA) Covid-19 Emergency Response for Suicide Prevention (Covid-19 ERSP) grants is today, Friday, May 22. The agency said it plans to issue 50 Covid-19 ERSP grants of up to $800,000 per year for 16 months for the program that is meant to support states and communities to prevent suicide and suicide attempts among adults 25 and older during the pandemic. SAMHSA’s announcement noted there are currently 57.8 million Americans living with mental and/or substance use disorders and suicide is the tenth leading cause of death in the United States. “The current national Covid-19 crisis will certainly contribute to the growth in the number of Americans needing urgent care to address mental health needs, including suicidality,” the announcement said. “Americans across the country will struggle with increases in depression, anxiety, trauma, grief, isolation, loss of employment, financial instability and other challenges, which can lead to suicide and suicide attempts.” Click here to for the application materials.Join the Conversation!
If you have not done so yet, please register today to access our Covid-19 Forum, an interactive comments page for all NABH members on NABH’s Covid-19 resources webpage. The Covid-19 Forum now requires an NABH login to view and post any content. Previously, a login was required only to post new content. So although members of the general public would not be able to post comments, they would be able to view them. This added feature makes it more exclusive to members. To participate you must first create an account and log-in. Your current NABH username and password will not work for this new feature. To help us connect your account to the correct NABH member organization, please use your work e-mail when registering. After you create a new username and password, you will use that information as your new login for all member-only resources at www.nabh.org, including CEO Update. After you have created an account, please visit the section, post information, and comment often. This forum is for you to post questions about issues you and your teams are managing during the coronavirus pandemic and to help provide answers and potential solutions to other NABH members. Please note that in creating this account, you are agreeing to view and post information that all NABH members can access. Our members will generate and share the content in this forum for other NABH members to use. NABH has not created this content; however, NABH staff will review postings regularly and may delete or reproduce posts if necessary. In addition, NABH is not liable to visitors of this site for any posted content. Our members agree to post questions or content that they believe is relevant to other member organizations. NABH may not be held liable for loss or damages that occur by the posting of or action taken on content posted. All content is for educational and informational purposes and is not intended as medical, legal, or other advice. If you have any questions, please contact nabh@nabh.org for assistance.Follow NABH on Twitter and LinkedIn During Mental Health Month
This Mental Health Month, please remember to follow NABH on Twitter @NABHBehavioral and on LinkedIn at the National Association for Behavioral Healthcare to learn what NABH members and other organizations are doing during the annual national observance.Fact of the Week
Among all adult discharges from opioid addiction treatment in the period 2015–17, 10.4% used both self-help groups and medications. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 101
NABH Letter to Lawmakers Outlines How to Address Covid-19’s Effects on Behavioral Health
NABH’s Covid-19 task force on Tuesday sent a letter to Vice President Mike Pence and senior congressional leaders that lists behavioral healthcare providers’ top challenges and recommendations as America prepares for a surge in mental health and addiction issues resulting from the Covid-19 pandemic. “Epidemics, even those of lesser magnitude than the Covid-19 pandemic, cause significant detrimental effects on mental health and substance use among affected populations often for years following an outbreak,” the letter noted. “Recent polls have found that half or more of Americans say the coronavirus pandemic is affecting their mental health with many reporting symptoms of anxiety and depression with high degrees of distress.” The letter lists key steps to address the behavioral health effects from Covid-19, including: maintaining and improving expansions of tele-behavioral health; maintaining other coverage expansions critical to improving access to behavioral healthcare; improving access to addiction services; increasing access to urgent and acute care for behavioral health conditions; and improving access to care and education for youth with serious behavioral health conditions. Click here to learn about NABH’s Covid-19 task force and to access behavioral healthcare resources during the pandemic.United Nations Releases Policy Brief on Covid-19 and Mental Health
United Nations (UN) Secretary-General António Guterres this week said mental health services are an essential part of all government responses to Covid-19 that must be expanded and fully funded. Guterres emphasized that message when he announced the UN’s policy brief on Covid-19 and mental health and urged the international community to do much more to protect all those who face rising mental pressures. “After decades of neglect and underinvestment in mental health services, the Covid-19 pandemic is now hitting families and communities with additional mental stress,” Guterres said in a video message. “Those most at risk are frontline healthcare workers, older people, adolescents and young people, those with pre-existing mental health conditions, and those caught up in conflict and crisis,” he added. “We must help them and stand by them. Even when the pandemic is brought under control, grief, anxiety, and depression will continue to affect people and communities.” Devora Kestel, director of the World Health Organization’s (WHO) Department of Mental Health and Substance Use, reiterated Guterres’s message when she said past economic crises had “increased the number of people with mental health issues, leading to higher rates of suicide for example, due to their mental health condition or substance abuse.” Kestel also said it’s critical to take measures that protect and promote care for the existing situation “so that we can prevent things becoming worse in the near future.”House to Vote Friday on Latest Coronavirus Stimulus Package
The House on Friday is expected to vote on a nearly $3 trillion coronavirus economic stimulus package that includes several behavioral healthcare provisions. According to a bill summary, the House bill includes $200 million for the National Institute of Mental Health to support research on the mental health consequences of Covid-19, including the effect on the nation’s healthcare providers. The legislation also includes $20 million to establish an emergency mental health and substance use training and technical assistance center at the Substance Abuse and Mental Health Services Administration (SAMHSA), and $50 million for the agency to award grants to states, tribes, and community-based entities to increase capacity for behavioral health services. In Medicaid, the bill would increase Federal Medical Assistance Percentage, or FMAP, payments to state Medicaid programs by a total of 14 percentage points from July 1, 2020 through June 30, 2021. And it would prevent the HHS secretary from finalizing the Medicaid Fiscal Accountability Regulation until the end of the Covid-19 public health emergency. The legislation also includes $175 billion for the public health and social services emergency fund, which breaks down to $100 billion in grants for hospitals and healthcare providers to be reimbursed for expenses or lost revenue resulting from the coronavirus, and $75 billion for Covid-19 testing and contact tracing. The House is expected to approve this bill, although its future is less certain in the Senate. NABH staff is watching the developments in this latest round of negotiations and its implications for behavioral healthcare providers.Senate Passes Bill to Make National Suicide Prevention Hotline ‘9-8-8’
In a unanimous voice vote, the Senate this week passed the National Suicide Hotline Designation Act, a bill that would make the national suicide prevention hotline a three-digit number. Currently the national suicide prevention hotline is accessible through a 10-digit number, 800-273-8225 (TALK). This legislation would allow a person to dial 9-8-8 to access the hotline, although the current number would still work. The bill now moves to the House for consideration.SAMHSA Covid-19 Emergency Response for Suicide Prevention Grant Applications Due May 22
SAMHSA this week said it is accepting applications for its Covid-19 Emergency Response for Suicide Prevention (Covid-19 ERSP) grants. The agency said it plans to issue 50 Covid-19 ERSP grants of up to $800,000 per year for 16 months for the program that is meant to support states and communities to prevent suicide and suicide attempts among adults 25 and older during the pandemic. SAMHSA’s announcement noted there are currently 57.8 million Americans living with mental and/or substance use disorders and suicide is the tenth leading cause of death in the United States. “The current national Covid-19 crisis will certainly contribute to the growth in the number of Americans needing urgent care to address mental health needs, including suicidality,” the announcement said. “Americans across the country will struggle with increases in depression, anxiety, trauma, grief, isolation, loss of employment, financial instability and other challenges, which can lead to suicide and suicide attempts.” SAMHSA will accept applications through next Friday, May 22. Click here to learn more.Follow NABH on Twitter and LinkedIn During Mental Health Month
This Mental Health Month, please remember to follow NABH on Twitter @NABHBehavioral and on LinkedIn at the National Association for Behavioral Healthcare to learn what NABH members and other organizations are doing during the annual national observance.Fact of the Week
Opioid use during pregnancy caused a 300% increase in neonatal abstinence syndrome (NAS) between 1999 and 2013. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 100
Health Affairs Blog Examines Strategies for Helping Individuals with OUD During Covid-19
A Health Affairs blog post this week outlines specific strategies that the federal government, states, and other stakeholders can apply to help individuals with opioid use disorder (OUD) mitigate the effects of Covid-19. Co-writers Jocelyn Guyer, managing director at Manatt Health, and Karen Scott, president of the Foundation for Opioid Response Efforts, note in the blog post that states and providers should update their approach to OUD treatment and “not only change their policies on paper but also issue clear and authoritative guidance to explain the new options available to help people with OUD through the pandemic.” The article highlights the various federal agencies involved in regulating medications used for OUD and recommends what should come next. “In the longer term, as the Covid-19 crisis eases, it also will be important to evaluate whether any of the temporary policy changes should be adopted on an ongoing basis,” the authors wrote. “These could include, for example, eliminating prior authorization requirements for medications used for OUD; allowing access to medications used for OUD even if someone is not participating in counseling; and using telehealth to ease access to medications used for OUD, peer supports, and individual counseling.”AHRQ Releases Consent Form for Telehealth Services
HHS’ Agency for Healthcare Research and Quality (AHRQ) has released a consent form for providers to document they had a discussion with a patient about telehealth services and that the patient understood the information discussed. AHRQ said providers should mail or provide an electronic portal to the form so patients have it before the discussion, and they should arrange for a qualified interpreter if the patient does not speak English well. The agency said the form is intended as a checklist to make sure providers cover all important information with patients in easy-to-understand language. Click here to access the form and for tips to follow during the consent discussion. Brookings Releases Report on Removing Barriers to Telehealth Services Research organization The Brookings Institution this week released Removing Regulatory Barriers to Telehealth Before and After Covid-19, a report that concludes state and federal barriers have prevented telehealth services from launching its full capabilities. The report provides a brief overview of the U.S. healthcare system; defines telemedicine, telehealth, and digital health; and examines federal versus state telehealth use implementation. Researchers noted that Covid-19 has shown the world the value of telemedicine, and asserted that telehealth regulations, especially those at the state level, should be written with a “broad eye toward the future,” being as flexible as possible. “While progress was being made before the coronavirus outbreak to adopt telehealth in states,” the study’s researchers wrote, “the pandemic not only demonstrated its worth but also proved it necessary to avert larger meltdowns in hospital systems and among medical professionals—even those whose work was stopped due to social distancing.”Next Week is National Prevention Week
The Substance Abuse and Mental Health Services Administration’s next National Prevention Week is May 10 through 16. This Mental Health Month, click here to download a toolkit from Mental Health America and here for resources from the National Alliance on Mental Illness.NABH Joins Psych Hub
NABH recently became a partner with Psych Hub, an online learning platform about mental health, substance use, and suicide prevention. Psych Hub’s free micro-video library hosts more than 100 consumer-facing, animated videos focused on improving mental health literacy and reducing stigma about seeking care. Click here to see all of Psych Hub’s partner organizations.Fact of the Week
A recent Kaiser Family Foundation tracking poll found that older adults were less likely than adults ages 18 to 64 to report that worry or stress related to the coronavirus has had a negative effect on their mental health: 31% versus 49%, respectively. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 99
CMS Announces Additional Medicare Coverage Flexibility for Behavioral Healthcare Services
The Centers for Medicare & Medicaid Services (CMS) on Thursday announced additional flexibility in Medicare coverage for several behavioral healthcare services during the Covid-19 pandemic, including partial hospitalization. CMS said it will allow payment for certain partial hospitalization services—namely, individual psychotherapy, patient education, and group psychotherapy—that are delivered in temporary expansion locations, including patients’ homes. In addition, hospitals may bill for services provided remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home when the home is serving as a temporary provider-based department of the hospital. Examples of this include counseling and educational service as well as therapy services. This change expands the types of healthcare providers that can provide using telehealth technology. CMS said hospitals may also bill as the originating site for telehealth services that hospital-based practitioners provide to Medicare patients registered as hospital outpatients, including when the patient is located at home. And while CMS announced previously that Medicare would pay for certain services conducted by audio-only telephone between beneficiaries and their doctors and other clinicians, the agency on Thursday broadened that list to include many behavioral health and patient education services. CMS is also increasing payments for these telephone visits to match payments for similar office and outpatient visits. This would increase payments for these services to about $46-$110 from a range of about $14-$41. The payments are retroactive to March 1, 2020. The changes will also allow Opioid Treatment Programs (OTPs) to perform periodic assessments through two-way audio-visual technology and through audio-only telephone calls. This change builds on CMS’ March 31st guidance, in which the agency said audio-only telephone calls were permitted for therapy, counseling, and counseling add-on codes. In addition, CMS said pharmacists may perform medication management in accordance with state scopes of practice and laws. This modification does not, however, apply to the dispensing of methadone. Thursday’s rule reaffirmed the continuation of methadone dispensing by certified and accredited OTPs, under the supervision of clinicians who have received appropriate training and as required by the Controlled Substances Act. Until now, CMS only added new services to the list of Medicare services that may be provided via telehealth using its rulemaking process. CMS is changing its process during the Covid-19 pandemic and will add new telehealth services on a sub-regulatory basis as it considers practitioner requests. CMS also announced that teaching hospitals, including inpatient psychiatric facilities, can increase temporary beds and admit more patients to alleviate pressure on acute-care hospital bed capacity without facing reduced teaching status payments and reduced payments for indirect medical education.May is Mental Health Month
May 1 kicks off Mental Health Month, and Mental Health America (MHA) has created a 2020 Mental Health Month Toolkit to commemorate the national observance. MHA and its affiliates nationwide have led this monthly observance since 1949, and this year will promote a “Tools 2 Thrive” theme to provide practical tools to improve mental health. According to MHA, which reports that one in five people will experience a mental illness during their lifetime, some of the tools may need to be adapted due to social-distancing restrictions during the global pandemic.HRSA Seeks Public Comment on Bureau of Health Workforce Substance Use Evaluation
HHS’ Health Resources and Services Administration (HRSA) announced it is seeking public comment for the next 30 days on its Bureau of Health Workforce Substance Use Evaluation. In September 2017, HRSA’s Bureau of Health Workforce launched a multi-pronged effort to increase the U.S. healthcare system’s workforce capacity to prevent and treat the nation’s deadly opioid crisis. HRSA developed or expanded activities under five programs as part of this effort—including programs such as the National Health Service Corps Loan Repayment Program and the Behavioral Health Workforce Education and Training Program—and is now seeking feedback to assess these program changes. Click here to learn more about the comment submission process.AHA to Host Webinar Next Week on Outpatient Services Featuring Sheppard Pratt Leaders
The American Hospital Association (AHA) will host a webinar about outpatient behavioral health services during the Covid-19 pandemic featuring leaders from NABH member Sheppard Pratt Health System on Monday, May 4. Harsh Trivedi, M.D., M.B.A., an NABH board member and AHA trustee, along with Sheppard Pratt’s chief medical officer, chief operating officer, and medical director for outpatient services, will discuss the system’s efforts to redesign and adapt innovative treatment programs across the full continuum of outpatient services. This event follows a webinar that AHA hosted last month on Sheppard Pratt’s processes and protocols in the system’s inpatient psychiatric settings during the pandemic. The hourlong webinar will begin on Monday at 3 p.m. ET. Click here to register.Brookings to Host May 6 Webinar on Telehealth Before and After Covid-19
Research organization Brookings will host an hourlong webinar about telehealth services before and after Covid-19 next Wednesday, May 6 at 2 p.m. ET. In its announcement, Brookings noted that before the global pandemic, federal and state regulations around reimbursement and licensure requirements limited telehealth use, while private insurance programs and Medicaid have historically excluded telehealth services from coverage. “Whether through remote clinical health management or real-time patient monitoring, telehealth will increasingly become a necessity in health care, especially in assessing treatment options prior to any hospital visits,” the webinar announcement said. The Center for Technology at Brookings and the John Locke Foundation will host the webinar to discuss the findings of a forthcoming paper on this issue, as well as the status of regulations and how to support telehealth services in the future. Click here to register.SAMHSA to Host May 7 Webinar on Combatting Social Isolation for Seniors During Covid-19
The Substance Abuse and Mental Health Services Administration (SAMHSA), the Administration for Community Living, the Veterans Health Administration, and the National Coalition on Mental Health and Aging will host a webinar about combatting social isolation for seniors during the pandemic to commemorate National Older Adult Mental Health Awareness Day on Thursday, May 7. The discussion will include practical ideas to promote connection and recovery for older adults with serious mental illness and substance use disorders during the global pandemic. Click here for more information about the 90-minute webinar, which will begin at 1 p.m. ET.Fact of the Week
According to the Kaiser Family Foundation, 56% of U.S. adults report that worry or stress related to the coronavirus outbreak has caused them to experience at least one negative effect on their mental health and wellbeing, such as problems with sleeping or eating, increased alcohol use, or worsening chronic conditions. For questions or comments about this CEO Update, please contact Jessica Zigmond.
NABH-The Kennedy Forum Op-Ed
In January, the Centers for Disease Control and Prevention announced some hopeful news when it reported a slight uptick in U.S. life expectancy following years of decline largely due to historic rates of overdoses and suicides.
Sadly, COVID-19 has the potential to reverse serious progress made in addressing our nation’s mental health and addiction crises — particularly around overdose rates — unless policymakers mitigate the pandemic’s serious effects on behavioral health in the next stimulus package.
Read More
CEO Update 98
CMS Expects FY 2021 IPF Payments to Increase by 2.4%
The Centers for Medicare & Medicaid Services (CMS) on April 10 said it expects payments to inpatient psychiatric facilities to increase by 2.4% in fiscal year 2021, boosting the federal per diem base rate to $817.59 from $798.55.
An announcement about CMS’ proposed inpatient psychiatric facility prospective payment system (IPF-PPS) rule said the agency estimates total IPF payments to increase by $100 million next year. The rule was published in the Federal Register on Tuesday, April 14.
According to the proposed rule, CMS will adopt the Office of Management and Budget guidelines regarding geographic delineation of statistical areas, which CMS said should result in wage index values better representing the actual labor costs in a given area.
“CMS is proposing that all IPF providers negatively impacted in their wage index, regardless of the circumstance causing the decline, be capped at a 5-percent decrease for FY 2021,” the announcement said. Table 6 at the start of page 57 in the proposed rule shows changes in 2021 from 2020 for different facility types.
The agency said it is not making changes to the IPF Quality Reporting Program.
NABH is analyzing the proposed rule and will submit comments by the June 9 deadline.
HHS Opens CARES Act Emergency Fund Attestation Portal
HHS has opened its Coronavirus Aid, Relief, and Economic Security (CARES) Act emergency fund attestation portal for healthcare providers who receive funds from the $100 billion Public Health and Social Services Emergency Fund within 30 days of receipt to attest that they received the funds and agree to payment terms and conditions.
HHS began distributing the first $30 billion from the fund on April 10 to reimburse providers for healthcare-related expenses and lost revenue related to Covid-19.
New Coalition Launches Initiative to Match PPE Donors with Hospitals
A coalition of organizations including the American Hospital Association (AHA), Kaiser Permanente, UPS, and Microsoft has launched the Protecting People Everywhere initiative to support a national exchange that matches personal protective equipment (PPE) donors with the hospitals in greatest need.
Powered by the HealthEquip™ app, the initiative is meant to ensure these critical supplies are distributed equitably. Click here to learn more.
NABH Sends Urgent OTP Requests to HHS and SAMHSA
NABH this week asked HHS and the Substance Abuse and Mental Health Services Administration (SAMHSA) to make changes in telehealth service delivery and payment rates for opioid treatment programs (OTPs) during Covid-19.
In a letter to HHS Secretary Alex Azar and SAMHSA Administrator Elinore McCance-Katz, M.D., Ph. D., NABH requested that the Trump administration support an NABH-proposed telehealth service-delivery model for new patients that addresses SAMHSA’s clinical concerns while also protecting patients and physicians.
The letter also asked the federal health officials to support OTP providers at a standardized rate during the pandemic period to mitigate the loss in revenue and increase in expenditures for OTPs during Covid-19.
Click here to read the letter, which is posted on NABH’s Covid-19 resources page.
AHA to Host Behavioral Health Webinar Featuring Sheppard Pratt Leaders Next Week
The AHA will host a webinar about behavioral health challenges during Covid-19 on Wednesday, April 22 featuring senior leaders from NABH member Sheppard Pratt Health System.
Harsh Trivedi, M.D., M.B.A., an NABH board member and an AHA trustee, along with Sheppard Pratt’s chief medical officer, chief nursing officer, and chief strategy officer, will discuss how the system re-engineered care processes and developed new care protocols for agitated patients during the pandemic. The team will also discuss the system’s efforts to support staff and build resistance during the national emergency.
The hourlong webinar will begin at 2 p.m. ET. Click here to register.
O’Neill Institute Covid-19 and Addiction Policy Webinar Includes Pinnacle Treatment Centers CEO
The O’Neil Institute for National and Global Health Law at Georgetown last week hosted a webinar on Covid-19 and addiction policy that featured Joe Pritchard, CEO of NABH member Pinnacle Treatment Centers and a member of NABH’s Addiction Treatment Committee.
Panelists discussed the current state of access to treatment and harm reduction services for people with substance use disorders. Topics included recently waived federal regulations related to medications and telehealth, as well as the availability of harm reduction and recovery support services.
Fact of the Week
Between 1999 and 2018, suicide rates were lowest among females aged 10-14. The rate for this age group increased to 2.0 in 2018 from 0.5 in 1999.
For questions or comments about this CEO Update, please contact Jessica Zigmond
CMS Expects FY 2021 IPF Payments to Increase by 2.4%
The Centers for Medicare & Medicaid Services (CMS) on April 10 said it expects payments to inpatient psychiatric facilities to increase by 2.4% in fiscal year 2021, boosting the federal per diem base rate to $817.59 from $798.55.
An announcement about CMS’ proposed inpatient psychiatric facility prospective payment system (IPF-PPS) rule said the agency estimates total IPF payments to increase by $100 million next year. The rule will be published in the Federal Register on Tuesday, April 14.
According to the proposed rule, CMS will adopt the Office of Management and Budget (OMB) guidelines regarding geographic delineation of statistical areas, which CMS said should result in wage index values better representing the actual labor costs in a given area.
“CMS is proposing that all IPF providers negatively impacted in their wage index, regardless of the circumstance causing the decline, be capped at a 5-percent decrease for FY 2021,” the announcement said. Table 6 at the start of page 57 in the proposed rule shows changes in 2021 from 2020 for different facility types.
The agency said it is not making changes to the IPF Quality Reporting Program.
NABH is analyzing the proposed rule and will submit comments by the June 9 deadline.
CEO Update 97
HHS Announces $30 Billion in Immediate Covid-19 Relief Funding for Providers
HHS announced on Friday it is distributing $30 billion immediately to healthcare providers fighting the deadly Covid-19 pandemic. The funding is the first portion of the $100 billion allotted to hospitals and other providers as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act that President Trump signed on March 27. The funding will arrive via direct deposit to eligible providers starting on Friday, April 10. HHS’ announcement said the money is in the form of payments, not loans, so the money will not need to be repaid. Eligible healthcare providers include all facilities and providers that received Medicare fee-for-service reimbursements in 2019. According to HHS, payments to practices that are part of larger medical groups will be sent to the group’s central billing office. Click here to learn how HHS will determine the payments and what eligible providers need to do. To receive funding, providers must agree not to seek to collect out-of-pocket payments from a Covid-19 patient that are greater than what the patient would have otherwise been required to pay if an in-network provider had provided care, HHS said. HHS has created a public website that shows all Covid-19 grant and cooperative agreement awards, which features a U.S. map detailing the amounts awarded by states, graphics highlighting the numbers of awards, amounts awarded by agency, and more.NABH Sends Latest Covid-19 Recommendations to Vice President Pence and Hill Leaders
NABH on Thursday sent Vice President Mike Pence and top Senate and House leaders a six-page letter outlining critical behavioral healthcare recommendations as lawmakers prepare for the next round of legislation to provide relief during the Covid-19 pandemic. The letter highlights behavioral healthcare provider needs related to payment issues, health information technology, telehealth, parity compliance, medication treatment for opioid use disorder, youth services, and additional emergency funding needs. Please visit NABH’s enhanced Covid-19 resources page for all pandemic-related correspondence, guidance, and external webpage links.NABH and Other Behavioral Health Organizations Request Emergency Covid-19 Relief
Earlier this week, NABH joined more than 35 other associations on a request for $38.5 billion in emergency funding for behavioral health organizations during Covid-19. The appropriations request calls for the $38.5 billion in emergency supplemental funding for direct payments to behavioral health organizations to ensure they can remain open and operating during the pandemic. A significant portion of the funding would be set aside for behavioral healthcare organizations enrolled in Medicaid. Also this week, NABH also supported a Mental Health Liaison Group letter to HHS Secretary Alex Azar and Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma that requested CMS immediately expand Medicare coverage of telehealth to allow audio-only communications and waive Medicare’s current requirement for audio-video connecting during the pandemic.The Joint Commission Releases FAQs on Healthcare Provider Face Masks Brought from Home
The Joint Commission (TJC) this week released frequently asked questions (FAQs) regarding TJC’s position statement on using face masks brought from home. TJC’s Office of Quality and Patient Safety has received many complaints from healthcare workers about inadequate personal protective equipment (PPE), such as a lack of N95 masks for performing aerosolizing procedures or working without routinely wearing a mask when exposed to a large number of patients who could have Covid-19. “If a hospital cannot provide N95 masks for staff performing these procedures or working in the immediate vicinity, staff should be allowed to bring in their own masks,” TJC noted. Click here to read the FAQ document, which is also posted on NABH’s Covid-19 resources page.CDC Reports National Suicide Rate Increased 35% Between 1999 and 2018
The Centers for Disease Control and Prevention (CDC) this week reported the U.S. suicide rate increased 35% between 1999 and 2018. During that period, suicide rates among females were highest for those between the ages of 45 and 64, while the rates were highest among males for those aged 75 and older. Meanwhile, in 2018, the suicide rate for males was 3.7 times the rate for females. According to the CDC, suicide is the 10th leading cause of death for all ages in the United States.Fact of the Week
The U.S. suicide rate increased on average about 1% per year from 1999 to 2006 and then by 2% per year from 2006 through 2018. For questions or comments about this CEO Update, please contact Jessica Zigmond.HHS Announces $30 Billion in Covid-19 Relief Funding for Providers
HHS announced on Friday it is distributing $30 billion immediately to healthcare providers fighting the deadly Covid-19 pandemic. The funding is the first portion of the $100 billion allotted to hospitals and other providers as part of the Coronavirus Preparedness and Response Supplemental Appropriations (CARES) Act that President Trump signed on March 27.
The funding will arrive via direct deposit to eligible providers starting on Friday, April 10. HHS’ announcement said the money is in the form of payments, not loans, so the money will not need to be repaid.
Eligible healthcare providers include all facilities and providers that received Medicare fee-for-service reimbursements in 2019. According to HHS, payments to practices that are part of larger medical groups will be sent to the group’s central billing office. Click here to learn how HHS will determine the payments and what eligible providers need to do.
To receive funding, providers must agree not to seek to collect out-of-pocket payments from a Covid-19 patient that are greater than what the patient would have otherwise been required to pay if an in-network provider had provided care, HHS said.
HHS has created a public website that shows all Covid-19 grant and cooperative agreement awards, which features a U.S. map detailing the amounts awarded by states, graphics highlighting the numbers of awards, amounts awarded by agency, and more.
CEO Update 96
NABH Covid-19 Resources Page Highlights Summaries, FAQs, and Links
Please visit NABH’s Covid-19 resources page for the latest behavioral healthcare guidance, recommendations, and best practices related to the Covid-19 pandemic. New resources this week include NABH’s priority issue areas and recommendations for the Centers for Medicare & Medicaid Services (CMS), an NABH summary of CMS’ policy changes, and a blog post from the law firm Holland & Knight about Covid-19 funding for healthcare providers. Also be sure to follow NABH on Twitter @NABHBehavioral and on LinkedIn at the National Association for Behavioral Healthcare to learn about the innovative practices NABH members are implementing during the national emergency.Joint APA-NABH Covid-19 Webinar Recording Now Available
NABH thanks NABH Board members Frank Ghinassi, Ph.D., A.B.P.P., CEO at Rutgers University Behavioral Health Care, and Harsh Trivedi, M.D., M.B.A., president and CEO of Sheppard Pratt Health System, for serving as presenters during a joint webinar with the American Psychiatric Association about Covid-19 on Wednesday, April 1. A recording of the webinar, How to Address Covid-19 Across Inpatient, Residential, and Other Non-ambulatory Care Settings, is free with registration if you missed it. Click here to register.SAMHSA Announces Covid-19 Emergency Grant Opportunities
The Substance Abuse and Mental Health Services Administration (SAMHSA) is accepting applications for Emergency Grants to Address Mental and Substance Use Disorders During Covid-19. According to the National Survey on Drug Use and Health, 2018, there are 57.8 million Americans living with mental and/or substance use disorders (SUDs). SAMHSA noted in its grant announcement this week that the Covid-19 pandemic will contribute to an increase in this figure. The agency said it plans to issue 60 grants of up to $2 million per state or up to $500,000 for territories and tribes for 16 months. The program is meant to provide crisis intervention services, mental and substance use disorder treatment, crisis counseling, and other related supports for children and adults affected by the COVID-19 pandemic. Click here for more information and to apply. Applications are due April 10.SAMHSA Announces Treatment, Recovery, and Workforce Support Grants
SAMHSA this week also said it is accepting applications for its Treatment, Recovery, and Workforce Support grants, which implement evidence-based programs to support individuals in SUD treatment and recovery to live independently and participate in the U.S. workforce. The agency said it expects to issue eight grants of up to $500,000 per year for up to five years. Click here for more information and to register. Applications are due June 1. NABH 2020 Exhibitor & Sponsor Guide Available Online NABH mailed all association members a printed copy of the NABH 2020 Exhibitor & Sponsor Guide on March 16. The Guide is also available online to download on the NABH Resources page. NABH thanks its exhibitors and sponsors and looks forward to working with them on the NABH 2021 Annual Meeting!Fact of the Week
Since fiscal year 2015, the Government Accountability Office has made more than 80 recommendations to multiple agencies responsible for addressing the drug crisis. More than 60 of these recommendations have yet to be implemented. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 95
President Trump Signs $2 Trillion Stimulus Bill to Address Covid-19 Pandemic
President Trump on Friday signed a $2 trillion stimulus package to address the Covid-19 pandemic’s devastating effects on the nation. Earlier Friday, the House passed the Senate-approved Coronavirus Aid, Relief, and Economic Security Act (CARES), which includes several provisions to address costs and other burdens on healthcare providers related to Covid-19—and improve access for mental health and substance use disorder treatment. The legislation includes tax rebates, expanded unemployment benefits, tax relief provisions, and grants focused on financially supporting individuals, families, businesses, and states. It also includes $100 billion for healthcare providers who provide care for individuals who may have or are diagnosed with Covid-19. These funds can be used for expenses or lost revenues that are attributable to the coronavirus. This funding is allocated to the Public Health and Social Services Emergency Fund that HHS’ Office of the Secretary manages. Here are other key provisions from the CARES Act for behavioral healthcare providers:- $16 billion is included for the Strategic National Stockpile for personal protective equipment and other medical supplies for federal and state response efforts.
- $3.5 billion is included for childcare with a clarification that states can use these funds to provide childcare for healthcare workers, including those who may not ordinarily qualify for services at federally funded sites.
- $425 million to the Substance Abuse and Mental Health Services Administration (SAMHSA), including:
- $250 million for the Certified Community Behavioral Health Center (CCBHC) grant program;
- $50 million for suicide prevention programs; and
- $100 million for emergency response grants—flexible funding to address mental health, substance use disorders and provide resources and support to local communities.
- Extends original CCBHC demonstration program funding for participating sites through November 2020 and directs HHS to select two additional states to include in the demo.
- Additional flexibility for Medicare to cover telehealth—eliminating the limitation on telehealth coverage to providers that had treated the patient in the last three years. Lifting this restriction will enable beneficiaries to access services via telehealth from a broader range of providers.
- Improved care coordination for patients with substance use disorders. This provision allows patients to consent to their records being shared for healthcare treatment, payment, and operations in accordance with the privacy requirements established through the Health Insurance Portability and Accountability Act (HIPAA). Patients will still be able to restrict disclosure by withholding consent, and the legislation contains anti-discrimination provisions and restrictions on law enforcement use of the records.
NABH and APA to Host Joint Webinar on Addressing Covid-19 in Multiple Settings
NABH and the American Psychiatric Association (APA) will host a joint webinar on Wednesday, April 1 that features experts working in inpatient, residential, and other non-ambulatory care settings who will discuss how they are assessing the current environment and developing new protocols to care for their patients during the Covid-19 pandemic. NABH Board members Frank Ghinassi, Ph.D., A.B.P.P., CEO at Rutgers University Behavioral Health Care, and Harsh Trivedi, M.D., M.B.A., president and CEO of Sheppard Pratt Health System, are among the presenters. The webinar will highlight types of services, key messages to share with team leaders, unique challenges for people with serious mental illness, how to handle group therapy, and more. It will include a live chat session for audience members to submit questions during the webinar. A recording will be available after the event. The hourlong webinar next week will begin at 2 p.m. ET. Click here to register.Mental Health Liaison Group Urges Policymakers to Broaden Telehealth Services
NABH joined other members of the Mental Health Liaison Group (MHLG) in urging House and Senate leaders to temporarily lift telebehavioral health restrictions during the Covid-19 pandemic. “Given the orders from local, city, state, and national leaders for communities to shelter in place, the Centers for Medicare and Medicaid Services have broadened access to telehealth services and established payment parity under a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act,” the MHLG wrote in its March 25 letter to Senate Majority Leader Mitch McConnell (R-Ky.) and House Speaker Nancy Pelosi (D-Calif.) “We applaud this decision to expand telehealth coverage for Medicare beneficiaries and strongly urge states to follow suit,” it continued. “We request states to temporarily lift restrictions on telebehavioral health at all levels of care by telephone or video for individuals regardless of insurance plan and ensure payment parity until the conclusion of this national emergency.”Kaiser Family Foundation Releases Medicaid Emergency Authority Tracker
The Kaiser Family Foundation this week released a Medicaid Emergency Authority Tracker that aggregates information on approved Medicaid emergency authorities to address the Covid-19 pandemic. The page noted that it currently includes details about section 1135 waivers and 1915 (c) waiver appendix K strategies and will later add other emergency authorities. NABH has posted the tracker on the Covid-19 resources page.Fact of the Week
As a result of the Covid-19 pandemic, states may request blanket exceptions for all stable patients in an opioid treatment program to receive 28 days of take-home doses of the patient’s medication for opioid use disorder. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 94
A Message President and CEO Shawn Coughlin
It’s hard to believe it has been only 10 days since we decided to cancel the 2020 NABH Annual Meeting. It feels more like 10 years. On behalf of our NABH team here in Washington, thank you for all you have done to provide excellent behavioral healthcare services during one of the most difficult and stressful times in our nation’s history. Through you, our members, we have learned and shared much in one week’s time. Ultimately, we hope to use the lessons we learn during the Covid-19 pandemic to help our members—and improve behavioral healthcare in the United States. As we all navigate the pandemic, I want to highlight some actions NABH has taken to apprise our members of federal guidance, to inform relevant federal agencies and lawmakers about our recommendations, and to share best practices with each other. First, please visit our Covid-19 webpage, which includes our weekly recommendations to the Centers for Medicare & Medicaid Services (CMS), guidance from relevant federal agencies, and other external resources that we think you and your teams will find useful. We will update that page regularly. We will also continue to send NABH Alerts when we have crucial and/or urgent information to share. This week’s CEO Update includes the NABH Alerts we sent earlier this week, in case you missed those. In addition, please remember to follow us on Twitter @NABHBehavioral and on LinkedIn, where we will post important information and share what our members are doing. Finally, please keep us informed about the challenges you’re managing and processes that are working well. You can reach us at nabh@nabh.org. Again, our thanks and very best wishes to each of you, your teams, and your families to stay healthy and safe. Shawn Coughlin President and CEONABH Sends Covid-19 Priority Recommendations to Vice President Pence, Hill Leaders
NABH on Friday sent a letter to top federal leaders outlining the association’s priority recommendations during the Covid-19 pandemic. Congress is considering a legislative package to address Covid-19 issues, and NABH alerted Vice President Mike Pence and congressional leaders about the major challenges that NABH members are managing during the pandemic. Click here for the full letter. CMS Outlines Actions for Healthcare Providers During Covid-19 National Emergency CMS this week released a fact sheet for healthcare providers and states following President Trump’s declaration of a national emergency due to Covid-19. You can learn more from the agency’s news release about these actions.Federal Agencies Offer Flexibility on Telehealth and HIPAA During Covid-19 Pandemic
Agencies within the U.S. Health and Human Services Department (HHS) as well as the U.S. Drug Enforcement Administration (DEA) on Tuesday released essential guidance allowing for expanded telehealth use during the Covid-19 pandemic. Also Tuesday, HHS’ Centers for Medicare & Medicaid Services (CMS) issued important information about waivers or modifications under section 1135 of the Social Security Act during the national public emergency. Please see below for information and related links. Meanwhile, CMS released a virtual toolkit for its partners, which includes links to the websites of other federal agencies, as well as guidance for schools, workplaces, Medicare beneficiaries, clinicians, caregivers, and others. The agency’s announcement on increased flexibility in telehealth for Medicare beneficiaries allows Medicare payment for professional services for patients in any healthcare facility and in patients’ homes – no longer limited to rural settings and certain types of facilities. See also the FAQs on this announcement.- CMS so also released guidance about telehealth services in the Medicaid program.
- HHS’ OIG released a policy statement and a fact sheet about telehealth cost-sharing during the Covid-19 pandemic.
- HHS Office for Civil Rights announced guidance on a limited waiver of HIPAA sanctions and penalties related to telehealth during the Covid-19 national emergency.
- DEA issued information related to telemedicine and medication assisted treatment.
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- Reimbursement of otherwise payable claims from providers not enrolled in Florida’s Medicaid program or Medicare if certain conditions are met;
- Waiver to allow facilities, including nursing facilities, intermediate care facilities for individuals with intellectual and developmental disabilities (ICF/IDDs), psychiatric residential treatment facilities (PRTFs) and hospitals’ NFs to be fully reimbursed for services rendered during an emergency evacuation to an unlicensed facility (where an evacuating facility continues to render services);
- Waiver for Pre-Admission Screening and Annual Resident Review (PASRR) Level I Level II Assessments for 30 days. All new admissions can be treated like exempted hospital discharges;
- See CMS guidance, for more information on section 1135 authority that allows waiver of certain Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) requirements.
SAMHSA Releases 42 CFR Part 2 Guidance During Covid-19
The Substance Abuse and Mental Health Services Administration (SAMHSA) on Thursday released 42 CFR part 2 guidance clarifying patient consent requirements during the Covid-19 pandemic. SAMHSA’s announcement acknowledges that patients may not be able to sign written consents due to social distancing and increased telehealth services during the pandemic. To ensure that substance use treatment is not interrupted, the agency’s guidance reminds providers they may determine that a “bona fide medical emergency exists” under the existing “medical emergency exception.” Please contact Sarah Wattenberg, NABH’s director of quality and addiction services, if you have questions.Fact of the Week
SAMHSA this week released tips on taking care of your behavioral health during the Covid-19 pandemic. For questions or comments about this CEO Update, please contact Jessica ZigmondNABH Board of Trustees Meeting
- Introductions
- Minutes Approval
- New Member Ratification
- Treasurer’s Report
- 2019 Audit
- Expanding Access to Care Initiatives
- Managed Care Coverage
- 190-Day Lifetime Limit
- Conditions of Participation (B-Tags)
- Communications Update
- NABH Champions PAC
- Annual Meeting
- Exhibitor’s Coffee with NABH Board, Tuesday, March 17 at 8 a.m. in Grand Ballroom C
Next Board Meeting:
DATE: Monday, October 5 & Tuesday, October 6, 2020
LOCATION: The Hay-Adams Hotel, 800 16th St NW, Washington, DC 20006, 202-638-6600
To make your hotel reservations, please click here. The group room rate is $395 for single/double Superior Room. RESERVATION CUT-OFF DATE: Tuesday, September 8, 2020.
CEO Update 93
WHO Declares COVID-19 a Pandemic; NABH Cancels 2020 Annual Meeting
The World Health Organization this week declared the coronavirus disease 2019 (COVID-19) a pandemic as the virus has spread to more than 100 countries and killed more than 4,200 people. After careful consideration, NABH this week cancelled the 2020 NABH Annual Meeting and all related events to protect the health and safety of all meeting participants and minimize unnecessary risks to exposure of the COVID-19. NABH will reimburse all meeting registrants in full, including the $50 cancellation fee for any meeting registrant who has cancelled already. All meeting registrants are responsible for covering and cancelling their hotel and transportation costs. In addition, NABH sent a message to all exhibitors and sponsors regarding reimbursement. The entire NABH team looks forward to seeing the association’s members and other meeting participants at the 2021 NABH Annual Meeting at the Mandarin Oriental Washington, DC from March 1-3, 2021!CMS Issues Guidance for Healthcare Workers During COVID-19 Pandemic
The Centers for Medicare & Medicaid Services (CMS) this week issued a series of guidance notices to ensure healthcare workers are protecting themselves and patients during the COVID-19 pandemic. On March 9, CMS delivered guidance on the screening, treatment, and transfer procedures healthcare workers must follow when interacting with patients to prevent the spread of the COVID-19 virus, as well as guidance that highlights the benefits of telehealth in the Medicare and Medicaid programs. The following day CMS issued a memorandum to state survey agencies—which are responsible for inspecting nursing homes and other facilities that serve Medicare and Medicaid beneficiaries—that includes guidance about protective mask guidance for healthcare workers. Click here for additional information from CMS and here for the situation summary on the virus from the Centers for Disease Control and Prevention.NABH Supports Recommendations for Strengthening Addiction Service Workforce
NABH this week joined more than a dozen organizations that comprise the Coalition to Stop Opioid Overdose (CSOO) in sending a letter to Congress that outlines recommendations to strengthen the addiction service workforce. The letter—which includes specific appropriations recommendations—requests increased funding of important addition prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in 2021. As the letter noted, an estimated 21.2 million Americans aged 12 or older needed treatment for substance use disorder (SUD) in 2018, but only about 3.7 million Americans aged 12 or older received any form of treatment for SUD. “By advancing sustainable, comprehensive public policies and expanding federal investment throughout our health care system for SUD, we will move closer to a future where all Americans living with addiction receive the high-quality care they need and deserve,” the letter said.IPFQR Webinar on Navigating Hospital Compare Website Scheduled for March 24
CMS will host a webinar for participants in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) program about how to navigate the Hospital Compare website on Tuesday, March 24 at 2 p.m. ET. The webinar will highlight the steps to use the Hospital Compare website to compare IPFQR program data for up to three providers at a time and review the ways to download complete facility-, state-, and national-level data files from the Hospital Compare archive. Slides will be available on the Quality Reporting Center website one day before the webinar. Click here to register.HRSA Accepting Applications for Opioid Response Program in Rural Communities
The Health Resources and Services Administration (HRSA) is accepting applications for its Rural Communities Opioid Response Program (RCORP), which is intended to reduce the morbidity and mortality of SUD, including opioid use disorder, in high-risk communities. Eligible applicants include all domestic public or private, non-profit or for-profit entities, including faith-based and community-based organizations, tribes, and tribal organizations. Click here to learn more and apply. HRSA will accept applications through April 24.Fact of the Week
In 2018, the states with the highest age-adjusted drug overdose death rates were West Virginia (51.5 per 100,000 standard population), Delaware (43.8), Maryland (37.2), Pennsylvania (36.1), Ohio (35.9), and New Hampshire (35.8). For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 92
CMS Announces Actions to Address Spread of Coronavirus
The Centers for Medicare & Medicaid Services (CMS) this week announced a series of actions intended to limit the spread of Coronavirus 2019 (COVID-19), starting with directing healthcare providers nationwide to ensure they are implementing their infection-control procedures, which providers are required to maintain at all times. CMS also announced that until further notice, state survey agencies and accrediting organizations will focus their facility inspections exclusively on issues related to infection control and other serious health and safety threats, such as abuse allegations, starting with nursing homes and hospitals. Vice President Pence—who is leading the government’s response to COVID-19—said this shift in approach will allow inspectors to focus their energies on addressing the spread of COVID-19. The agency also provided information on suspension of survey activities, guidance for infection control and prevention concerning COVID-19 and related FAQs, and guidance for infection control and prevention of COVID-19 in nursing homes. As of noon ET on Friday, the Centers for Disease Control and Prevention reported a total of 164 COVID-19 cases and 11 deaths in the United States, with 19 states reporting cases. The Atlanta-based agency has also provided guidance for healthcare facilities and information about clinician outreach and activity. Click here for an overview and additional information. NABH alerted 2020 NABH Annual Meeting participants on March 3 that the association is watching federal updates closely and will continue its plans for the Annual Meeting in Washington, D.C. from March 16-18.Senators Manchin, Moore Capito Reintroduce Protecting Jessica Grubb’s Legacy Act
Senators Joe Manchin (D-W.Va.) and Shelley Moore Capito (R-W.Va.) this week reintroduced the Protecting Jessica Grubb’s Legacy Act, which would allow patients to opt in and share their addiction medical records. The legislation would also make it easier to share addiction records for the purposes of treatment, payment, and healthcare operations, while allowing patients to remain in control. The bill would also provide new protections under 42 CFR Part 2, which was passed in the 1970s before the Health Insurance Portability and Accountability Act of 1996 and electronic medical records. NABH has long supported reforming 42 CFR Part 2. Click here to read a summary of the bill from Sens. Manchin and Moore Capito.NABH Supports Medicare Mental Health Inpatient Equity Act
NABH was one of 40 organizations in the Mental Health Liaison Group this week to support the Medicare Mental Health Inpatient Equity Act, which would eliminate Medicare’s 190-day lifetime limit for Medicare beneficiaries who require inpatient psychiatric hospital care. “This lifetime limit does not apply to psychiatric units in general hospitals and there is no such lifetime limit for any other Medicare specialty inpatient hospital service,” the MHLG wrote in a letter to Sens. Susan Collins (R-Maine) and Tina Smith (D-Minn.) “Through passage of landmark legislation, the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008, Congress put coverage for mental health and substance use disorders on par with other medical disorders,” the letter continued. “Also, that year, Congress passed important legislation to phase-in equalization of the Medicare outpatient coinsurance for mental and physical health. We must now finish the parity job and finally give Medicare beneficiaries the full parity that other individuals now have.” The MHLG also sent a letter to Reps. Paul Tonko (D-N.Y.), an NABH Behavioral Healthcare Champion, and Bill Huizenga (R-Mich.) regarding a companion bill in the House.CMS Issues Guidance on Access to Mental Health and SUD Services for Children and Pregnant Women
CMS this week sent a letter to state health officials that describes a provision in the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act related to coverage of mental health services for children and pregnant women. “While the SUPPORT Act builds on MHPAEA, it is different in two important ways,” Calder Lynch, deputy administrator and director for the Center of Medicaid and CHIP Services, wrote in the letter. “Unlike MHPAEA, the SUPPORT Act explicitly requires coverage of behavioral health services.”ONDCP to Host Webinar on Building the Addiction Physician Expert Workforce
Office of National Drug Control Policy (ONDCP) Director James Carroll and HHS Assistant Secretary for Health Admiral Brett Giroir, M.D. will host the webinar Building the Addiction Physician Expert Workforce to promote understanding of the addiction physician’s role in meeting the needs for substance use disorder (SUD) prevention and treatment. The hourlong session on Tuesday, March 10 at 2 p.m. ET will also provide information and resources for efforts to expand the addiction physician workforce. Click here to register.NABH Welcomes Domestic Policy Council Director Joe Grogan as Annual Meeting Speaker
NABH is pleased to welcome Joe Grogan, assistant to President Trump and director of the Domestic Policy Council, as a speaker to kick off the Annual Meeting policy breakfast on Wednesday, March 18 at 8 a.m. Grogan, who leads the Trump administration’s domestic policy agenda, served previously as associate director for health programs at the Office of Management and Budget, where he managed the allocation and budgeting of more than $1 trillion in federal spending. In the private sector, Grogan has worked in management at leading biotechnology firms Gilead Sciences, Inc., and Amgen, Inc. During President George W. Bush’s administration, he served as both a civil servant and in policy-making roles for more than seven years. Grogan has also served as executive director of the Presidential Advisory Council on HIV and AIDS (PACHA), senior advisor to the FDA commissioner, and special assistant in the Administration for Children and Families. Learn more about our Annual Meeting speakers and preliminary program. We look forward to seeing you in Washington!Fact of the Week
In 2018, estimated 27.2 million Americans age 18 and older reported they experienced an alcohol or other drug use problem in their lifetime and approximately 20.2 million Americans over 18 described themselves as being in recovery from a drug or alcohol problem or having recovered from one. For questions or comments about this CEO Update, please contact Jessica Zigmond.CEO Update 91
Insurers Sign Settlement with Massachusetts Attorney General Over Mental Health Parity
Five large Massachusetts health insurers and two behavioral healthcare companies on Thursday signed a settlement with Massachusetts Attorney General Maura Healey regarding allegations that the organizations violated the state’s mental health parity laws.
A statement from Healey’s office said a number of the state’s healthcare companies have under-reimbursed mental healthcare services; imposed unlawful barriers, including prior authorization requirements for behavioral health services that were not required for comparable physical health services and could not be justified under the Parity Act; and had inaccuracies in their provider directories. The companies will pay a combined $1 million for a fund to promote initiatives to broaden access to mental health.
The settlement involves Harvard Pilgrim Healthcare and its behavioral health management company United Behavioral Health, which does business as Optum, Fallon Health and its behavioral health management company Beacon Health Strategies, Always Health Partners, Blue Cross Blue Shield of Massachusetts, and Tufts Health Plan.
“Treatment for substance use disorder and access to therapy are vital to public health, but too many people are facing unlawful barriers to the care they need,” Healey said in the statement. “These companies are making substantial and unprecedented changes to help ensure patients don’t have to struggle to find behavioral health services in Massachusetts.”
DEA Eases Regulations for Mobile Methadone
The Drug Enforcement Administration (DEA) this week proposed a regulation that revises the Controlled Substances Act (CSA) to permit narcotic treatment programs (NTPs)—opioid treatment programs, detoxification services that use methadone, and compounders— to operate mobile components, or mNTPs, without separate registrations.
The rule also proposes requirements related to security, recordkeeping, reporting, and inventory. The purpose of the rulemaking is to address the opioid epidemic by expanding access to methadone treatment, especially for residents of rural and underserved communities.
Learn more here from the NABH Issue Brief about the proposed rule.
CDC Requests Information on Workplace Supported Recovery
The Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH) is seeking feedback on a NIOSH plan to develop resources and conduct research on Workplace Supported Recovery.
Workplace Supported Recovery programs help workers and employers facing the nation’s opioid crisis and other substance use disorders.
Click here to learn more about the request for information.
CMS Requests Public Comments on Rural Maternal and Infant Healthcare
The Centers for Medicare & Medicaid Services (CMS) has released a request for information regarding rural maternal and infant healthcare to improve access, quality, and outcomes for women in rural communities before, during, and after pregnancy.
Click here to read the agency’s Issue Brief on maternal healthcare in rural communities, and here to learn more about CMS’ request for information.
NABH Endorses NSC’s National Plan to Address Opioid Misuse
NABH this week joined more than 50 other organizations to endorse the National Safety Council’s National Plan to Address Opioid Misuse, which is intended for any presidential candidate to adopt as a roadmap to tackle America’s opioid crisis.
The plan offers solutions for the entire lifecycle of addiction, from prevention to recovery. It also offers recommendations that address the role prescribers play and that improve training and education of the non-addiction specialist medical workforce, including primary care, emergency department, Acura Care, and nw ark health professionals.
Kirsten Beronio Joins NABH as New Director of Policy and Regulatory Affairs
NABH is pleased to welcome Kirsten Beronio as the association’s new director of policy and regulatory affairs, effective Feb. 24.
Kirsten comes to NABH with more than 20 years of experience developing mental health and substance use disorder policy in leadership positions she has held in the legislative and executive branches of the federal government and at Mental Health America.
“Kirsten’s background in developing, implementing, and advocating for policies that help people struggling with mental health and substance use disorder positions her well for this role, and we are thrilled to have her join our team,” NABH President and CEO Shawn Coughlin said in a Feb. 24 news release.
Most recently Kirsten served as the senior policy advisor for behavioral health in the Center for Medicaid and Children’s Health Insurance Program (CHIP) at the Centers for Medicare & Medicaid Services from 2016 to 2020.
Before that, Kirsten worked as the first division director for behavioral health and intellectual disabilities policy in HHS’ Office of the Assistant Secretary for Planning and Evaluation. In addition to developing this new division from its inception, Kirsten served as a subject matter expert focused on federal parity legislation and regulations, implementation of key provisions of the Affordable Care Act, and various healthcare financing policies in Medicaid, Medicare, and CHIP. Kirsten earned a B.A. from Princeton University and a J.D. from Georgetown University.
At NABH, Kirsten will oversee quality and regulatory issues and will serve as the staff liaison for the Youth Services and Quality Committees.
2020 NABH Online Membership Directory Now Available
NABH this week released its 2020 online Membership Directory to help clinicians, hospital admissions staff, employee assistance directors, school counselors, policymakers, journalists, patient advocates, and families identify systems and facilities that provide essential behavioral healthcare services.
This is the second year NABH has made the Membership Directory available online, and the first year it is available only in a digital format. 2020 also marks the first time NABH has made the directory available to the general public.
“We are eager to share this useful resource with the public at a time when the need for quality behavioral healthcare services has never been greater,” NABH President and CEO Shawn Coughlin said in a Feb. 26 news release. “We hope people will find it helpful and share it with others who are looking for mental health or substance use treatment in their area.”
Directory information includes each NABH system member’s name, leadership, address, phone number, and website, as well as the behavioral healthcare facilities that each system operates.
Please call NABH at 202-393-6700 or e-mail nabh@nabh.org if you have questions.
NIMH, CDC Leaders to Address Attendees at NABH 2020 Annual Meeting
NABH is pleased to welcome federal healthcare officials from the National Institute of Mental Health (NIMH) and the CDC at the Annual Meeting in Washington next month.
Please join us on Tuesday, March 17 at 8:30 a.m. to hear from Joshua Gordon, M.D., Ph.D., director of the NIMH, whose work has had direct relevance to schizophrenia, anxiety disorders, and depression. And on Wednesday, March 18 at 9 a.m., NABH will welcome Debra Houry, M.D., M.P.H., director of the CDC’s National Center for Injury Prevention and Control. Dr. Houry, who completed her residency training in emergency medicine, will discuss adverse childhood experiences, overdose, and suicide.
Learn more about Drs. Gordon and Houry and our other Annual Meeting speakers on our Annual Meeting Speakers page. We look forward to seeing you next month in Washington!
Fact of the Week
Despite the number of people in recovery, nearly 89% of the estimated 20.2 million Americans who met the criteria for a substance use disorder (SUD) in 2018 did not receive specialized treatment for their condition.
For questions or comments about this CEO Update, please contact Jessica Zigmond
DEA Eases Regulations for Mobile Methadone
DEA Eases Regulations for Mobile Methadone
The Drug Enforcement Administration (DEA) on Feb. 26 proposed a regulation that revises the Controlled Substances Act (CSA) to permit narcotic treatment programs (NTPs)—opioid treatment programs, detoxification services that use methadone, and compounders— to operate mobile components, or mNTPs, without separate registrations.
The rule also proposes requirements related to security, recordkeeping, reporting, and inventory. The purpose of the rulemaking is to address the opioid epidemic by expanding access to methadone treatment, especially for residents of rural and underserved communities.
Background
Currently, each mobile component of an NTP must be separately registered, as the components dispense narcotic drugs regularly and therefore constitute a “principal place of business” or a “professional practice.” The CSA permits waivers to this requirement in instances that serve public health. The DEA had provided waivers on an ad hoc basis until a moratorium was implemented in 2007; after that, there was a subsequent decline in the number of operational mobile components.
The proposed rule obviates the need for ad hoc waivers by establishing mobile unit operations as a permissible “coincident activity” under the CSA with prior approval of a local DEA office.
Selected Summary of Requirements
- Registration
- Registrants notify the local DEA office in writing about intent to operate an mNTP and receive explicit written approval prior to operation.
- The mNTP functions within the same states that the NTP is registered.
- Practitioners maintain a DEA license in each state where they dispense controlled substances.
- Vehicles possess valid county/city and state information on file at the NTP.
- mNTPs are a controlled premise subject to administrative inspection; registrants provide licensing and registration to DEA at time of the inspection and before transportation of substances.
- mNTPs may not serve as hospitals, long-term care facilities, emergency medical service vehicles, or patient transportation.
- Security
- Storage area must not be accessible from the outside of the mNTP vehicle.
- Substances are secured in a locked safe:
- with safeguards against forced entry, lock manipulation, and radiological attacks;
- cemented to the floor or wall such that it cannot be readily removed;
- equipped with an alarm system that can directly signal a protection company, local or State policy agency, or 24-hour registrant-operated control station, or other DEA Administrator approved protection.
- Transportation personnel retain control over the controlled substances when transferring, traveling, and dispensing the substances.
- mNTP is returned to registration location after operations are completed.
- Substances are removed and secured within the registered NTP location.
- Protocols allow for securing substances if the component is disabled.
- Substances are removed and secured if the vehicle is taken to an automotive shop for repair.
- For security breaches such as theft and loss, the NTP must abide by theft and loss reporting requirements.
- NTPs follow state and federal regulations or whichever is more stringent and consults with State Opioid Treatment Authority to ensure compliance.
- Other security controls
- Ensure proper security measures and patient dosage, e.g., enrolled individuals wait in an area of the mNTP that is physically separated from the narcotic storage and dispensing area by a physical entrance.
- If no seating is available, patient will wait outside of the mNTP.
- mNTPs will abide by existing HHS standards for quantity of substances provided for unsupervised use.
- Degree of security is at DEA discretion, based on factors including the location, number of patients, staff, and security guard.
- Disposal of controlled substances is done consistent with all applicable laws and regulations.
- Distribution and delivery of controlled substances to mNTP is only done at the registered location. Persons delivering narcotic drugs to mNTP may not:
- Receive or deliver controlled substances to another mNTP or other entity while deployed outside the registered location.
- Act as reverse distributors (or collectors).
- Ensure proper security measures and patient dosage, e.g., enrolled individuals wait in an area of the mNTP that is physically separated from the narcotic storage and dispensing area by a physical entrance.
- Records and Reports
- mNTP records are maintained in a paper dispensing log at the registered NTP, or
- Use of automated/computerized system if the system:
- maintains the same information as required for paper records;
- has the capability to produce hard copies of the dispensing records;
- the mNTP prints each day’s dispensing log which is initialed by individuals who dispense the medication;
- produces accurate summary reports for any time frame requested by DEA in an investigation;
- Hard copies of summaries are systematically organized at the NTP;
- Computer generated information has off-site back-up;
- DEA approves of the system.
- mNTP maintain records for two years, or longer if required by the state.
NABH 2020 Directory Features Essential Behavioral Healthcare Sources
WASHINGTON, Feb. 26, 2020 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) is pleased to share its online Membership Directory with the public for the first time.
NABH’s Membership Directory is designed to help clinicians, hospital admissions staff, employee assistance directors, school counselors, policymakers, journalists, patient advocates, and families identify systems and facilities that provide essential behavioral healthcare services across the United States.
Read more at PR Newswire
Kirsten Beronio Joins NABH as Director of Policy and Regulatory Affairs
WASHINGTON, Feb. 24, 2020 /PRNewswire/ — Kirsten Beronio has joined the National Association for Behavioral Healthcare (NABH) as director of policy and regulatory affairs, effective Feb. 24.
Kirsten Beronio comes to NABH with more than 20 years of experience developing mental health and substance use disorder policy in leadership positions she has held in the legislative and executive branches of the federal government and at a leading mental health advocacy organization.
“We are excited to welcome someone with the depth and breadth of behavioral healthcare policy experience that Kirsten brings,” said Shawn Coughlin, president and CEO at NABH. “Kirsten’s background in developing, implementing, and advocating for policies that help people struggling with mental health and substance use disorder positions her well for this role, and we are thrilled to have her join our team.
Learn more at PR Newswire
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 ZigmondCEO 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.
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. 28The 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 ZigmondONDCP 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.
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 ZigmondNABH Comments on CMS’ New Survey and Certification Process for Psychiatric Hospitals
WASHINGTON, Jan. 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
CEO Update 85
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.
CEO Update 84
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
WASHINGTON, Dec. 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 WeekThe 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 ForceThe 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 AvailableGeneral 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 WeekIn 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.CEO Update | 81
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
WASHINGTON, Nov. 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.CEO Update | 79
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 ScheduleCMS 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:
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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 BeneficiariesAn eligible individual for section 5052 (the new IMD authority) is a person who is:
Requirements for IMDsEligible 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 StatesStates are required to:
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