Author: Meghan Barrett

CNN Analyst Ron Brownstein to Headline 2026 Annual Meeting Luncheon

NABH is pleased to welcome CNN analyst and two-time Pulitzer Prize finalist Ron Brownstein as our 2026 Annual Meeting Luncheon speaker during this election year.

As a senior political analyst for CNN and opinion columnist, Brownstein produces sharp analysis on politics, policy, the electorate, media, healthcare, and the range of issues informed by his strong sense of American political and national history.

Brownstein also served as the national political correspondent and a columnist for the Los Angeles Times. In his years at the Times, he earned two finalist nods from the Pulitzer Prize Board for his coverage of the 1996 and 2004 presidential elections. He has appeared frequently on Meet the Press, This Week with George Stephanopolous, Face the Nation, The Newshour, and Washington Week in Review. He has also served as an election analyst for ABC.

Brownstein is the author or editor of seven books. His previous book, Reagan’s Ruling Class: Portraits of the President’s Top 100 Officials, was a Washington Post bestseller for five weeks. His articles on politics, public policy, books and culture have also appeared in a number of newspapers and magazines, including The New York Times Magazine, Esquire, Vanity Fair, The Washington Monthly, The Wall Street Journal, The Boston Globe, and The Chicago Sun-Times.

Please be sure to register for this year’s Annual Meeting and help us welcome Brownstein on Tuesday, March 3 at 12:45 p.m. ET at The Ritz-Carlton Washington, DC.

President Trump Signs Appropriations, Health Extenders, Telehealth Extention Package

President Trump on Tuesday, Feb. 3 signed legislation to end the three-day government shutdown. Earlier in the day, the House passed the appropriations minibus that funds five agencies – including  Labor and HHS – through Sept. 30. The bill also includes key Medicare extenders.
 
The package that congressional leaders negotiated last month extends Medicare telehealth flexibilities through 2027, continues mandatory funding for community health centers, reauthorizes a slate of expiring Medicare and public health programs, and delays disproportionate share hospital payments cuts through FY2028. The package also takes a step toward site-neutral pay by requiring off-campus hospital outpatient departments to maintain a separate national provider identity.

This minibus bill’s passage will allow CMS and other key HHS offices to resume operations following the brief lapse in funding. Twenty-one Democrats joined Republicans in passing the minibus, with 21 Republicans bucking against leadership and voting against the package.

Federal Court Issues Amended Remedies in Wit v. UBH

The U.S. District Court for the Northern District of California this week issued an amended remedies order in Wit v. United Behavioral Health (UBH), a landmark case for which in the Court in 2019 found that UBH violated its responsibilities to beneficiaries of applicable plans by imposing medical necessity criteria that misaligned with generally accepted standards of care (GASC) to protect its own interests.
 
The latest order: 1) permanently enjoins UBH from implementing these medical necessity criteria (other than portions that accurately reflect GASC), and 2) for five years directs UBH to align medical necessity criteria with GASC, as established by the court’s findings and in accordance with state law.

President Trump Announces Actions to Begin Implementing SUD Executive Order

Following President Trump’s Executive Order last week that launched the Great American Recovery Initiative – a government-wide effort to coordinate and implement actions to prevent, treat, and support recovery from substance use disorder (SUD) – HHS expanded several new opportunities.
 
The new Safety Through Recovery, Engagement, and Evidence-based Treatment and Supports (STREETS) Initiative through the Substance Abuse and Mental Health Services Administration (SAMHSA) will provide $100 million for “targeted outreach, psychiatric care, medical stabilization and crisis intervention, while connecting Americans experiencing homelessness and addiction to stable housing with a clear focus on long-term recovery and independence.”

Another SAMHSA grant program, Assisted Outpatient Treatment, will receive $10 million to support civil court-ordered outpatient treatment for adults with serious mental illness.

Meanwhile, the Administration for Children and Families announced that medications for opioid use disorder (i.e., methadone, buprenorphine, naltrexone) are now included in the Title IV-E Prevention Program, an optional program that allows states and tribes to receive a 50% federal match for select services that help prevent youth from entering foster care. As a result, states and tribes will have another funding mechanism to support families with children at imminent risk for foster care placement solely due to a parent’s untreated opioid use disorder.

CMS Issues Letter on State-Directed Payments

CMS this week sent a “Dear Colleague” letter related to the Working Families Tax Cuts legislation’s state-directed payments (SDPs) provision.
 
The law (also referred to as H.R. 1 or the OBBBA) requires CMS to lower the payment rate limits for certain SDPs in Medicaid managed care beginning July 4, 2025, while temporarily grandfathering some existing arrangements until 2028. This letter primarily reiterates the statute, noting that certain SDPs from 2024–2026 may qualify for temporary grandfathering if submitted on time or supported by a good‑faith effort to obtain approval.
 
In the letter, CMS said it is exploring the option of expanding the SDP restrictions to other services besides the four in statute (inpatient hospital services, outpatient hospital services, nursing facility services, qualified practitioner services at academic health centers) but did not name other potential services.

CMS said it is developing a notice of proposed rulemaking to implement provision of the law. NABH will continue monitoring this issue and will weigh in with CMS before and during rulemaking.

HHS Selects Nationwide Pilot Programs to Improve Behavioral Health Data Exchange

The Assistant Secretary for Technology Policy (ASTP) and SAMHSA announced it has selected nine nationwide pilot programs to test health information technology (IT) standards to strengthen behavioral and physical health integration through improved data exchange.

Together SAMHSA and ASTP are supporting the pilots through the Behavioral Health Information Technology (BHIT) Initiative, a $20+ million program.  

The pilot program includes 45 exchange partners across nine states (Colorado, Connecticut, Delaware, Florida, Massachusetts, North Carolina, Oregon, Rhode Island, and Washington, D.C.) and will test specific behavioral health data elements in real-world behavioral health settings.

The pilots will be completed by the end of 2026, and their findings will inform future standards, technical specifications, and policy considerations for the broader health provider community and shape future resources for the behavioral health community.

Fact of the Week

Facing an estimated 50% of Olympians and 60% of Paralympians reporting mental‑health concerns, the U.S. Olympic & Paralympic Committee has dramatically expanded its support program ahead of the 2026 Milano‑Cortina Games, USA Todayreported this week.

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

2026 NABH Exhibitor and Sponsor Guide Ad Deadline is Today, Jan. 30!

This is a reminder that all advertisements to be included in NABH’s 2026 NABH Exhibitor and Sponsor Guide are due today, Friday, Jan. 30.
 
The Exhibitor and Sponsor Guide provides an opportunity to showcase your organization’s products and services, elevate your brand visibility, and reach key decision makers. Distributed to all registrants at the 2026 NABH Annual Meeting, the Exhibitor and Sponsor Guide highlights logos, organization descriptions, and additional advertisements.
 
The association will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage and Resources page.
 
Be sure your organization is included today!

Congress Struggles to Reach Government Funding Deal Before Likely Shutdown

On Thursday, Jan. 29, seven Senate Republicans joined all Democrats in blocking a procedural motion forcing the majority and the White House to work on a compromise funding agreement to avoid a government shutdown. Following House passage of a $1.3 trillion spending bill to fund most of the federal government last week, Senate Democrats followed through on their vow to block the package over Department of Homeland Security (DHS) funding. The compromise stripped funding for DHS from the six-bill package and replaced it with a two-week stopgap measure to allow for negotiations over immigration and custom enforcement restrictions. 
 
The Senate convenes today, Jan. 30, to attempt to clear the funding package, which includes $2.79 billion for behavioral health programs under the Substance Abuse and Mental Health Services Administration (SAMHSA), and health extenders, including delaying disproportionate share hospital (DSH) cuts through 2027 and extending Medicare telehealth flexibilities through Dec. 2027. The package does not include any extension of the expired enhanced ACA premium tax credits.
 
Senators have until tonight, Friday, Jan. 30, to secure a deal before the government enters a partial shutdown, but the amended package must go back to the House of Representatives, which is in recess until Monday, making a shutdown almost certain. A partial shutdown will occur because six of the 12 annual spending bills for other major federal departments have already been signed into law. If the shutdown is brief, few, if any, government services will be interrupted.

White House Releases Executive Order Launching a Substance Use Initiative

The White House, on Thursday, Jan. 29, released a new executive order, Addressing Addiction Through the Great American Recovery Initiative. Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr. and Kathryn Burgum, Interior Secretary Doug Burgum’s wife and former first lady of North Dakota, will chair the effort. The administration has appointed Ms. Burgum, who is in recovery from alcohol use disorder and as first lady advocated for substance use treatment access and stigma reduction, as senior adviser for addiction recovery.
 
An executive director will manage the initiative and report to the assistant to the president for domestic policy. This initiative will include officials or their designees from several federal agencies, including the departments of justice, interior, labor, education, veterans affairs, and the Office of National Drug Control Policy. The executive order also names the assistant secretary for mental health and substance use, the head of SAMHSA, as part of the initiative, but the White House has not nominated anyone to fill this role.
 
According to the executive order, the initiative will “coordinate the federal government’s response to the addiction crisis, including by better aligning relevant federal programs, setting clear objectives, and providing data-driven updates to the public on progress towards meeting these objectives.” The initiative will also increase awareness of substance use disorder, advise department and agency leadership on substance use programs and grants, and consult with states, tribes, localities, and other entities to support access to treatment and “celebrate individuals going through the recovery process.”

Medicaid and CHIP Payment and Access Commission Held January Public Meeting

On Thursday, Jan. 29 and Friday, Jan. 30, the Medicaid and CHIP Payment and Access Commission (MACPAC) held its first public meeting of 2026.
 
Among topics relevant to NABH members, MACPAC commissioners discussed findings from Chapter 2 of their June 2025 Report to Congress, which focuses on appropriate access to residential behavioral health treatment for children and youth. To address concerns raised in that report, MACPAC recommended three policy options:

1. Congress will require HHS to develop and maintain a directory of youth residential treatment facilities.
2. The Centers for Medicare & Medicaid Services (CMS) will report on the use of residential treatment services.
3. CMS will revise federal regulations to establish minimum requirements for discharge planning processes.

During the public meeting, MACPAC also discussed considerations and policy options for implementing Medicaid community engagement requirements, children and youth with special health care needs transitions to adult coverage, behavioral health in Medicaid and the state Children’s Health Insurance Program, and Medicaid for justice-involved youth transitions to the community. NABH will monitor these policy recommendations, engage with MACPAC and CMS, and provide updates to NABH members.

Outpatient Drug Acquisition Cost Survey Resources

HHS is requiring hospitals to complete the Outpatient Drug Acquisition Cost Survey (ODACS). ODACS collects the acquisition costs of certain outpatient drugs and biological products that hospitals paid under the Medicare Hospital Outpatient Prospective Payment System (OPPS) purchase. CMS will consider these data when determining the appropriate payment rates for hospitals paid under the OPPS.
 
All hospitals paid under the OPPS between July 1, 2024, and June 30, 2025, must submit data by March 31, 2026. For more information on the ODACS, please see the OPPS ODACS webpage, FAQs, or contact OPPSDrugSurvey@cms.hhs.gov with questions.

Fact of the Week

A recent JAMA survey found that daily generative AI use is linked to a 30% increased likelihood of moderate depressive symptoms by users. Out of 20,847 US adults polled, 10.3% reported using generative AI daily.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Learn from Former Walmart Leadership Director and Author Neil Pasricha at the 2026 Annual Meeting!

NABH is pleased to welcome author and former Walmart leader Neil Pasricha to kick off Day 2 of the NABH 2026 Annual Meeting on Tuesday, March 3 at 10 a.m.

Pasricha’s research and books on happiness, mindset, and human potential have been featured in the Harvard Business Review, The New Yorker, The Sunday Times, CNN, and the BBC.

After graduating from Harvard Business School, Pasricha spent a decade as director of leadership at Walmart. It was during this period that he wrote his 50-million-hit, award-winning blog 1000 Awesome Things and the New York Times bestsellers The Book of Awesome and The Happiness Equation, which have been on international bestseller lists for more than 200 weeks and sold more than 1 million copies. Onstage, he’s known for his high energy and his applicable messages to leaders everywhere.

Please help us welcome Neil and other Annual Meeting speakers in March. We look forward to seeing you in Washington!

2026 Annual Meeting Hotel Reservation Cutoff Date is Approaching!

The hotel reservation cutoff date for the NABH 2026 Annual Meeting – Future-Forward Leadership: Imagine. Innovate. Transform. – is Monday, Feb. 9.

If you haven’t done so, please reserve your hotel room today to secure NABH’s group rate. Also please remember to register for this year’s meeting!

House Passes $1.2 Trillion Spending Bill Before Government Shutdown Deadline on Jan. 30

The House on Thursday passed a $1.2 trillion spending bill to fund the majority of the federal government as the Jan. 30 government shutdown deadline looms.
 
The four-bill minibus includes nearly $117 billion for HHS and $13.7 billion for the U.S. Labor Department and a long-delayed health extenders package.
 
The Labor/HHS bill supports HHS Secretary Robert F. Kennedy Jr.’s “Make America Healthy Again” agenda but does not include funding for the new agency he proposed to create, the Administration for a Healthy America (AHA). Kennedy’s planned AHA is a $19 billion proposal that would include functions of five existing agencies focusing on primary care, maternal and child health, mental health, environmental health, HIV/AIDS, and workforce development.
 
The health extenders package includes:

• A two-year extension of Medicare telehealth flexibilities through December 2027.
• An extension of Medicare add-on payments for low-volume hospitals through fiscal 2028 and the Medicare Dependent Hospital program through Dec. 31, 2026.
• An extension of incentive payments for participation in eligible alternative payment models (APMs) to cover 2028, with the incentive set at 3.1%.
• Multi-year extensions of funding for community health centers, the National Health Service Corps, and teaching health center graduate medical education programs.
• An extension of the Medicare Geographic Practice Cost Index floor through Jan. 1, 2027.
• Medicare Advantage provider directory accuracy requirements, addressing so-called “ghost networks” that have come under scrutiny in recent years.
• Language from the Accelerating Kids Access to Care Act to streamline out-of-state Medicaid provider requirements.
• A reduction in the Medicare Improvement Fund and an extension of Medicare sequestration instructions into fiscal year 2033, both used as budgetary offsets.
• Requirements for a separate identification number and attestation for each off-campus outpatient department.

More comprehensive site-neutral payment policies were omitted, as were two heavily supported bills from Sen. Roger Marshall (R-Kansas) that would have imposed tougher statutory Medicare Advantage prior authorization requirements and strengthened hospital price transparency rules.
 
As NABH expected, the package doesn’t include an extension of the expired enhanced Affordable Care Act premium tax credits. The legislation now moves to the Senate, where it is expected to pass.

SAMHSA Announces Funding Opportunity for 988 Lifeline

The Substance Abuse and Mental Health Services Administration (SAMHSA) recently announced a $231 million funding opportunity to administer the 988 Suicide & Crisis Lifeline.
 
According to the announcement, public and private not-for-profit entities are eligible to apply, and the purpose of the program is to serve as the 988 Lifeline Administrator and manage, enhance, and strengthen the 988 lifeline.
 
Click here for more information. Applications are due by Friday, Feb. 27, 2026.

Fact of the Week

In a randomized clinical trial of 590 adults who had received evidence-based smoking cessation treatment and had abstained for three to 30 days, mobile chat messaging significantly increased six-month, biochemically validated tobacco abstinence compared with text messaging 45.9% versus 35.5%), according to a recent study published in JAMA Internal Medicine.

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

Explore NABH’s Opportunities to Highlight Your Organization in 2026

NABH is eager to feature your organization in conjunction with our 2026 Annual Meeting– Future-Forward Leadership: Imagine. Innovate. Transform.
 
Please take a moment to review the options in our 2026 Exhibitor and Sponsor Opportunities and share this resource with anyone interested in building professional relationships, elevating brand visibility, and generating business development in behavioral healthcare.
 
And please consider advertising in this year’s Exhibitor and Sponsor Guide, regardless of whether you choose to serve as an exhibitor or sponsor at the 2026 Annual Meeting. Please click here for details. All advertisements are due by Friday, Jan. 30, 2026.  
 
We look forward to seeing you at The Ritz-Carlton Washington, DC in March. Please register for the meeting and reserve your hotel room today!

ICYMI: SAMHSA Reverses Course on Grant Funding Terminations

Congressional leaders announced Wednesday, Jan. 14 that the Substance Abuse and Mental Health Services Administration (SAMHSA) will reinstate grant awards the agency had terminated on Tuesday.

SAMHSA had sent termination notices for about 2,800 awards, totaling approximately $2 billion in mental health and substance use funding. Congress showed bipartisan support to reinstate the funding, pressuring HHS Secretary Robert Kennedy to reverse the terminations.
 
In other federal healthcare news this week, President Trump released his healthcare framework, a one-page document that maps out his priorities related to insurance premiums, insurer accountability, and price transparency.

CBO Evaluates Effectiveness of Opioid Crisis Policy Approaches

The Congressional Budget Office (CBO) this week released a report that assesses policy approaches to address the opioid crisis, including policies related to reducing opioid supply, demand, and harms.
 
CBO found that opioid use disorder treatment-related efforts such as expanding Medicaid coverage, increased telehealth, supporting treatment engagement for people involved in the criminal justice system, and enhancing state prescription drug monitoring programs had consistent evidence for several positive outcomes (e.g., treatment engagement, lower drug misuse). Broadening access to opioid overdose reversal medications (e.g., naloxone) also helped reduce deaths, the report said.
 
Meanwhile, efforts to disrupt the supply of illicit opioids had somewhat consistent evidence for reducing hospital admissions, crime rates, and mortality, but some evidence indicated that the effects were temporary.

CMS Releases RFI on Feedback to Modernize Claims Processing System

The Centers for Medicare & Medicaid Services (CMS) has released a request for information (RFI) seeking ways to replace its Medicare claims processing system with a real-time, cloud-based platform.
 
According to the RFI, the new “ClaimsCore” program will redesign Medicare fee-for-service processing by replacing legacy shared systems, including the Multi-Carrier System, Fiscal Intermediary Shared System, and Durable Medical Equipment Claims System, as well as the Common Working File, with a flexible and interoperable platform that puts Medicare beneficiaries at the center of every decision.
 
The changes are meant to improve the beneficiary experience, reduce provider burden, and increase administrative efficiency in the Medicare program.

American Medical Association Releases 2025 Report on Substance Use

In a report released this week, the American Medical Association (AMA) said while opioid-related deaths have dropped to 75,000 from more than 110,000 in 2023, most are still driven by illicitly made fentanyl—and nearly 60% involve more than one dangerous substance.
 
The report, Substance Use and Treatment: Progress, Policy, and Future Directions, also noted that the 2024 decline in overdose deaths is coupled with a complex substance use and overdose epidemic, complicated by increasing prevalence of polysubstance use and an unpredictable illicit drug supply.
 
AMA recommends expanding naloxone distribution and access and removing barriers to substance use treatment access. The organization endorses additional research on emerging threats and identifies their policy priorities, including enforcing parity laws, removing barriers to treatment for pain and substance use disorder, and strengthening overdose prevention efforts.
 
The Chicago-based medical association also commented on the effects of cannabis use nationwide.

“We’re also seeing harms rise even as more states legalize cannabis,” the reported noted. “Emergency visits for cannabinoid hyperemesis syndrome have climbed more than 400% since 2016, and more than 19 million people met criteria for cannabis use disorder in 2023,” it added. “The evidence needs to guide us moving forward. Legal doesn’t mean harmless or useful, and we can’t ignore these trends.”

Fact of the Week

About 38% of Americans plan to make a mental health-related resolution for 2026, according to a new poll from the American Psychiatric Association. The percentage is considerably higher than the 5% of Americans who made the same resolution last year, the survey noted.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Welcomes Jim Shaheen to Second Term as NABH Board Chair

NABH is pleased to welcome NABH Board Chair Jim Shaheen, CEO of New Season, to his second year leading the association’s board of trustees.
 
NABH members voted last month on the association’s 2026 slate of board candidates, and Jim graciously agreed to serve as board chair for another year as NABH continues to move through a staff leadership transition.
 
A longtime NABH member, Jim has served NABH in many capacities, including presently as vice president of the NABH Education and Research Foundation and member of the Substance Use Disorder Treatment Committee. Previously he served as NABH’s board treasurer.
 
Jim leads New Season, a nationwide medication-assisted treatment company that serves more than 33,500 patients in 94 clinics located in 20 states. 
 
NABH board member Andrew Lynch, Ph.D., chief strategy officer at Acadia Healthcare in Franklin, Tenn., is now the association’s board chair-elect and will succeed Jim in 2027.
 
NABH is also pleased to welcome members Gina Sharp, M.B.A., FACHE, president of Endeavor Health Linden Oaks Hospital in Naperville, Ill., and Tanmay Mathur, M.S., M.B.A., vice president of Vanderbilt Behavioral Health in Nashville, who began their NABH board terms on Jan. 1.

Performance Management Coach & Former NFL Player Eric Boles to Open 2026 Annual Meeting

NABH is eager to welcome former NFL wide receiver Eric Boles, CEO and Founder of The Game Changers, Inc., as our keynote speaker at the NABH 2026 Annual Meeting on Monday, March 2.

Boles’s company The Game Changers, Inc. offers a non-traditional approach to performance management through talent development, business strategy, change management, cultural transformation, and peak performance. Under his leadership, Boles helps transform an organization’s most valuable resource – its people – through high-energy and powerful storytelling aimed at unleashing individual potential, navigating change, and leading with purpose.

The company’s recent clients include IBM, FedEx, Motorola, Astra Zeneca, Mayo Clinic, Northwestern Mutual, Medtronic, Motion Industries, Bridgestone Tires, Southeastern Grocers, and Boys & Girls Clubs of America.

Before becoming a sought-after speaker and consultant, Boles learned many of his principles of peak performance, team dynamics, and leadership from his experience as a wide receiver with the NFL’s Green Bay Packers and New York Jets. He is the author of Moving to Great: Unleashing Your Best in Life and Work.

NABH will share information about our other Annual Meeting speakers and program information in future Annual Meeting Alerts each week leading up to the Annual Meeting. Please remember to visit our Annual Meeting homepage to view our Schedule At-A-Glance, register for the meeting, and book your hotel room today!

Advertise in the 2026 NABH Exhibitor and Sponsor Guide!

Showcase your organization’s products and services in the 2026 NABH Exhibitor and Sponsor Guide! Distributed to all registrants at the 2026 NABH Annual Meeting, the Exhibitor and Sponsor Guide features logos, organization descriptions, and additional advertisements. Be sure your organization is included today!
 
All advertisements are due by Friday, Jan. 30, 2026. Please click here for details about advertising opportunities.
 
The association also will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage.

House Passes Bill to Revive ACA’s Enhanced Subsidies for Three Years

Seventeen Republicans joined Democrats in passing legislation Thursday that would revive the Affordable Care Act’s (ACA) enhanced subsidies for three years, rebuffing opposition from GOP leadership.
 
The 230-196 vote followed a procedural vote Wednesday to advance the bill, as nine Republicans joined Democrats in forcing a vote on the House Floor. The enhanced ACA subsidies expired at the end of 2025, leaving the prospect of higher premiums for consumers looming while negotiations dragged into January.
 
While a straight three-year extension of the ACA tax credits is a non-starter with Senate Republicans, the bill is a potential vehicle for compromise legislation. A bipartisan group of senators is moving closer to a deal on extending the subsidies with some reforms. Such a deal will likely be similar to Rep. Brian Fitzpatrick’s (R-Pa.) bill that would extend the subsidies for two years, cap income at 700% of poverty, require a minimum payment, and create a pathway for consumers to choose to put subsidies in health savings accounts (HSAs). The Fitzpatrick bill also cracks down on brokers, implements pharmacy benefit manager (PBM) reforms, and importantly, extends open enrollment through March.
 
Lawmakers continue to project optimism about reaching a deal, though thorny issues remain over how to address the so-called Hyde amendment, which restricts federal funding for abortion. Similarly, some Republicans’ long-held opposition to the ACA could ultimately keep a deal from happening. NABH will keep members apprised of any movement on this legislation.

Senate Confirms Journalist Sara Carter to Lead ONDCP

The Senate on Tuesday voted 52-48 to confirm journalist and former Fox News contributor Sara Carter to lead the White House Office of National Drug Control Policy (ONDCP).
 
A statement from the White House on Tuesday highlighted Carter’s experience as an investigative journalist exposing drug cartels and drug trafficking routes along the U.S.-Mexico border. Trump has spent part of his second term using the fight against illicit drug trafficking to depose Venezuela’s president, Nicolás Maduro, and to threaten other countries in the region with military action.
 
“We will hold accountable the narco-terrorists who infringe upon this right, participating in the deliberate poisoning of tens of thousands of Americans each year,” Carter said in the announcement about her confirmation as the country’s 10^th drug czar. “They will no longer kill our families, friends, neighbors, and even children with impunity,” she continued. “At the same time, I will ensure that every parent, family member, and child have the resources they need to prevent and combat addiction. I will stand with our brave law enforcement officials, and with every family who has lost a loved one to drug overdose. This is my promise to the American people.”

DEA and SAMHSA Temporarily Extend Flexibility for Prescribing Controlled Substances via Telemedicine

The Drug Enforcement Administration (DEA) and Substance Abuse and Mental Health Services Administration (SAMHSA) recently issued another temporary extension of the COVID-19 pandemic-era flexibility to the general requirement for practitioners to conduct an in-person medical evaluation before prescribing a controlled substance.
 
This extension allows practitioners to prescribe controlled substances via telemedicine to patients with whom they have never had an in-person visit through Dec. 31, 2026. The agencies implemented this extension to give them more time to consider further rulemaking on telemedicine, which could include establishing a special registration for telemedicine, as proposed previously.
 
Meanwhile, a final rule is now effective that allows practitioners to prescribe buprenorphine for opioid use disorder via telemedicine for up to 6 months before having an in-person visit or leveraging another regulatory pathway for telemedicine (including any forthcoming rule). However, buprenorphine for opioid use disorder is covered by the temporary extension discussed above, so the 6-month time limit would not be imposed until the extension expires at the end of 2026.
 
Please note that none of the aforementioned regulatory activities affect the use of telemedicine for medications that Opioid Treatment Programs dispense.

CMS Announces $50 Million in Rural Health Transformation (RHT) Program Awards

The Centers for Medicare & Medicaid Services (CMS) announced that all 50 states will receive awards under the Rural Health Transformation (RHT) Program, a five-year, $50 billion initiative established under Working Families Tax Cuts legislation (Public Law 119-21, also known as H.R. 1 or the One Big Beautiful Bill Act).
 
This year CMS will distribute first-year awards averaging $200 million per state. Awards ranged from $147 million in New Jersey to $281 million in Texas. Congress included the RHT program in the July 2025 budget reconciliation bill to mitigate the impact to rural communities of other cuts to the Medicaid program. 
 
CMS has compiled the RHT Program project abstracts each state submitted as part of its application. The Kaiser Family Foundation reported that the first-year RHT funds range from less than $100 per rural residents in 10 states to more than $500 per rural resident in eight states.
 
In December, CMS established the Office of Rural Health Transformation (ORHT) within the Center for Medicaid and CHIP Services (CMCS) to administer the RHT Program.

Fact of the Week

For the fifth year in a row, use of most substances among U.S. teenagers has continued to hover around the low-water mark reached in 2021, according to latest Monitoring the Future, an annual survey of drug use behaviors and attitudes among eighth, 10th, and 12th graders that the National Institutes of Health has supported for 51 years.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Register Today for the 2026 Annual Meeting and Visit Our Annual Meeting Homepage!

Registration opened this week for the 2026 NABH Annual Meeting, Future-Forward Leadership: Imagine. Innovate. Transform. at The Ritz-Carlton Washington, DC from March 2 – 4, 2026!
 
Our team in Washington is excited about the 2026 Annual Meeting, and we will e-mail members information about our keynote speakers, new breakout sessions, and more in an Annual Meeting Preview on Friday, Jan. 2.

In the meantime, please visit the Annual Meeting homepage today to view our Schedule At-A-Glance, register for the meeting, reserve your hotel room, and learn about and share our 2026 Exhibitor and Sponsor Opportunities.  We look forward to seeing you in Washington!

Reminder: NABH 2026 Board Election Ballots Are Due Wednesday, Dec. 31

NABH asks all system members to please elect new members to the 2026 Board of Trustees by the end of this month.
 
On Dec. 9, the association e-mailed NABH system members an attachment with NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2026 Board.
 
If you haven’t yet, please vote for the open NABH Board Chair-Elect position and two available Board seats; sign the ballot; scan it; and send it to nabh@nabh.org or maria@nabh.org no later than Wednesday, Dec. 31, 2025.
 
Please note your ballot is not valid without a signature. New Board members and the Board Chair-elect will take office in January 2026.

NABH Submits Comments on Proposed Safety and Follow-up Plan Measure

NABH on Dec. 19 submitted comments to CMS about the proposed Post-Discharge Safety and Follow-up Plan for Patients with Suicidal Ideation measure, which the agency is considering including in the Inpatient Psychiatric Facility Quality Reporting Program.
 
In our comments, we noted our support for safety planning, which has a strong evidence base. However, we did not support including the discharge planning component of the measure, which does not have the same evidence-based support for use among all patients admitted to Inpatient Psychiatric Facilities. We highlighted this lack of evidence as well as the burden of discharge planning in our letter. Meanwhile, we recommended re-examining exclusions.
 
CMS posted measure information, specific questions, and directions for submitting public comments on its Measures Management System.

NABH to Launch Quality Measure Initiative in 2026

NABH will launch an initiative in 2026 to improve behavioral health quality measurement.
 
Led by Quality Committee co-chairs Frank Ghinassi, Ph.D., A.B.P.P. and Karen Johnson, M.S.W., NABH will form a subcommittee to review validated quality measures for both mental health and substance use. The subcommittee will identify the best quality measures in key domains, determine gaps in quality measure research, and engage with behavioral health stakeholders to come to a consensus on key quality indicators.
 
NABH’s ultimate goal is to standardize and improve measurement across the industry. For more information, please contact Sarah Steverman, the NABH staff leader for the initiative. 

NABH Urges Strong Federal Enforcement of Mental Health Parity

NABH and a group of behavioral health stakeholders sent a letter this week to the Secretaries of Labor, Health and Human Services, and Treasury – whose respective agencies regulate health plans – recommending they strongly enforce the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
 
The letter describes the high rates of MHPAEA violations and growing congressional scrutiny of utilization management controls (e.g., prior authorization) that impede access to care. The letter also suggests mechanisms to improve compliance, such as requiring insurers to use data to monitor compliance instead of solely self-attestation, issuing more detailed guidance for insurers, and leveraging civil monetary penalty authorities.

President Trump Signs Executive Order to Reschedule Marijuana

President Trump on Thursday issued an Executive Order to reschedule marijuana from Schedule I to Schedule III, which would eventually enable U.S. Food and Drug Administration-approved marijuana products to be prescribed legally for medical purposes under the federal Controlled Substances Act.
 
Marijuana is one of the most commonly used recreational drugs and marijuana use disorder is a major contributor to the national burden of substance use disorders, with more than 20 million people aged 12 and older reporting a past-year marijuana use disorder in 2024. Meanwhile, anecdotal reports and some research studies have demonstrated a positive clinical effect of marijuana for some conditions, including pain, anorexia related to a medical condition, and nausea and vomiting.  Based on this evidence, HHS in 2023 recommended that the Drug Enforcement Administration (DEA) reschedule marijuana to Schedule III.
 
While states have permitted marijuana to be dispensed for medical or recreational purposes for many years, per federal law, it has been illegal to use outside of research studies. However, in 2013, the U.S. Justice Department issued a memorandum exercising enforcement discretion that has largely stopped prosecutions outside of major trafficking.
 
To effectuate the Executive Order, the DEA must undergo rulemaking to reschedule marijuana.

CMS Releases Psychiatric Inpatient Experience (PIX) Survey Resources for IPFs

CMS released new resources for the Psychiatric Inpatient Experience (PIX) Survey, a new requirement for the Inpatient Psychiatric Facilities Quality Reporting (IPFQR) Program.
 
For calendar year (CY) 2025, CMS encouraged voluntary reporting of the PIX Survey; however, the mandatory reporting period begins in CY 2026. CMS posted the resources on the IPFQR Program Resources webpage of QualityNet and the IPFQR Program Resources and Tools webpage of the Quality Reporting Center.
 
The new PIX Survey Resources are the Comma-separated Value (CSV) Data Collection Template and Instructions, Data Dictionary, Extensible Markup Language (XML) File Layout and Instructions, File Upload Edit Messages, PIX Survey – Spanish Version, and PIX Emoji Scale.

House Passes Healthcare Bill That Does Not Address Expiring ACA Tax Credits

The House passed a conservative healthcare bill Wednesday evening that did not address expiring Affordable Care Act (ACA) tax credits, all but guaranteeing the enhanced subsidies will lapse at the end of the year.
 
H.R. 6703, the Lower Health Care Premiums for All Americans Act, would expand association health plans by allowing employers to offer their own coverage and would codify a rule permitting employers to fund health reimbursement arrangements for workers purchasing individual-market plans.
 
The bill would also fund the ACA’s required cost-sharing reductions, eliminating the need for insurers to raise silver-level premiums. The Congressional Budget Office (CBO) estimated that enacting the GOP’s health plan would decrease the number of people with health insurance by an average of 100,000 a year over the 2027-2035 period. This would add to CBO’s previous estimate that 4 million people would become uninsured if Congress allowed the ACA subsidies to expire. Ultimately, NABH expects the bill will be dead on arrival in the Senate.
 
Hours before the House bill passed, four House Republicans – Reps. Robert Bresnahan (Pa.), Brian Fitzpatrick (Pa.), Mike Lawler (N.Y.), and Ryan Mackenzie (Pa.) — signed onto Minority Leader Hakeem Jeffries’s (D-N.Y.) discharge petition to force a vote on a clean three-year extension of the subsidies, bringing the number of signatures to 218, the threshold required to force a vote on the floor. This sets in motion a January House vote that Democrats and moderate Republicans lawmakers signaled could be a glide path toward a compromise.
 
NABH sent letters to the House and Senate about the ACA’s positive effects on expanding behavioral healthcare and urged extending the ACA’s enhanced tax credits.

‘American Journal of Managed Care’ Examines Impact of Medicaid’s IMD Exclusion on SMI Outcomes

A new study published in the American Journal of Managed Care concluded that Institutions for Mental Diseases (IMD) exclusion waivers have a “beneficial impact” on psychiatric-specific and all-cause healthcare utilization and costs as well as incarceration rates for individuals with serious mental illness (SMI). 
 
Medicaid’s IMD exclusion forbids federal funding for treatment in facilities with more than 16 psychiatric beds; however, some states have obtained waivers under Section 1115 of the Social Security Act to increase options for treating SMI. This new, retrospective claims study assessed healthcare resource utilization, costs, homelessness, and incarceration among Medicaid beneficiaries with SMI in states with and without waivers.
 
According to the study, the odds of having psychiatric-specific inpatient admissions and emergency department (ED) visits were lower by 14% and 26%, respectively, in the waiver cohort (n = 130,224) versus the non-waiver cohort (n = 3,102,971). Odds of all-cause inpatient admissions and ED visits were also lower (9% for both) in the waiver cohort, but the odds of having all-cause outpatient visits were 19% greater in the waiver cohort.  
 
“Although the IMD exclusion was put into place to protect patients from prolonged institutionalization, our findings indicate that state waivers allowing treatment in IMDs do not lead to increased psychiatric hospitalization,” the study noted. “Additional state-level policies such as Medicaid Health Homes and Medicaid expansion should be considered by state policymakers and Medicaid administrators when assessing the risk-benefit trade-offs of investing in mental health services.”

Fact of the Week

Among U.S. adults, 41% say they anticipate more stress related to the holidays this year than last year, a notable increase from 2024 (28%) and 2023 (29%), according to a recent APA Healthy Minds poll.

Happy Holidays from NABH!

NABH will not publish CEO Update on Friday, Dec. 26. Instead, please look for a 2026 Annual Meeting Preview on Friday, Jan. 2. CEO Update will resume on Friday, Jan. 9.

The entire NABH staff wishes you, your families, and your teams a very happy, healthy, and safe holiday season!

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

NABH 2026 Board Election Ballots Due Wednesday, Dec. 31

NABH asks all system members to please elect new members to the 2026 Board of Trustees by the end of this month.
 
On Dec. 9, the association e-mailed NABH system members an attachment with NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2026 Board.
 
If you haven’t yet, please vote for the open NABH Board Chair-Elect position and two available Board seats; sign the ballot; scan it; and send it to nabh@nabh.org or maria@nabh.org no later than Wednesday, Dec. 31, 2025.
 
Please note your ballot is not valid without a signature. New Board members and the Board Chair-elect will take office in January 2026.

NABH 2026 Annual Meeting Registration Opens Next Week; View Our Schedule At-A-Glance

Next week NABH will alert members about preliminary speaker information and open registration for our 2026 Annual Meeting, Future-Forward Leadership: Imagine. Innovate. Transform. at The Ritz-Carlton Washington, DC from March 2-4.
 
Before then, please review our Schedule At-A-Glance to learn the days and times of committee meetings, general sessions, new breakout session, and more.

Senate Rejects Competing Healthcare Bills

The Senate rejected two competing healthcare bills on Thursday, Dec. 11.
 
Both bills fell short of the 60 votes need to pass. Senators voted not to advance a GOP healthcare bill that would have expanded health savings accounts as an alternative to the expiring the Affordable Care Act (ACA) Enhanced Premium Tax Credits. Meanwhile, the Democrats’ bill to extend the enhanced tax credits for three years also did not receive enough votes to pass.

The two votes fell largely along party lines. Sen. Rand Paul (Ky.) was the only Republican to oppose the GOP plan, while Republican Sens. Susan Collins (Maine), Josh Hawley (Mo.), Lisa Murkowski (Alaska) and Dan Sullivan (Alaska) voted to advance the Democrats’ healthcare plan. With time running out, House Republican leaders are expected to introduce a healthcare package this weekend that would expand health savings accounts but does not include an ACA extension.
 
Similarly, a bipartisan group of House lawmakers, led by Rep. Brian Fitzpatrick (R-Pa.), filed a discharge petition Wednesday, Dec. 10 on a bill that would extend the expiring ACA EPTCs for two years; implement income caps and a minimum payment requirement; extend open enrollment through March; add new broker requirements to curb unauthorized enrollments; and allow exchange consumers to establish health savings accounts and elect to send a portion of their tax credits to those accounts. There must be 218 signatures from lawmakers who approve this plan to bring the discharge petition to the House Floor, and House Democratic leaders have not indicated that they support it.
 
Meanwhile, the president’s general disengagement with lawmakers on healthcare talks has effectively doomed chances of a deal before the Dec. 31 expiration of the tax credits, although legislative failures in the Senate could potentially spur more serious negotiations.
 
Earlier this week, NABH sent a letter to senators and contacted their offices about the ACA’s EPTCs and its effect on expanding access to behavioral healthcare.

Senate Advances Resolution that Mandates Public Input on Most HHS Regulatory Activities

The Senate this week voted to advance to a floor vote Senate Joint Resolution 82, which would repeal an HHS policy statement issued in March 2025 that would narrow how HHS regulatory activities are subjected to notice and comment procedures.
 
Under the Administrative Procedures Act (APA), federal agencies are generally required to undertake notice and comment procedures (with exceptions), which consist of publishing proposed rules in the Federal Register, allowing the public to submit feedback on proposed rules, and publishing final rules that include agencies’ responses to public comments on proposed rules. Exceptions to this requirement include regulatory activities “relating to agency management or personnel or to public property, loans, grants, benefits, or contracts;” however, HHS policy since 1971 has been to apply notice and comment procedures to excepted regulatory activities.
 
The 2025 HHS policy statement rescinds the longstanding policy, meaning that some regulatory activities can be pursued without public input. The impact of this policy change is unclear, although other legal requirements may necessitate notice and comment procedures even for regulatory activities excepted under the APA. Meanwhile, the Social Security Act separately requires these procedures for most Medicare regulatory activities.
 
To successfully repeal the HHS policy statement, the House and Senate must pass the Joint Resolution and the President must sign it.

CMS Issues Preliminary Guidance on Medicaid Community Engagement Requirements

The Centers for Medicare & Medicaid Services (CMS) on Dec. 8 provided preliminary guidance to implement the Working Families Tax Cut’s (WFTC) community engagement requirements. The WFTC is also known as H.R. 1 or the One Big Beautiful Bill Act. States will be required to implement community engagement or work requirements for all adults in the Medicaid expansion population by Jan. 1, 2027.
 
The Center for Medicaid and CHIP Services (CMCS) Information Bulletin provides an overview of the WFTC legislation’s community engagement provision but does not provide many details. Importantly, the guidance does not include specific guidance about exempting beneficiaries with disabling mental disorders and substance use disorders.

NABH continues to engage CMS about the best way to ensure coverage continuity for people with behavioral health conditions who rely on Medicaid for their care. We hope our recommendations will support CMS decision-making prior to its publishing an interim final rule with detailed, binding implementation requirements by June 1, 2026.

CMS Seeks Public Comment on a New Safety and Follow-up Plan Measure

CMS on Dec. 5 published a request for public comment on a new measure for potential future inclusion in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program.
 
CMS is developing the Post-Discharge Safety and Follow-up Plan for Patients with Suicidal Ideation measure as part of a broader Behavioral Health Measures Development & Inpatient and Outpatient Measures Maintenance (BHIOMM) project.
 
NABH plans to submit public comments about the Safety and Follow-up Plan measure by CMS’ deadline of Dec. 19. Please contact Sarah Steverman with any feedback or questions.

U.S. Education Department Announces More Than $208 Million for School-Based Mental Health Services

The U.S Education Department on Thursday announced more than $208 million in new grant awards for the Mental Health Service Professional Demonstration and School-Based Mental Health programs.
 
According to the announcement, the new grants will be awarded to 65 recipients
will increase the number of credentialed school-based mental health service providers, delivering mental health services to students in high-need local educational agencies. 
 
Of the 65 new awards, 33 serve rural communities, allocating more than $120 million to rural states and school districts.

Reminder: SAMHSA to Host Webinar Dec. 17 on How Substance Use Trends Affect Child Safety

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar next week to explore how substance use trends affect child safety and family risk factors.
 
National experts will highlight insights from the National Opioid Environmental Scan, discuss the rise of fentanyl and other substances, and offer strategies to improve outcomes for families.
 
The hourlong webinar will begin at 2 p.m. ET on Wednesday, Dec. 17. Click here to register. 

Fact of the Week

A new National Alliance on Mental Illness poll found nearly 1 in 5 Americans say their mental health is poor right now, NPR reported this week. Meanwhile, nearly 2 in 3 Americans say they don’t think Congress is doing enough about mental health in America.

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

2026 Annual Meeting Schedule At-A-Glance Now Available!

This month NABH will open registration for our 2026 Annual Meeting, Future-Forward Leadership: Imagination. Innovation. Transformation, which will take place at The Ritz Carlton-Washington, DC from March 2-4, 2026.

Before then, please take a moment to review our 2026 Annual Meeting Schedule At-A-Glance, which includes times for general sessions, committee meetings, time with exhibitors and sponsors, and new breakout sessions focused on new approaches to outpatient treatment, payor issues, policy, and quality. Please note we will not host Hill Day in conjunction with the 2026 Annual Meeting.

We hope you join us, and please look for Annual Meeting updates in member alerts and upcoming issues of CEO Update!

CMS Releases CY 2026 Hospital Outpatient Prospective Payment System Final Rule

Before Thanksgiving, the Centers for Medicare & Medicaid Services (CMS) published the calendar year (CY) 2026 Hospital Outpatient Prospective Payment System (OPPS) final rule, which finalizes hospital outpatient prospective payment rates and updates Medicare payment rates for intensive outpatient program (IOP) and partial hospitalizations program (PHP) services furnished in hospital outpatient departments and Community Mental Health Centers (CMHCs).
 
For both IOP and PHP services, CMS finalized its proposal to maintain the existing rate structures and use OPPS data to calculate costs for three services per day and for four or more services per day. In addition, CMS finalized its proposal to change the methodology for calculating the CMHC IOP and PHP costs based on 40% of the final hospital-based IOP and PHP costs. This change resolves a cost inversion in CMHC cost data that would otherwise result in higher payment for three-service days than for four-service days.. The below table shows the final CY 2026 PHP and IOP per diem costs compared with the CY 2025 costs.

The final rule also includes updates to the Overall Hospital Quality Star Rating; finalizes changes to the Hospital Outpatient Quality Reporting and Rural Emergency Hospital Quality Reporting Programs; and reviews responses to a Request for Information on future measure concepts related to well-being and nutrition.

NABH Will Recommend Medicaid Community Engagement Requirements to CMS

NABH is developing recommendations to advise CMS and states about how to best implement statutory exceptions to the community engagement requirements – commonly referred to as “work requirements” – for people with mental and substance use disorders.

Passed by Congress in July, H.R. 1 exempted people with substance use disorders and disabling mental health conditions, and NABH is urging CMS to promulgate guidance and regulations that minimize disruptions in Medicaid coverage and reduce burden on providers and patients.

NABH staff held a meeting with our members this week to discuss proposed recommendations, and the NABH team is preparing a letter to CMS for NABH members to review. We expect CMS will publish preliminary guidance very soon for states seeking to implement requirements sooner than Jan. 1, 2027, the date by which H.R. 1 mandates states comply. CMS will then publish an interim final rule with detailed, binding implementation requirements by June 1, 2026.

In related news, the Kaiser Family Foundation (KFF) this week launched an interactive tool with key data and policies that will affect how states implement Medicaid community engagement requirements. KFF plans to update the tracker as CMS releases additional guidance and states begin implementation.

While NABH is focused presently on advocating for good policy with CMS, our team believes this tool will be useful for our state-based advocacy to encourage states to implement community engagement requirements that protect Medicaid access for people with mental health and substance use conditions and reduce burden for providers and patients.

Senate Democrats Introduce Plan for Healthcare Vote Next Week

Senate Minority Leader Chuck Schumer (D-N.Y.) on Thursday unveiled Democrats’ plan for a healthcare vote next week on a clean, three-year extension of the Affordable Care Act (ACA) tax credits. The Democratic bill is unlikely to garner the 60 votes needed to pass.

The ACA’s Enhanced Premium Tax Credits (EPTC) for marketplace policies expire at the end of the year, leading to significant cost increases for exchange enrollees in 2026. Senate Democrats who supported ending the government shutdown last month secured a promise from Senate Majority Leader John Thune (R-S.D.) to hold a vote on the issue next week.

Meanwhile, Senate Republicans are still considering whether to present a healthcare counterproposal to vote on next week. If such legislation is proposed, it will likely include income caps and other new restrictions.

Most GOP lawmakers in the House and Senate remain opposed to the ACA and to renewing the enhanced tax credits, which President Joe Biden and the Democratic majority created as a COVID-19 relief measure in 2021. House Speaker Mike Johnson (R-La.) has not pledged to allow a vote in the lower chamber; however, House committee chairs are working to finalize a Republican healthcare plan that could be considered next week. It would likely include various GOP bills aimed at providing more healthcare coverage options outside of the ACA. President Trump has wavered about whether to let the enhanced subsidies lapse.

Although the EPTCs are scheduled to expire Dec. 31, some Members of Congress consider the Jan. 30, 2026 expiration of the current Continuing Resolution as the next deadline for a compromise ACA bill that would be coupled with the next government funding package.

NABH will send a letter to senators and is contacting their respective offices about the ACA’s EPTCs and its effect on expanding access to behavioral healthcare.

SAMHSA to Host Webinar This Month on How Substance Use Trends Affect Child Safety

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar later this month to explore how substance use trends affect child safety and family risk factors.

National experts will highlight insights from the National Opioid Environmental Scan, discuss the rise of fentanyl and other substances, and offer strategies to improve outcomes for families.

The hourlong webinar will begin at 2 p.m. ET on Wednesday, Dec. 17. Click here to register. 

WHO Release Mental Health Report  

The World Health Organization (WHO) recently released guidance on policy and strategic actions to protect and promote mental health and well-being across government sectors.

Based on the premise that every sector – health, culture, arts, sports, defense, veterans, education, environment, and workforce – has a role to play in protecting and promoting mental health, the 236-page document is intended as practical roadmap for action.

”The cost of neglect is high,” the WHO cautions in the guidance. “It undermines individual well-being, family stability, societal cohesion, and economic performance. By contrast, investing in mental health delivers wide-ranging benefits, boosting economic productivity, strengthening communities, improving well-being, and building more equitable and resilient societies.”

Fact of the Week

A recent JAMA Network study of 373 participants found that a one-week social media detox intervention significantly reduced symptoms of anxiety by 16.1%, depression by 24.8%, and insomnia by 14.5%

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

2026 NABH Annual Meeting Update: Engage in Future-forward Leadership!

NABH is pleased to report the 2026 NABH Annual Meeting Program Committee has chosen Future-forward Leadership: Imagine. Innovate. Transform. as the theme of our next Annual Meeting at the Washington, DC-Ritz Carlton from March 2-4, 2026.
 
Our thanks to 2026 Annual Meeting Program Chair Cindy Meyer, M.S.S.W. from Rogers Behavioral Health and Program Committee Members Andrew Gerber, M.D., Ph.D., from Silver Hill Hospital and Lori Scharff, L.I.C.S.W. from Boys Town Behavioral Health Division for their constructive feedback in planning next year’s program.
 
NABH reported in last week’s CEO Update that we’re revising our Annual Meeting format in 2026 and will introduce Breakout Sessions to engage attendees during the meeting in between the General Sessions.
 
If you haven’t done so yet, please answer this one-question survey and rank the listed issue areas from your greatest priority (1) to your lowest priority (8).
 
Thank you for your time, and please read upcoming issues of CEO Update for more 2026 Annual Meeting information.

Trump Signs Spending Bill that Extends Certain Healthcare Policies Through January 2026

The longest government shutdown in U.S. history came to an end Thursday evening when President Trump signed into law a short-term spending package to fund the government through Jan. 30, 2026, and provide full-year appropriations (until Sept. 30, 2026) for the U.S. Agriculture and Veterans Affairs Departments and legislative operations.
 
The Continuing Resolution, or CR, also included several healthcare extenders but failed to extend the Affordable Care Act (ACA) subsidies that expire at the end of this year. Appropriators will need to work immediately to avert another shutdown cliff in just two months.
 
Senate Majority Leader John Thune (R-S.D.) promised to give Democrats a vote on the expiring marketplace subsidies in December. With Republicans largely against the ACA, the measure is not expected to pass in the Senate. However, negotiations are underway in the House and Senate to develop a compromise before the subsidies expire at the end of the year.
 
GOP moderates would like to see the subsidies extended at least temporarily with some additional guardrails, while GOP hardliners have sought to steer conversation away from the enhanced premium tax credits in favor of more sweeping alternative proposals that could reshape U.S. health insurance markets.
 
The CR extended major healthcare-related policies extended through Jan. 30, 2026. The new law:

• Funds community health centers.
• Resumes inpatient payments for Medicare low-volume hospitals and Medicare-dependent hospital payments.
• Delays Medicaid disproportionate share hospital payment cuts enacted under the ACA.
• Extends Medicare telehealth flexibilities through Jan. 30 and retroactively extends the flexibilities to when the programs had lapsed on Oct. 1.
• Exempts the package from statutory PAYGO (Pay-as-You-Go) and Senate PAYGO requirements to prevent Medicare sequestration cuts.
• Funds implementation of the No Suprises Act with a boost of $14 million.

The CR also includes three yearlong funding bills, collectively called a “minibus,” which fund the U.S. Agriculture Department, Legislative Branch Operations, and Military Construction/Veterans Affairs (VA). For the last of those three areas, the bill allocates $37 billion on non-VA medical care by private doctors, a record amount of funding from VA medical services to [non-VA] community care.

Trump Administration Proposes Cuts to Housing Grants; Shifts Funds to Program that Prioritizes Work Requirements and SUD Treatment

The Trump administration this week announced a shift of billions of dollars from housing aid for the nation’s homeless population to short-term programs that would impose work rules, help the police dismantle encampments, and require homeless individuals to accept treatment for mental illness or substance use disorders.
 
On Thursday, the U.S. Housing and Urban Development Department (HUD) released a 128-page notice and grant opportunity about this major change in policy that would allocate about $3.9 billion in a new Continuum of Care (CoC) Program. The program is intended to quickly rehouse homeless individuals, families, persons fleeing domestic violence, dating violence, sexual assault, and stalking, and youth while minimizing the trauma and dislocation caused by homelessness; to promote access to and effective utilization of mainstream programs by homeless individuals and families; and to optimize self-sufficiency among those experiencing homelessness.
 
The notice includes grant program criteria that seeks “management, substance use treatment, mental health treatment, and employment assistance) will ensure that the participant is able to successfully obtain self-sufficiency among those experiencing homelessness.”

Kellogg to Host Webinar on AI Adoption for Business Leaders on Friday, Nov. 21

Northwestern’s Kellogg School of Management will host a webinar titled The Insightful Leader Live: Drive Smarter Adoption with the 3 As of AI next week to help businesses avert common pitfalls and make the most of AI.
 
Kellogg experts will provide strategic solutions to help leaders audit existing workflows; identify where and when AI is most needed; and determine how it can be most effective. Panelists will also highlight three “As” of AI: Automate, which uses AI to handle repetitive tasks and improve efficiencies; Augment, which uses to AI to amplify human creativity and decision-making; and Analyze, which leverages AI to better understand and process large amounts of data to gain insight and support data-driven decision-making.
 
The webinar begins at 1 p.m. ET on Friday, Nov. 21. Click here to register.

Please Submit Your Updates for NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent. Thank you for your time.

Fact of the Week

A new study published in JAMA study found that 13% of surveyed youth between the 12-21 years old said they used generative AI for mental health advice.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Wants to Hear from You: Please Rank the 2026 Annual Meeting Breakout Session Topics!

NABH is revising its Annual Meeting format in 2026 and will introduce Breakout Sessions to engage attendees during the meeting in between the General Sessions.
 
Please take a moment to answer this one-question survey and rank the listed issue areas from your greatest priority (1) to your lowest priority (8).
 
Thank you for your time, and please read upcoming issues of CEO Update for more 2026 Annual Meeting information.

CMS Incorporates NABH Recommendations in the Final 2026 Physician Fee Schedule Rule

NABH is pleased to report the Centers for Medicare & Medicaid Services (CMS) incorporated some of the association’s recommendations in the final calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) rule the agency released on Oct. 31. 

In our comments to CMS on the proposed rule, NABH supported adding the three new HCPCS G-codes to incentivize and compensate for collaborative care for behavioral health conditions for Advanced Primary Care Management (APCM) services. CMS finalized the three new codes, expanding coverage to address comorbid physical health conditions that are common among people with behavioral health conditions.

NABH is also pleased that CMS finalized coverage for digital mental health treatment (DMHT) devices used in the treatment of Attention-Deficit/Hyperactivity Disorder. Presently, CMS covers DMHT devises that have received U.S. Food and Drug Administration (FDA) clearance, approval, or authorization. In the proposed rule, we expressed concerns with CMS expanding coverage for digital tools that have not been subjected to FDA oversight. In the final rule, CMS did not establish coding for a broader set of digital tools intended as complements to mental health treatment but will consider doing so in future rulemaking.

CMS finalized its proposed policy to include marriage and family therapists (MFTs) and mental health counselors (MHCs) as practitioners who can bill Medicare directly for Community Health Integration services (HCPCS codes G0019 and G0022), Principal Illness Navigation services (HCPCS codes G0023 and G0024), and Principal Illness Navigation – Peer Support (HCPCS code G0146).

NABH also supported CMS’ proposal to extend or make permanent certain telehealth flexibilities, including permanently removing frequency limitations for subsequent inpatient visits. CMS finalized that proposal, as well as a proposal to adopt permanently a definition of direct supervision to include virtual presence via appropriate audio/video real-time communication technology.

Finally, NABH urged CMS to consider extending the waiver allowing providers to report practice addresses instead of home addresses when they perform telehealth services from their home. We are disappointed CMS did not address this issue in the final rule.

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

Center for Connected Health Policy Releases 2025 State Telehealth Policy Summary

The Center for Connected Health Policy (CCHP) recently released its 2025 State Telehealth Policy Summary.
 
The Fall 2025 Summary Report includes state telehealth laws and Medicaid program policies and links to an updated online Policy Finder tool. The report provides a national overview of state telehealth policy and the Policy Finder offers state-specific information for the 50 states, District of Columbia, Puerto Rico, and the Virgin Islands.
 
The report includes laws, regulations, and policy documents on an array of telehealth topics, including Medicaid and Medicare reimbursement, private payer laws, professional requirements, and federally qualified health centers (FQHCs). 

AAPC to Host Webinar on Improving Accuracy & Documentation in Behavioral Health Claims

Experts from firm AAPC – the nation’s largest education and credentialing organization for medical coders, billers, auditors, practice managers, documentation specialists, compliance officers, and revenue cycle managers – will host a webinar next week to share insights into how credentialed professionals can navigate behavioral health compliance challenges.

The webinar will help attendees learn how to recognize documentation and coding pitfalls, prevent payor denials through staff credentialing and structured training, strengthen audit readiness, and more.

Click here to register for the webinar on Tuesday, Nov. 11 at 1 p.m. ET.
 
Please Submit Your Updates for NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent. Thank you for your time.

Fact of the Week
North Carolina Gov. Josh Stein (D) signed a law this past summer requiring the North Carolina Department of Health and Human Services to suspend, rather than terminate, Medicaid coverage for people entering jails, bringing the state in line with federal requirements that become effective on Jan. 1, 2026. This distinction is notable because Medicaid generally does not pay for health care provided in state and local prisons and jails. Learn more here from a Pew report about the issue.

Many Thanks to All Veterans!

As Veterans Day approaches, NABH thanks its members and their families who have served or are serving in the U.S. military. We appreciate your sacrifice and service.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

American Foundation for Suicide Prevention Launches New Collection of Resources

The American Foundation for Suicide Prevention (AFSP) recently launched The Upright, a collection of research, program, and policy resources that aim to advance health equity in suicide prevention. The resources are meant to support localities, organizations, and individuals wishing to develop suicide prevention strategies in underserved communities.
 
As part of the launch, AFSP will host The Summit, three virtual events featuring local and national experts who have supported suicide-prevention strategy implementation. The events will highlight community-based programs that have shown measurable impact on suicide outcomes.

AFSP will host the first of the three events on Tuesday, Oct. 28, from 2– 4:15 p.m. ET. The event will feature suicide prevention experts with experience embedding health equity into suicide-prevention efforts.

CMS Instructs Medicare Administrative Contractors to Lift Claims Holds

The Centers for Medicare & Medicaid Services on Oct. 21 provided updated guidance that instructs all Medicare Administrative Contractors (MACs) to lift the claims hold CMS announced at the start of the government shutdown and process claims with dates of service of Oct. 1, 2025, including claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, Federally Qualified Health Center (FQHC) claims, and telehealth mental health services claims.
 
Specifically, the new guidance instructs MACs to lift the claims hold for “telehealth claims that CMS can confirm are definitively for behavioral and mental health services.” CMS directed MACs to continue to hold claims for other non-behavioral health telehealth services and for acute Hospital Care at Home claims.

This latest guidance follows the agency’s Oct. 15 guidance on new in-person visit requirements, which requires all new Medicare patients receiving mental health treatment via telehealth to have received an in-person visit within the past six months and every 12 months after the initial telehealth visit. As reported in last week’s edition of CEO Update, CMS clarified that established telehealth patients do not need to have had an in-person visit within six months and only must receive an in-person visit in the next 12 months to continue mental health treatment via telehealth.

NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.
 
Thank you for your time and all you do to advance NABH’s Vision and Mission!

Fact of the Week

A new ballot initiative in California – the California Kids AI Safety Act – would restrict kids’ access to AI chatbots without safety guardrails, establish statutory damages for AI harms, and limit the sale of minors’ data and require third-party audits of AI tools, Politico reported this week.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Please Help Us Identify New NABH Board Members by Monday, Oct. 20

As the NABH Selection Committee prepares to consider possible nominees, please help us identify potential candidates for: 

     ► Board Chair-Elect and
     ► One Board seat that will open in 2026

The Selection Committee is interested particularly in identifying senior managers who represent the broad diversity of NABH’s membership, including various levels of care, organizational structures, and size.   

Please download a nomination form to recommend individuals you would like to see included in the single slate for 2026. Please attach a curriculum vitae (CV) for each person you recommend. This will help the Selection Committee in its deliberations. You are welcome to suggest yourself. 

Please return this form (and candidates’ CVs) by Monday, Oct. 20, 2025, to maria@nabh.org.

Thank you for your time and recommendations!

CMS Releases Additional Guidance on Medicare Telehealth Services

In guidance released Oct. 15, the Centers for Medicaid & Medicaid Services (CMS) said effective as of Oct. 1, Medicare patients initiating mental health treatment via telehealth must have an in-person visit within the previous six months and every 12 months after the initial telehealth visit.

The agency’s latest guidance also noted “… if a beneficiary began receiving mental health services on or before Sept. 30, 2025, then they would not be required to have an in-person visit within 6 months; rather, they will be considered established and will instead be required to have at least one in-person visit every 12 months.”

NABH and partners are urging Congress to continue the Covid-19 pandemic’s flexibilities and retroactively allow telehealth visits for new patients without an in-person visit. Without congressional action, providers who initiate mental health services via telehealth to new patients without an in-person visit may not be reimbursed for the service. CMS recommends providers who perform telehealth services and are unsure if they will be reimbursed should provide beneficiaries with an Advance Beneficiary Notice of Noncoverage, or ABN.

This policy change does not affect telehealth services for substance use or co-occurring treatment, which do not require initial and annual in-person visits. CMS instructed all Medicare Administrative Contractors to continue temporarily holding claims for services provided after Sept. 30, including claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center claims. This policy change does not affect Medicaid, commercial, PHP/IOP, or IPF claims.

Federal Agency Reductions in Force Draw Scrutiny from Lawmakers as Government Shutdown Enters Week #4

Friday, Oct. 17 marks Day #17 of the federal government shutdown and there’s no resolution in sight to break the impasse.

Senate Majority Leader John Thune (R-S.D.) continues to force Senate lawmakers to vote on the House-passed Continuing Resolution that would fund government operations through Nov. 21. However, Democrats remain firm in resisting the measure and demanding a vote to extend the Affordable Care Act’s tax credits before they support legislation to fund the government.

As the shutdown continues, the Trump administration has initiated reductions in force (RIF) across numerous federal agencies, including HHS and the Substance Abuse and Mental Health Services Administration (SAMHSA), which has raised concerns from lawmakers.

Meanwhile, Democratic Reps. Paul Tonko (D-N.Y.), Don Beyer (D-Va.), Madeleine Dean (D-Pa.), Lori Trahan (D-Mass.), Brittany Pettersen (D-Colo.), and Andrea Salinas (D-Ore.) – all mental health and substance use disorder treatment champions – this week urged HHS to immediately reinstate fired SAMHSA staff and provide information about the effects of the departmental reorganization and RIF on the agency’s operations,

In their letter to HHS Secretary Robert F. Kennedy, Jr., the lawmakers wrote these actions — which have reduced SAMHSA’s staff by more than half since the start of the Trump administration — run contrary to bipartisan congressional intent and undermine the nation’s response to its mental health and substance use disorder crises. These lawmakers each serve as leaders in either the Addiction, Treatment, and Recovery (ATR) Caucus, the Bipartisan Mental Health and Substance Use Disorder Task Force, or the Mental Health Caucus.

NABH will continue to keep members informed as we learn new developments regarding government funding and agency staffing and services. Please contact Andy Dodson if you have questions or face challenges related to federal programs and services.  

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.

Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.

To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.

Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.

Thank you for your time and all you do to advance NABH’s Vision and Mission!

Attention All ‘Unit’  Committee Members: Register Today for NABH’s Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

A new JAMA Psychiatrystudy that examined the efficacy of heart rate variability biofeedback, or HRVB, in treating 115 adults with SUD found that those who received HRVB experienced significant reductions in negative affect, craving, and alcohol and other drug use relative to controls. The findings suggest that HRVB practice may disrupt moment-level associations between craving and substance use, highlighting its potential as an adjunctive SUD treatment.

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

Please Help Us Identify New NABH Board Members

As the NABH Selection Committee prepares to consider possible nominees, please help us identify potential candidates for: 

     ► Board Chair-Elect and
     ► One Board seat that will open in 2026
 
The Selection Committee is interested particularly in identifying senior managers who represent the broad diversity of NABH’s membership, including various levels of care, organizational structures, and size.   
 
Please download a nomination form to recommend individuals you would like to see included in the single slate for 2026. Please attach a curriculum vitae (CV) for each person you recommend. This will help the Selection Committee in its deliberations. You are welcome to suggest yourself. 

Please return this form (and candidates’ CVs) by Monday, Oct. 20, 2025, to maria@nabh.org.

Thank you for your time and recommendations!

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
The original deadline for changes was Oct. 3; however, the NABH team is glad to receive this information at any time because it is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.
 
Thank you for your time and all you do to advance NABH’s Vision and Mission!

Uncertainty Remains After Oct. 1 Telehealth Changes Arrive

NABH and its members are looking to CMS for additional guidance after the agency’s telehealth requirements became effective on Oct. 1.
 
For the last several years, Congress extended telehealth policies set to expire on Sept. 30 to allow continued Medicare reimbursement for telehealth services that were not allowed before the Covid-19 public health emergency (PHE).

That changed on Oct. 1 after Congress failed to extend those telehealth flexibilities and CMS furloughed staff during the federal government shutdown, leaving providers confused about what they should bill Medicare for and how.

Thanks to previous congressional action, mental health and substance use services delivered through telehealth services continue to be covered in many cases. For instance, substance use services and services provided for co-occurring mental health and substance use conditions may be delivered via telehealth, regardless of a patient’s geographic location or originating site (i.e., physical location, such as a person’s home).

As of Oct. 1, 2025, CMS requires that if patients receive a mental health telehealth visit, they must have had an in-person visit within the past 6 months (and every 12 months after the initial telehealth visit). When this requirement was imminent at the end of the PHE on May 11, 2023 (before Congress acted to extend flexibilities), CMS said it would waive the requirement for established patients to have received an in-person visit within the past 6 months, requiring only an annual in-person visit thereafter (this requirement was also delayed through Sept. 30, 2025).

Presently, without further guidance, providers cannot be certain if CMS will grandfather established patients and only require an in-person visit within the preceding 6 months for new telehealth patients.

Meanwhile, for new and established patients receiving mental health services via telehealth, CMS allows the required in-person service to be administered by a colleague in the same sub-specialty within the same group practice if the original practitioner is unavailable. In addition, patients and providers may agree to waive the in-person visit if the “risks and burdens of travel outweigh the benefits of an in-person encounter,” according to CMS. If the patient and provider waive the in-person visit, the practitioner must document the reason for this decision in the patient’s medical record.

NABH had hoped CMS would provide information about this policy change; however, since the government shutdown began, CMS has not released additional guidance. As a reminder, this policy change only affects Medicare mental telehealth visits billed to the Physician Fee Schedule and does not impact Medicaid, commercial, PHP/IOP, IPF, or substance use services.
The Center for Connected Health Policy released an FAQ Resource Document to address complex questions Medicare providers may have.

NABH urges members to consult their billing and legal experts to determine their approach to the uncertainty, and we will keep members apprised of any new information we learn.

HHS OIG Recommends Changing Medicare OTP Funding Methodology to Lower Expenditures

A report from the U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) this week showed if the Medicare program’s Opioid Treatment Program (OTP) bundled payment methodology had better reflected the frequency of services delivered, the program could have saved Medicare $301.5 million (53% of total payments to OTPs) between Jan. 1, 2020 and Sept. 30, 2022.
 
The HHS OIG provided several recommendations to the Centers for Medicare & Medicaid Services (CMS), including that the agency should: 1) consider revising its methodology for the non-drug component of the bundle, 2) consider developing additional HCPCS codes for bundles based on the types and frequency of services provided, and 3) perform monitoring activities to ensure that Medicare only pays when OTPs have properly documented treatment services in patients’ treatment plans.
 
CMS has implemented the first recommendation and indicated it will consider revisions to the bundled payment methodology each year during the rulemaking process. Meanwhile, CMS did not concur with the second or third recommendations. For recommendation #2, CMS said the recommendation is outside the scope of CMS’ statutory authority; and for #3, CMS said it does not require treatment plans as a condition of payment.

Digital Medicine Society Releases Blueprint for Implementing AI in Healthcare

The Digital Medicine Society has released The Playbook, a guide to implementing AI that the organization says is meant to help providers navigate the complexities of AI into clinical care and deliver better outcomes for patients.
 
The new resource guides users through three, interconnected sections: 1) Identify the Problem and Assess Your Readiness, 2) Source, Evaluate, and Choose the Right AI Tool, and 3) Implement AI Across Your System.
 
In related news, the U.S. Food and Drug Administration (FDA) announced last month it will convene an advisory committee on AI and mental health devices. Reuters reported in September that the FDA Digital Health Advisory Committee expected to meet on Nov. 6 to examine how these digital tools could help address a widening gap in access to mental health services in the United States, while also exploring the unique risks they pose.

Attention All NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

A recent survey from the International Academies of Emergency Dispatch found most mental health crisis calls in the United States still go to 911, not 988: the findings showed that in 2023, Emergency Crisis Centers (ECCs) across the United States received at least 24 million calls involving a mental health crisis, compared with the 17 million calls, texts, and chats the 988 Suicide & Crisis Lifeline received since its launch in 2022.

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

Shawn Coughlin Retires; Previous NABH President and CEO Mark Covall Named Interim Leader

Shawn Coughlin retired as NABH’s president and CEO this week after nearly six years in the position. The NABH Executive Committee named Mark Covall as interim president and CEO as it engages an executive search firm to find Coughlin’s successor.
 
Coughlin served previously as the association’s executive vice president of government relations and policy from 2017 until he began his role as president and CEO in January 2020. In all, he has spent 14 years working directly for or with NABH as a leader or consultant.
 
“It has been an honor to lead the preeminent behavioral healthcare association in the country,” Coughlin said in a statement NABH released this week. “Having started my leadership role with the association during the opioid crisis and guiding it through the Covid-19 pandemic, it is time for me to turn my attentions to other opportunities.”
 
Covall retired from NABH in December 2019 after more than 35 years with the association and 24 years as its president and CEO. He began his interim role on Oct. 1.
 
“On behalf of the NABH Board of Trustees, we thank Shawn for his years of service to our association,” NABH Board Chair Jim Shaheen said in the statement. “His passion for lobbying has helped guide our members through some critical times and several legislative and regulatory changes,” he continued. “We all wish Shawn continued success.”

No Major Changes Expected for Behavioral Healthcare Providers as Government Shutdown Continues

The federal government is ending week one of its shutdown and there appears to be no end in sight as negotiations continue.
 
NABH does not expect legislative or regulatory changes that would affect behavioral healthcare providers’ work during the shutdown. Meanwhile, the NABH Government Relations team continues to contact congressional offices about extending the expiring enhanced Affordable Care Act (ACA) tax credits, eliminating cuts to the Medicaid Disproportionate Share Hospital (DSH) payments, and extending Medicare’s telehealth flexibilities. 
 
The shutdown officially began Wednesday, Oct. 1 at 12:01 a.m. ET after senators rejected competing Democratic and Republican bills to keep the government open. Previously, House lawmakers passed a continuing resolution (CR) that would have funded the government until Nov. 21 and contained several healthcare extenders. In the Senate, lawmakers needed seven Democratic votes to meet a 60-vote threshold for the measure to pass. That didn’t happen after Democrats demanded extending ACA credits and repealing H.R. 1 health policies in exchange for their votes, which the Senate rejected.
 
In addition to lapsed federal funding, the legal authority allowing Medicare to provide reimbursement for some non-behavioral health telehealth services delivered to patients in their home also lapsed, as well as the Oct. 1 deadline that marks the start of cuts to Medicaid DSH funding. In the past, federal lawmakers reauthorized these programs retroactively after the shutdown ended; however, this practice creates uncertainty in the interim.

In guidance this week, CMS directed all Medicare Administrative Contractors to implement a temporary claims hold. “The hold prevents the need for reprocessing large volumes of claims if Congress acts after the statutory expiration date and should have minimal impact on providers due to the 14-day payment floor,” the guidance noted. Providers may continue to submit claims; however, payment will not be released until the hold is lifted. NABH continues to analyze the guidance and will keep members apprised when we have more information.

Senate Majority Leader John Thune (R-S.D.) this week continued to bring the House CR to a vote on the Senate floor. Although the measure failed repeatedly, several additional Democratic senators supported passing legislation.
 
Meanwhile, a bipartisan group of senators is working on a deal that would extend ACA credits while simultaneously reducing costs and fraud in federal healthcare programs to reach a compromise. Other lawmakers have proposed extending the subsidies for one year and follow that with a one-year phasedown as a way to return the tax credits to pre-pandemic levels.
 
Within the federal agencies, HHS has said it has the necessary staff to execute mandatory activities. The shutdown leaves the Centers for Medicare & Medicaid Services (CMS) with only 53% of its workforce, according to HHS’ recently published 2026 contingency plan. The Medicare program will still cover claims during the shutdown; however, the contingency plan notes that enrollment education and outreach will slow down, which would happen just weeks before the Medicare annual enrollment period kicks off.
 
NABH has learned the Veteran Affairs Department (VA) has not been affected as other federal agencies have because Congress has already provided appropriations for this agency. The VA will continue to process benefits checks, and medical appointments at VA health centers will not be disrupted. However, the VA is closing several support phone services and regional VA benefits offices temporarily during the shutdown.
 
As NABH noted to members earlier this week, we will continue to keep you informed as we learn new developments. Please contact Andy Dodson if you have questions or face challenges related to federal programs and services.  

States Advance Applications for the Rural Health Transformation Program

CMS held a webinar on Tuesday, Sept. 30 to provide states and relevant stakeholders with guidance about the Rural Health Transformation (RHT) Program as all federal offices faced a looming government shutdown at 11:59 p.m. ET that day. 
 
CMS staff said 27 states had submitted optional letters of intent as of Tuesday morning.
 
The agency said it intends for the RHT Program to provide funding to states and their subrecipient organizations for infrastructure, including investing in workforce, updating technology, and other innovations. States may only use 15% of grant funds for services and those funds cannot be used to supplant current funded services.
 
CMS said it will allow only up to 5% of total funding to be used to replace an electronic medical record (EMR) system if a previous HITECH-certified EMR system was in place as of Sept. 1, 2025. CMS told attendees they plan to release additional guidance on the program’s funding limitations.
 
Applications are due Nov. 5, 2025 and CMS plans to send funding announcements to states by Dec. 31, 2025.
 
CMS has deemed RHT Program staff essential employees during the government shutdown, so they will continue to provide additional guidance and technical assistance to state applicants. To stay up-to-date on the RHT Program, sign up for email updates from CMS.

Mental Health America Releases 2025 Report on Mental Health and Well-Being in the United States

Advocacy group Mental Health America (MHA) this week released The State of Mental Health in America 2025 that highlights the latest national data and provides state-level rankings on mental health and well-being in the United States.
 
MHA uses national survey data to measure a community’s mental health needs, access to care, and outcomes, regardless of the differences among states and their varied mental health policies.
 
According to the report, nearly 3 million American youth ages 12-17 have frequent thoughts of suicide and 77% of U.S. adults with substance use disorder did not receive treatment.
 
The report also included some hopeful news, as survey data showed the percentage of youth ages 12-17 who experienced a major depressive episode decreased to 15.4% in 2024 from 18.1% in 2023, while the percentage of youth ages 12-1 who reported serious thoughts of suicide in the past year decreased to 10.1% in 2024 from 12.30% of youth in 2023.
 
The 45-page report provides a comprehensive summary of key findings, state rankings, mental health prevalence among adults and youth, access to care for all ages, and mental health workforce availability.

Attention All NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

New York, Hawaii, and New Jersey (in that order) scored the best across 17 measures of prevalence of mental illness and access to mental health care, according to MHA’s 2025 report on the state of mental health and well-being in America.

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

Reminder: Please Submit Your System’s Information for the NABH 2025 Membership Directory Updates by Next Friday, Oct. 3

NABH is compiling information for its 2025 Membership Directory, which we will publish online only. To help ensure we have the most accurate member information, please use the link to our membership update tool that NABH sent to all system members earlier this month and verify your system’s information.
 
Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership. The answers to these questions will help us provide a more accurate description of our members to policymakers, regulators, partner organizations, and the media.
 
The deadline to submit your changes to NABH is next Friday, Oct. 3.  If you need assistance or the link to be resent, please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104.

NABH & Partner Groups Urge Congressional Leaders to Extend Telehealth Flexibilities and Enhanced Premium Healthcare Tax Credits

NABH and our partners in the Mental Health Liaison Group (MHLG) this week urged House and Senate leaders to establish a two-year or permanent extension of Medicare telehealth services flexibilities and pass an extension of enhanced premium healthcare tax credits.
 
To learn more, please read the MHLG’s telehealth letter and the organization’s tax credits extension letter.

HHS-OIG Urges CMS to Help States Better Ensure Children at Risk of Suicide Receive Timely Follow-Up Care

A new report from the HHS Office of Inspector General (OIG) recommended the Centers for Medicare & Medicaid Services (CMS) should assist low-performing states to better ensure children at risk of suicide receive timely follow-up care.
 
The report showed that in half of cases of hospitalization or emergency department (ED) visits for suicidal thoughts or behaviors, children enrolled in Medicaid did not receive a follow-up visit in the week after their discharge—a critical time for intervention.
 
When children did receive follow-up visits, researchers found, most visits occurred with behavioral health providers such as counselors, social workers, and psychiatrists.
 
“Subject matter experts whom OIG interviewed attributed the lack of timely follow-up visits to provider shortages and difficulties connecting children to care,” the report noted. “The experts also shared that brief interventions from any type of provider could support children while they await more comprehensive care from a behavioral health professional (e.g., telephone contacts and safety planning).”

The report also noted suicide is the second leading cause of death for children in the United States. In 2023, nearly 225,000 children aged 10–17 who were enrolled in Medicaid were hospitalized or visited the ED for suicidal thoughts or behaviors.
 
“OIG interviewed experts who told us that a follow-up visit should occur anywhere from 24 hours to 1 week after a child’s discharge from the hospital or ED,” the report said.

Kaiser Family Foundation Report Examines CMS’ Rural Health Fund Announcement

A new report from the Kaiser Family Foundation (KFF) highlights five essential points from CMS’ recent rural health Notice of Funding Opportunity (NOFO).
 
KFF’s analysis notes CMS will distribute $25 billion equally across states with approved applications and the remaining $25 billion based on numerous factors, some more data-driven than others; states will receive more funds if they adopt Make America Healthy Again policies; while the $50 billion fund could help rural communities in a number of ways, the extent to which it will benefit rural hospitals and offset their losses under the reconciliation law is unclear; it remains unclear which states and rural hospitals will benefit the most; and it is unclear how transparent CMS and states will be about the distribution and oversight of the fund, such as by disclosing the flow of dollars to specific hospitals and other entities.
 
“While the NOFO includes many new details about how the funds will be distributed across states,” the KFF report noted, “questions remain about which states will receive funding, the final distribution across approved states, and how well this distribution will align with various definitions of need.”

Fact of the Week

A new JAMA study suggests expanding access to behavioral healthcare may be a financially viable cost-reduction strategy for healthcare buyers.

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

House Passes Short-Term Funding Bill

The House passed a continuing resolution on Friday to fund the federal government through Nov. 21, which would give Congress more time to develop a full-year funding package.
 
The bill now heads to the Senate, where it needs 60 votes to pass, necessitating some Democratic votes in support. Congress must pass the bill by the end of September to avoid a government shutdown.
 
The bill also includes several healthcare extenders, including delaying the expiration date for Medicare telehealth flexibilities and preventing cuts to the Disproportionate Share Hospital (DSH) program, which helps hospitals cover the cost of treating patients who are uninsured or underinsured. This comes amidst growing Congressional concern about the significant potential harms of DSH cuts, with a bipartisan group of 141 Representatives sending a letter to House leadership this week urging that current funding be maintained.
 
However, the bill does not extend the enhanced premium tax credit (EPTC) that improves the affordability of Marketplace plans.

Senate Passes SUPPORT Act Reauthorization

On Thursday, the Senate passed the SUPPORT for Patients and Communities Reauthorization Act of 2025, which reauthorizes billions of dollars in funding to address overdoses, substance use disorders, and mental disorders.
 
A variety of programs are reauthorized through fiscal year 2030, such as grants to address substance use disorders among pregnant and postpartum women, grants to promote housing for individuals in recovery from substance use disorders, and a loan repayment program for certain health care providers treating substance use disorders.
 
Additionally, the bill establishes new requirements for the U.S. Department of Health and Human Services, including establishing a Federal Interagency Work Group on Fentanyl Contamination of Illegal Drugs, and conducting a review of the scheduling of buprenorphine/naloxone combination products under the Controlled Substances Act.
 
The Act previously passed the House on June 4, 2025. With Senate passage, the bill now goes to the President for his signature.

CMS Finalizes New Provide Directory Requirements for Medicare Advantage Organizations

The Centers for Medicare & Medicaid Services (CMS) this week finalized a new rule that will require Medicare Advantage (MA) organizations to submit data on their provider directories, which will be published online as part of the Medicare Plan Finder tool.
 
In addition to providing the data to CMS, MA organizations will need to update their provider directory data within 30 days of discovering any changes, as well as attest to CMS at least annually that the information submitted is accurate.
 
The final rule will be applicable beginning Jan. 1, 2026.

Please Submit Changes for the NABH 2025 Membership Directory by Friday, Oct. 3

NABH is compiling information for its 2025 Membership Directory, which we will publish online only. To help ensure we have the most accurate information on our members, please use the link to our membership update tool that was sent earlier this week to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
The answers to these questions will help us provide a more accurate description of our members to policymakers, regulators, partner organizations, and the media.
 
The deadline to submit your changes to NABH is Friday, Oct. 3.  If you need assistance or the link to be resent, please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104.
 
As always, thank you for your time and for all you do to provide quality behavioral healthcare to those who need it most.

CBO Estimates $350 Billion Cost to Permanently Extend EPTC

This week, the Congressional Budget Office (CBO) released a new estimate of the effects of permanently extending the EPTC – a credit that reduces the premiums of Marketplace plans – which is scheduled to expire at the end of calendar year 2025 after first being introduced in 2021.
 
CBO estimates that permanent extension would increase the federal deficit by $350 billion through 2035, and by that year, 3.8 million more people would have health insurance than if the EPTC reverts to its original structure. They also estimate that benchmark plan premiums would be 7.6% lower (not factoring in the tax credit), given that healthier individuals would be more likely to enroll with the EPTC.
 
The original premium tax credit was limited to individuals with incomes between 100-400% of the federal poverty level, while the EPTC eliminated the maximum income threshold for eligibility.

Senate Confirms EBSA Nominee

The Senate on Thursday confirmed Daniel Aronowitz to lead the Employee Benefits Security Administration (EBSA) in the U.S. Department of Labor.
 
Previously, Mr. Aronowitz served as the President of Encore Fiduciary, a fiduciary liability underwriting company.
 
EBSA is the primary federal regulator overseeing employee benefits, including most employer-sponsored health plans. Notably, EBSA is one of three agencies – alongside CMS and the Internal Revenue Service – tasked with implementing the Mental Health Parity and Addiction Equity Act.

CMS Releases Rural Health Transformation Program Funding Opportunity

On Monday, CMS released the Notice of Funding Opportunity (NOFO) for the Rural Health Transformation (RHT) Program. Congress appropriated $50 billion for the RHT Program in H.R. 1, which will be available to states for five fiscal years.
 
CMS will issue cooperative agreements to states with approved applications. States must involve rural stakeholders – which could include NABH members with facilities in rural areas – throughout the application and implementation phases. CMS also requires states to identify the organizations intended to receive RHT funding within their applications. Therefore, NABH encourages all members to review the NOFO and work with their states to support their RHT Program application.

CMS will host two webinars for program applicants and interested stakeholders:

• Friday, Sept. 19 from 3 – 4:30 p.m. ET; register here.
• Thursday, Sept. 25 from 3 – 4:30 ET; register here.

States must submit applications by Nov. 5, 2025. CMS will only have one funding opportunity for this program and will announce awardees by Dec. 31, 2025.

Joint Commission and Coalition for Health AI Issue Guidance for Responsible Use of AI

Joint Commission and the Coalition for Health AI (CHAI) on Wednesday issued guidance on artificial intelligence (AI) use in healthcare, which is intended to “serve as internal governance to help U.S. health systems safely and effectively implement [AI] at scale.”
 
The guidance includes high-level recommendations for responsible use of AI across seven elements: AI Policies and Governance Structures, Patient Privacy and Transparency, Data Security and Data Use Protections, Ongoing Quality Monitoring, Voluntary, Blinded Reporting of AI Safety Related Events, Risk and Bias Assessment, and Education and Training.
 
From these high-level recommendations, Joint Commission and CHAI will develop a series of playbooks to include baseline controls, examples, and challenges to each element. The organizations are soliciting feedback on the initial document and will incorporate community feedback and examples into updates of this guidance and the Playbooks, which they say will be released later this year and into 2026.
 
If any NABH members have feedback on the newly released guidance or how AI is or could be used in their organizations, please contact Emily Wilkins, NABH’s director of government relations (emily@nabh.org).

GAO Releases Report on Administrative Spending for Georgia’s Medicaid Work Requirements

The Government Accountability Office (GAO) released a report this week examining the administrative processes and costs to implement work requirements in Georgia’s Medicaid program.
 
In 2020, CMS approved Georgia’s Medicaid section 1115 demonstration request to expand coverage to adults aged 19-64 contingent on them reporting 80 hours of work or educational activities each month. To implement the demonstration, Georgia needed to make several changes to their administrative eligibility and enrollment systems, conduct specialized outreach efforts, and undertake other administrative tasks prior to opening enrollment in 2023.
 
In the first 4.5 years of the program, Georgia reported spending $80.3 million total, of which $54.2 million were administrative costs. The federal government funded 88% ($47.4 million) of the administrative costs, which GAO warns may have exceeded the allowable match rate. In addition to the high administrative costs to the federal government, GAO found weaknesses in CMS’ oversight of that spending.
 
This report helps shed light on the processes and costs associated with Medicaid work requirements, which is especially important as states begin implementing work requirements and other changes to Medicaid included in H.R. 1.

Fact of the Week

A new study found that individuals with opioid use disorder who received medication during incarceration were more likely to continue treatment six months post-release than those who did not. Medication receipt was also associated with substantial reductions in adverse risks: 52% for fatal opioid overdose, 24% for nonfatal opioid overdose, 56% for all-cause mortality, and 12% for reincarceration.

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

Congress Faces Host of Decisions as Federal Funding Deadline Looms

Congress returned from its August recess last week to a fall agenda that requires lawmakers to
decide on how it will fund the federal government and extend critical healthcare programs.
 
The House has 10 legislative days, and the Senate has 12 legislative days to determine how to fund federal government operations before the Sept. 30 deadline.  
 
Multiple factions within Congress have advocated different funding approaches. The White House this week suggested Congress delay the upcoming government shutdown deadline to Jan. 31, creating a four-month extension that Democrats and many Republican lawmakers oppose.
 
The proposal would couple a funding extension of federal health insurance subsidies set to expire on Jan. 1 with government funding through September 2026. As congressional Republicans continue to manage messaging about pending Medicaid changes included in this summer’s H.R. 1, One Big Beautiful Bill Act (OBBBA), the threat of surging costs for those families who purchase their insurance through the exchanges is becoming clearer. Unless Congress acts, premiums will spike for both subsidized and unsubsidized enrollees. If the enhanced tax credits expire, an estimated 4 million people could stop receiving coverage through the Marketplace by 2026.
 
Meanwhile, Democrats and Republicans alike are paying close attention to pending Medicaid Disproportionate Share Hospital (DSH) cuts, which could be addressed as part of a government funding extension. DSH payments help compensate hospitals that deliver care to a high volume of uninsured individuals and Medicaid beneficiaries, as Medicaid reimbursement is typically well below the actual cost of behavioral healthcare. Medicaid DSH cuts are scheduled to take effect on Oct.1, 2025, unless Congress acts. If this occurs, many behavioral healthcare providers will be forced to reduce services, limit availability of inpatient treatment, or close their doors.
 
NABH sent an Action Alert to members asking them to urge their lawmakers to act by Sept. 30 to avert the DSH cuts before the Oct.1 deadline and also act by Sept. 30 to extend the enhanced tax credits.
 
We also joined our coalition partners in asking our members to urge their representatives to sign a congressional letter to House leaders imploring them to prevent the DSH cuts. NABH sent this Action Alert Thursday and hopes to have several new representatives sign the letter by next week’s Tuesday, Sept. 16 deadline. As of Sept. 11, more than 60 representatives signed the letter to House Speaker Mike Johnson (R-La.) and House Minority Leader Hakeem Jeffries (D-N.Y.).
 
Numerous other healthcare programs are set to expire at the end of September, including extending telehealth authority and reauthorization of the SUPPORT Act. Last week, Rep. Buddy Carter (R-Ga.) and Rep. Debbie Dingell (D-Mich.) introduced H.R. 5081, the Telehealth Modernization Act, bipartisan legislation to establish permanency for telehealth access. NABH continues to push for telehealth permanency and advocates for H.R. 4619, the Medicare Mental Health Inpatient Equity Act, which would eliminate Medicare’s 190-day lifetime limit for inpatient psychiatric hospital services.
 
Meanwhile, Congress’ regular appropriations process continues as congressional leaders address a stop-gap funding measure. A $108 billion funding bill for the U.S. Health and Human Services Department advanced in the House Appropriations Committee by a 35-28 party-line vote on Sept. 10. The bill cuts the agency by 6%, more than $25 billion shy of the reduction President Trump requested.
 
The Trump administration requested more than $20 billion for the Administration for a Healthy America, a proposed unit that would consolidate several HHS agencies, which the bill does not fund. The full Senate Appropriations Committee passed a $116 billion HHS bill in July, which includes a $446 million increase in discretionary funds compared with the current fiscal year. Both the House HHS bill and the Senate HHS bill now await floor votes in both chambers and a Conference Committee to resolve any differences.

NABH Sends Comments to CMS on Agency’s 2026 Physician Fee Schedule Proposed Rule

NABH on Sept. 11 sent a letter to the Centers for Medicare & Medicaid Services (CMS) supporting several policy proposals affecting behavioral healthcare providers that the agency included in its 2026 Physician Fee Schedule rule.
 
In our letter to CMS Administrator Mehmet Oz, M.D., NABH applauded efforts to promote primary and behavioral healthcare integration among Advanced Primary Care Management (APCM) services. While we support CMS’ clarification that Digital Mental Health Treatment (DMHT) codes finalized in CY 2025 can be used for ADHD treatments and all FDA-cleared tools, we noted concern about establishing coding and payment for a broader set of services using digital tools that do not require FDA regulatory oversight.

We also supported the rule’s proposal to include marriage and family therapists and mental health counselors as practitioners who can bill Medicare directly for Community Health Integration and Principal Illness Navigation services.

Finally, NABH expressed support for CMS’ proposal to make permanent certain telehealth flexibilities, including removing frequency limitations for subsequent inpatient visits and adopting a definition of direct supervision to include virtual presence via appropriate audio/video real-time communications technology.

NABH Urges CMS to Ensure the Rural Health Transformation Program Funding Includes Behavioral Healthcare Providers

NABH sent a letter to CMS Administrator Oz, M.D. this week requesting that CMS’ Rural Health Transformation (RHT) Program prioritize a key part of the rural health infrastructure: inpatient and outpatient programs that provide mental health and substance use services.
 
As we posted in last week’s CEO Update, CMS released information about the RHT Program, for which H.R. 1 (OBBBA), has provided $50 billion to be allocated to states over the next five fiscal years starting in 2026. In both H.R. 1 and the RHT Program guidance, Congress and CMS have rightly identified infrastructure and technology investments as necessary for maintaining rural healthcare systems and identified mental health and substance use programs in rural areas as eligible rural healthcare providers.

Because the HITECH Act omitted behavioral healthcare providers from eligibility for the incentives physical healthcare providers received for electronic health record (EHR) system adoption, NABH members are not at parity with physical healthcare providers in their HIT infrastructure.

In our letter, we urge CMS to clarify to states in the RHT Program funding notice and additional guidance that inpatient psychiatric hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, and Opioid Treatment Programs are allowable sub-recipients of RHT Program funds.
 
“If CMS and states exclude behavioral health providers from the RHT Program, we fear the disparities in infrastructure and technology between physical healthcare and behavioral healthcare delivery systems in rural areas will be further exacerbated,” our letter noted.
Click here to learn more about CMS’ RHT program.

Livestream Available for Rural Health Transformation Planning Summit on Sept. 30

Interested NABH members can participate virtually in a Rural Health Transformation Planning Summit at the Watergate Hotel in Washington, D.C. on Tuesday, Sept. 30.
 
The one-day event will convene state and federal officials with organizations investing in new and better ways to reach Americans in rural areas with high-quality healthcare.
 
A host of companies will sponsor and support the summit or provide state grants, including ATI Advisory, Bamboo Health, Barr-Campbell Family Foundation, BioIntelliSense, Epic, Guidehouse, homeward, Horne, Magellan Health, maximus, McKinsey & Company, Philips, Rural Health Innovators, surescripts, Trualta, welldoc.
 
Click here for the livestream registration.

NABH Comments on MAHA Strategy & Report in ‘Behavioral Health Business’

NABH President and CEO Shawn Coughlin was quoted this week in a Behavioral Health Business story about the Trump administration’s Make America Healthy Again (MAHA) Commission’s Make Our Children Healthy Strategy to implement its earlier-released report.
 
Coughlin noted NABH will continue to review the strategy and join our partner organizations in urging the Trump administration to inform every action with thoroughly researched scientific evidence from psychiatrists and other behavioral healthcare practitioners.
 
“We also emphasize that when comparing our practices with practices in other countries,” Coughlin’s statement continued, “differences in prevalence in no way make overdiagnosis and overtreatment ‘empirically evident.’”

SAMHSA and CMS Release State Health Official Letter on Best Practices for Implementing the Continuum of Crisis Services

The Substance Abuse and Mental Health Services Administration (SAMHSA) and CMS’ Center for Medicaid and CHIP Services (CMCS) this week issued guidance to states about the crisis services continuum and how states may support implementing this continuum through Medicaid and CHIP.
 
The letter to state health officials describes specific Medicaid and CHIP authorities and flexibilities to support the full continuum of crisis-response services and suggests strategies for measuring and monitoring crisis response. The letter references SAMHSA’s recently published National Guidelines for a Behavioral Health Coordinated System of Crisis Care.
 
SAMHSA and CMS encourage states to take advantage of Medicaid and CHIP flexibilities for ensuring individuals who are in crisis have access to inpatient, residential, or intensive outpatient services. The letter includes specific financing flexibilities, fee-for-service and managed care considerations, payment strategies, and best practices for measuring and monitoring utilization and outcomes.

SAMHSA and CMS Release State Health Official Letter on Best Practices for Implementing the Continuum of Crisis Service

CMCS released a letter Sept. 9 detailing OBBBA’s provisions directing CMS to reduce the total Medicaid payment rate limit for state-directed payments (SDPs) for four services: inpatient hospital services, outpatient hospital services, nursing facility services, or qualified practitioner services at academic medical centers.
 
CMS published this letter to aid state-planning efforts and noted it will release a notice of proposed rulemaking (NPRM) with more specific directions. As part of the NPRM, CMS is considering changes to the total payment rate limit for SDPs for other services beyond the four services that OBBBA mandates.  
 
The letter provides an overview of Section 71116 of the OBBBA, which requires the total Medicaid payment rate for any SDP for those four services to 100% of the specified total published Medicare payment rate for expansion states or 110% of the Medicare payment rate for non-expansion states. OBBBA included a provision temporarily grandfathering certain SDPs until the rating period beginning on or after Jan. 1, 2028. CMS offered a preliminary interpretation of this provision in its letter.

Study Finds 41% Lower Risk of Death for People Who Receive Contingency Management

A study published this week in the American Journal of Psychiatry found that among veterans with stimulant use disorder, those who received contingency management (CM) were 41% less likely to die within one year than those who did not – a statistic similar to the lower chance of death associated with taking buprenorphine for opioid use disorder.
 
This is the first study to assess the relationship between CM and mortality, and the findings underscore the potential for CM to greatly enhance the outcomes of people with stimulant use disorder.
 
“Our data confirm that wide-scale access to CM for individuals with [stimulant use disorder] can save lives, both reducing all-cause mortality and preventing over­dose deaths,” the authors noted. “This is particularly important given that these findings are from real-world clinical care as opposed to clin­ical trials focused on efficacy, lending support to the asser­tion that wide-scale uptake of CM across health systems and states could potentially help reduce deaths.”

MACPAC to Webcast Public Meeting Next Week

The Medicaid and CHIP Payment and Access Commission (MACPAC) will webcast its two-day meeting next week.
 
MACPAC will host its meeting on Thursday, Sept. 18 from 9:30 a.m. to 4:30 p.m. ET and on Friday, Sept. 19 from 9:30 a.m. until Noon ET.

Click here to register.

Fact of the Week

State lawmakers this week sent Gov. Gavin Newsom (D-Calif.) a bill that would block artificial intelligence chatbots from representing themselves as medical professionals, Politico and other news outlets reported.

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

NABH and Partners Push Federal Lawmakers to Address Medicaid DSH Cuts

NABH and its partner associations representing America’s hospitals and health systems on Sept. 5 sent a letter to congressional leaders urging them to address impending Medicaid disproportionate share hospital (DSH) program reductions.
 
The letter reminds House and Senate leaders: “If Congress does not act, hospitals are facing $8 billion in cuts that would be detrimental to our facilities and communities they serve.”
 
Unless Congress delays program cuts, Medicaid DSH payment reductions will begin Oct. 1, 2025.

CMS Provides Details on H.R. 1’s Rural Health Transformation Program

The Centers for Medicare & Medicaid Services (CMS) has posted information about the Rural Health Transformation Program (RHT), for which H.R. 1 (the One Big Beautiful Bill Act) has provided $50 billion to be allocated to states over the next five fiscal years starting in 2026 and ending in 2030.
 
According to CMS, $10 billion in funding will be available each year, with 50% of it going to approved states. CMS will allocate the remaining 50% based on a variety of factors, including rural population, the proportion of rural health facilities in the state, the situation of certain hospitals in the states, and other factors that CMS said it will specify in the Notice of Funding Opportunity, or NOFO.
 
The CMS announcement said applications are due in “early November” and didn’t specify a date. The agency also said application instructions to apply for RHT funding will be included in the NOFO and released on www.grants.gov by mid-September. CMS will determine awards by Dec. 31, 2025.

CMS to Host Webinar on Medicaid & CHIP Policy for a Behavioral Health Coordinated System of Crisis Care

CMS will host a 90-minute webinar next week to discuss Medicaid and the Children’s Health Insurance Program (CHIP) policy related to a behavioral health coordinated system of crisis care.
 
The webinar is intended for state Medicaid staff and others involved in crisis-service initiatives in the states. Please share the information with anyone who might be interested.
 
Click here for registration information about the webinar on Wednesday, Sept. 10 starting at 2 p.m. ET.

KFF to Examine How States Will Implement Medicaid Work Requirements in Sept. 11 Webinar

The Kaiser Family Foundation next week will host a webinar to explore how states will implement the new Medicaid work requirements that this summer’s budget reconciliation package mandated.
 
The webinar will feature four panelists, including two state Medicaid directors, in an hourlong discussion that will address issues such as how much it will cost states and the federal government to implement work requirements; whether states will be able to meet the Dec. 31, 2026 implementation deadline; how states will use or improve “data matching” to automate verifying work activities, hours, and exemptions; and what states are looking for in forthcoming federal guidance.
 
Click here to register for the webinar that starts at Noon ET on Thursday, Sept. 11.

Reminder: Manatt to Host Webinar on Scaling Telehealth to Manage Healthcare Workforce Challenges

Research firm Manatt will host a webinar titled “Scaling Telehealth and Other Emerging Technologies to Mitigate the Health Care Workforce Crisis” next week.
 
The hourlong, interactive webinar will discuss developing a framework for considering how digital health can alleviate healthcare workforce challenges; how to adopt AI to enhance telehealth workflows; and why broader policy and industry changes are needed to attract, optimize, and retain healthcare professionals.
 
The webinar will take place on Wednesday, Sept. 10 starting at 2:30 p.m. ET. Click here to register and here to read a related white paper on the topic from Manatt and the Medical University of South Carolina.

ICYMI: NABH Welcomes Sarah Steverman, Ph.D., M.S.W. as Vice President of Regulatory Affairs, Quality, and Compliance

NABH on Aug. 25 welcomed Sarah M. Steverman, Ph.D., M.S.W. as the association’s new vice president of regulatory affairs, quality, and compliance.
 
Sarah comes to NABH from HHS’ Office of the Assistant Secretary for Planning and Evaluation (ASPE), where she supported behavioral health policy research and coordination as a social science research analyst. Before joining ASPE, Sarah served as a social behavioral scientist administrator at the National Institute on Drug Abuse’s Prevention Research Branch, where she focused on prevention research in healthcare settings and research on policies and environmental strategies to prevent substance misuse.
 
Prior to her work in government service, Sarah worked at Abt Associates, where she specialized in behavioral health policy, research, and dissemination of evidence-based interventions. She has also served as a public health analyst at the Substance Abuse and Mental Health Services Administration (SAMHSA) and led policy efforts at Mental Health America and the National Conference of State Legislatures.
 
Sarah began her career working in direct service with individuals with co-occurring substance use and mental health conditions. She earned both her master’s and doctoral degrees at Catholic University of America.
 
At NABH, Sarah is responsible for developing regulatory solutions and policy recommendations that support and promote quality behavioral healthcare services nationwide. She will monitor legislation and regulations that affect the behavioral healthcare industry and provide strategic direction about essential programs and initiatives in the federal regulatory environment and will focus on advancing the association’s public policy priorities. Sarah will also manage the association’s Quality Committee and Behavioral Health Services within General Healthcare Systems Committee.

Fact of the Week

A new study published in Health Affairs show that fewer than one in three adolescents with past-year opioid use disorder received substance use treatment in 2022-2023.

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

NABH Welcomes Sarah Steverman, Ph.D., M.S.W. as Vice President of Regulatory Affairs, Quality, and Compliance

This week NABH welcomed Sarah M. Steverman, Ph.D., M.S.W. as the association’s new vice president of regulatory affairs, quality, and compliance.
 
Sarah comes to NABH from HHS’ Office of the Assistant Secretary for Planning and Evaluation (ASPE), where she supported behavioral health policy research and coordination as a social science research analyst. Before joining ASPE, Sarah served as a social behavioral scientist administrator at the National Institute on Drug Abuse’s Prevention Research Branch, where she focused on prevention research in healthcare settings and research on policies and environmental strategies to prevent substance misuse.
 
Prior to her work in government service, Sarah worked at Abt Associates, where she specialized in behavioral health policy, research, and dissemination of evidence-based interventions. She has also served as a public health analyst at the Substance Abuse and Mental Health Services Administration (SAMHSA) and led policy efforts at Mental Health America and the National Conference of State Legislatures.
 
Sarah began her career working in direct service with individuals with co-occurring substance use and mental health conditions. She earned both her master’s and doctoral degrees at Catholic University of America.
 
At NABH, Sarah is responsible for developing regulatory solutions and policy recommendations that support and promote quality behavioral healthcare services nationwide. She will monitor legislation and regulations that affect the behavioral healthcare industry and provide strategic direction about essential programs and initiatives in the federal regulatory environment and will focus on advancing the association’s public policy priorities. Sarah will also manage the association’s Quality Committee and Behavioral Health Services within General Healthcare Systems Committee.

CMS Releases 2022 T-MSIS Behavioral Health Data Book

The Centers for Medicare & Medicaid Services (CMS) has released its 2022 Transformed Medicaid Statistical Information System (T-MSIS) Behavioral Health (BH) Data Book and accompanying static tables pursuant to Section 202 of the Consolidated Appropriations Act (CAA), 2024 (CAA, 2024; P.L. 118-42).
 
The resource is a publicly available compendium of the number of Medicaid and Children’s Health Insurance Program beneficiaries with a substance use disorder (SUD) or a mental health (MH) condition and the services they received. The report catalogs the treatment of SUD and MH in the Medicaid and CHIP beneficiary population and services provided for the treatment of SUD and MH under Medicaid and CHIP. 

SAMHSA Announces $19 Million to Improve Housing Capacity for Homeless Persons with SMI

SAMHSA this week announced $19 million in supplemental funding through the Community Mental Health Services Block Grant to strengthen the nation’s housing capacity for homeless persons with serious mental illness (SMI).
 
“Addressing homelessness for people with serious mental illnesses requires improved coordination and partnerships nationwide,” SAMHSA Principal Deputy Assistant Secretary Art Kleinschmidt, Ph.D., M.B.A., said in an announcement about the funding. “This investment will help build data-driven capacity at the state and local level and is critical to make our communities safer and healthier.”
 
According to SAMHSA, this supplemental funding provides an opportunity for states to align public health, housing, and justice systems in order to reduce homelessness and improve outcomes for individuals with SMI. The funding will help states build capacity and promote collaboration across systems, with a particular focus on addressing the intersection of homelessness and SMI.

NYC Health & Hospitals to Launch Contingency Management Pilot in 2026

NYC Health & Hospitals will launch a pilot Contingency Management (CM) program next year to patients who are treated for substance use disorder, Politico reported this week.
 
According to the story, the pilot will test CM at Lincoln, Elmhurst, and Bellevue Hospitals, where officials expect to reach hundreds of patients each year. The program is expected to expand citywide to serve about 1,000 patients annually, the story said.
 
Please remember to read and share NABH’s CM fact sheet.

Manatt to Host Webinar on Scaling Telehealth to Manage Healthcare Workforce Challenges

Research firm Manatt will host a webinar titled “Scaling Telehealth and Other Emerging Technologies to Mitigate the Health Care Workforce Crisis” next month.
 
The hourlong, interactive webinar will discuss developing a framework for considering how digital health can alleviate healthcare workforce challenges; how to adopt AI to enhance telehealth workflows; and why broader policy and industry changes are needed to attract, optimize, and retain healthcare professionals.
 
The webinar will take place on Wednesday, Sept. 10 starting at 2:30 p.m. ET. Click here to register and here to read a related white paper on the topic from Manatt and the Medical University of South Carolina.

Fact of the Week

Three major AI chatbots — ChatGPT, Claude, and Gemini — generally respond appropriately to questions about suicide when those queries are especially benign or dangerous; however, there is still some fine-tuning needed, especially when it comes to questions that lay somewhere in the middle, according to a new RAND study.  For more information about this topic, please see this article from The Wall Street Journal and this story from The New York Times.

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

New JAMA Study Shows ED Boarding is a ‘Considerable Issue’ for Medicaid-Enrolled Youth

A new study published in JAMA shows that emergency department (ED) boarding is a “considerable issue” for Medicaid-enrolled youth, with more than one in 10 mental health-related ED visits lasting more than two days. The findings also showed that in five states, boarding occurred in more than one in five in such visits.
 
Medicaid covers more than 35 million children and youth – nearly half of all youth in the United States – and this study investigated prevalence and variations in boarding for youth ED visits in 2022.
 
“Boarding poses a substantial emotional toll on patients, families, and staff; it also may result in challenges related to patient and staff safety and restraint use, and it suggests an inability to find timely and appropriate care for youths in crisis,” the study noted. “The high levels of boarding observed in our study and the substantial state-level variation should warrant concern, particularly given evidence that boarding can lead to care delays, clinical deterioration, and increased costs— outcomes that may disproportionately affect low-income children who face systemic barriers to timely and coordinated behavioral healthcare.”

GAO Report Shows HHS Tops Federal Agencies for Most AI Use

A recent study from the Government Accountability Office (GAO) analyzed 11 selected federal agencies with artificial intelligence (AI) inventories and found the total number of reported AI use cases nearly doubled to 1,110 in 2024 from 571 in 2023. At the same time, generative AI use cases increased about nine-fold, to 282 from 32.
 
HHS led the pack with 116 different ways the federal health agency used AI for generating content and responses in 2024, up from seven ways in 2023.
 
On a related note, the think tank The Bipartisan Policy Center published a report last week that shows how three HHS agencies have implemented AI and that they’re mostly using chatbots to help them work more efficiently.

SAMHSA to Host Eating Disorders & Suicide Webinar Next Week

The Substance Abuse and Mental Health Services Administration’s (SAMHSA) Eating Disorder Center of Excellence will host an hourlong webinar to discuss the relationship between eating disorders and suicide next Thursday, Aug. 28 starting at 1 p.m. ET.
 
Jean Doak, Ph.D., a licensed psychologist and clinical director of the UNC Center of Excellence for Eating Disorders, and Jeff Greenberg, director of SAMHSA’s Eating Disorder Center of Excellence, will host the webinar that will emphasize the importance of early identification and intervention. The webinar will also outline risk factors, warning signs, and co-occurring conditions such as mood disorders that heighten suicide vulnerability in patients with anorexia, bulimia, and binge eating.
 
Click here to register.

SAMHSA’s National Recovery Month Toolkit Available Now

SAMHSA has released its annual toolkit for National Recovery Month that begins on Sept. 1.
 
Started in 1989, National Recovery Month is observed every September to promote and support new evidence-based treatment and recovery practices. This year’s theme is Recovery is REAL (Restoring Every Aspect of Life).
 
Click here for the toolkit, which includes social media messages, graphics, and promotional materials for various audiences. Remember to include #RecoveryMonth when sharing any Recovery Month-related content.

Reminder: HHS Announces Funding Opportunity for Behavioral Health IT Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due next Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

Nearly two-thirds (65%) of college students with autism suffer from anxiety, compared with just more than 9% of their peers without autism, according to a new study in the Journal of Autism and Developmental Disorders. The findings also show that nearly half (48%) report depression, compared with 8% of their peers.

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

Manhattan Institute Publishes Report on Psychiatric Hospitals and the IMD Exclusion

The Manhattan Institute released a report yesterday assessing the current landscape of freestanding psychiatric hospitals amidst Medicaid’s Institution for Mental Diseases (IMD) exclusion and identifying opportunities for policy reform, including repeal of the exclusion.
 
NABH provided information to the author to inform the report’s content, and NABH publications were cited.
 
The report emphasizes that modifying the IMD exclusion is needed to ensure the financial sustainability of psychiatric hospitals and address the significant unmet need for care among Medicaid beneficiaries with serious mental illness. “Prohibiting reimbursement for treatment in psychiatric hospitals—without any clinical justification—exposes hospitals to financial losses from uncompensated care, a risk that becomes unavoidable as hospitals grow beyond 16 beds.”

District Court Issues Order Favorable to Beneficiaries in Wit vs. United Behavioral Health

On Aug. 5, a judge in the U.S. District Court for the Northern District of California issued an order favorable to the plaintiffs, health insurance beneficiaries who sued United Behaioral Health (UBH) alleging that the company improperly denied coverage for behavioral healthcare services.
 
In a landmark ruling in 2019, the District Court found that UBH violated its responsibilities to beneficiaries by imposing medical necessity criteria that misaligned with generally accepted standards to protect its own interests.
 
However, upon appeal by UBH, the U.S. Ninth Circuit Court of Appeals partially reversed the initial decision and sent the case back to the District Court for further consideration of whether plaintiffs’ breach of fiduciary duty claims are distinct from denial of benefits claims, the latter of which the Appeals Court ruled in favor of UBH.
 
The latest order affirms that they are distinct, specifically with respect to breaches of the fiduciary duties of loyalty and due care.
 
The case will now proceed to remedies and final judgment.

Sen. Grassley Introduces Bill to Disclose IPF Accreditation Survey Information

Sen. Chuck Grassley introduced the Psychiatric Hospital Inspection Transparency Act of 2025, which would require the U.S. Department of Health and Human Services (HHS) to make public information from psychiatric hospitals’ accreditation surveys that helps “health care consumers to make informed decisions regarding where to receive health care.”
 
The bill directs HHS to work with accreditation organizations and psychiatric hospitals to determine the type of information that is appropriate to disclose and how this information is presented to the public.
 
The bill also provides HHS the authority to publicly disclose full accreditation surveys of psychiatric hospitals.
 
NABH has conveyed significant concerns with disclosure of accreditation surveys to Sen. Grassley’s staff, underscoring the importance of confidentiality to facilitate quality improvement activities between facilities and accreditors, and the potential for this information to mislead consumers.

HHS Releases Report on Youth Psychiatric Medication Prescribing

HHS issued a report describing national trends in psychiatric medication dispensing to youth aged 3-17 between 2006 and 2023.
 
The largest change in proportion of youth receiving a medication was for selective serotonin reuptake inhibitors, which rose from 1.5% to 3.6%. Meanwhile, gradual reductions occurred for antipsychotics (1.3% to 1.1%) and mood stabilizers (1% to 0.8%), and there was a slight increase for stimulants (5% to 5.3%).
 
The trends for antipsychotics and mood stabilizers are opposite to adults, who experienced a steady increase during this period.

GAINS Center to Host Webinar Next Week on Supporting Service Members & Veterans in Criminal Justice Settings

The GAINS Center at the Substance Abuse and Mental Health Services Administration (SAMHSA) and SAMHSA’s Service Members, Veterans, and Their Families Technical Assistance Center will host a national webinar titled Supporting Justice-Involved Service Members and Veterans Through Early Interventions in Criminal Justice Settings on Tuesday, Aug. 19 from 1 p.m. to 2:30 p.m. ET.
 
The webinar will explore the Sequential Intercept Model, focusing on Intercepts 0 and 1, and its application to justice-involved service members, including active duty, Guard/Reserve, and retired military populations. Identifying and engaging individuals early at their intersection with behavioral health or criminal justice systems plays a critical role in achieving successful outcomes.
 
Click here to register.

Reminder: HHS Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

The U.S. Food and Drug Administration (FDA) has asked the U.S. Justice Department to classify 7-OH, a compound from the kratom plant with opioid-like effects found in unregulated tablets, gummies, and drink mixes sold in gas stations and convenience stores, as an illicit substance.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

RFK Jr. Says HHS Will Move Forward with HHS Reorganization

The publication Inside Health Policy this week reported that U.S. Health and Human Services Department (HHS) Secretary Robert F. Kennedy, Jr. said HHS will move forward with its plan to reorganize its agencies even though Senate appropriators omitted the proposed reorganization from the Senate Appropriations Committee’s funding bill.
 
According to the story, the bipartisan HHS funding bill that advanced last week does not include any language to create a new “Administration for a Healthy America,” or AHA, as HHS did not submit a formal reorganization plan to Congress and allow for six months of consideration, a spokesperson for Senate Appropriations Committee Chair Susan Collins (R-ME) told Inside Health Policy. AHA would combine multiple current agencies, including the Agency for Toxic Substances and Disease Registry, Health Resources and Services Administration, National Institute for Occupational Safety and Health, Office of the Assistant Secretary for Health, and Substance Abuse and Mental Health Services Administration (SAMHSA).
 
HHS has said the reorganization centralizes functions including human resources, information technology, procurement, external affairs and policy in single offices, as well as reduces the number of regional offices from 10 to five.

In addition to AHA, the planned reorganization would merge the Administration for Strategic Preparedness and Response into the Centers for Disease Control and Prevention (CDC); merge the office of Assistant Secretary for Planning and Evaluation with the Agency for Healthcare Research and Quality as a new Office of Strategy; and move to the functions of the Administration for Community Living to other agencies, including the Centers for Medicare & Medicaid Services (CMS).

SAMHSA Releases Behavioral Health Workforce Self-Care Fact Sheet

SAMHSA this week released Taking Care: Promoting Well-being for Recovery and Behavioral Health Care Providers, which includes resources and tips for the nation’s behavioral health workforce.
 
“Recent definitions suggest that self-care is inherently community-centered,” the resource notes. “There is a growing shift toward regarding self-care as a workplace focus that amplifies the need for collective practices and workplace well-being,” it continued. “Varying definitions of self-care emphasize the importance of valuing individualized approaches that are historically rooted, healing-centered, trauma-informed, holistic, ecological, and culturally nurtured.”
 
SAMHSA’s new fact sheet emphasizes that wellness involves purpose in life, active involvement in satisfying work and play, joyful relationships, a healthy body and living environment, and happiness.

ICYMI: CMS Finalizes 2.4% Payment Increase to IPFs in FY 2026

CMS will apply a 2.4% payment increase to inpatient psychiatric facilities in 2026, according to the Fiscal Year (FY) 2026 Inpatient Psychiatric Facility (IPF) Prospective Payment System final rule the agency released Aug. 1 in the Federal Register.

The final rule also includes a slight increase in the outlier threshold as well as increases to the teaching and rural facility adjustments.

For the IPF Quality Reporting program, CMS will remove four quality measures: Facility Commitment to Health Equity, COVID-19 Vaccination Coverage Among Healthcare Personnel, Screening for Social Drivers of Health, and Screen Positive Rate for Social Drivers of Health.

The rule also noted CMS will modify the reporting period from one to two years for the 30-day Risk-Standardized All Cause Emergency Department Visit Following an IPF Discharge measure and will delay its initial use to the FY 2029 payment determination.

These changes align with the agency’s proposed rule. Click here for a summary of provisions that take effect on Oct. 1, 2025.

Reminder: CMS Seeking Participants for Hospital Price Transparency Virtual Listening Session: Monday, Aug. 11

CMS is seeking hospital and health system representatives to attend a Hospital Price Transparency (HPT) consumer-friendly display listening session with CMS staff to help the agency better understand how to empower consumers with accessible and actionable pricing information and make more meaningful price comparisons.
 
This session will focus solely on the HPT program’s consumer-friend display requirement, and staff from the federal contractor MITRE will ask several questions about the consumer-friendly format functionality, including required standard data elements to enhance comparability, number and type of services of most interest, patient interaction with the consumer-friendly display, and the intersection with other programs, such as the Transparency in Coverage and No Surprises Act.
 
The listening session will be held on Monday, Aug. 11 from 12:30 p.m. to 2 p.m. ET. Please contact MITRE_HPT@mitre.org if you want to participate.

Reminder: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

CDC has launched Free Mind, a national campaign that provides youth ages 12-17 and their parents and caregivers with information and resources about substance use, mental health, and the connection between the two.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Congress Advances Legislation for Veterans’ Healthcare Services

Congress this week continued to focus on the Veterans Affairs (VA) Community Care Network by advancing several Community Care-focused bills and the Senate FY 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act to increase funding levels for the Community Care Network.
 
Both the House and Senate committees that oversee veterans’ care advanced bills that would expand access to community care for veterans while standardizing and improving VA mental health programs.
 
The Veterans’ Assuring Critical Care Expansions to Support Servicemembers Act of 2025 (ACCESS)(S. 275 | H.R. 740), introduced in the Senate by Senate VA Committee Chairman Jerry Moran (R-Kan.) and in the House by House VA Committee Chairman Mike Bost (R-Ill.), would codify standards for veterans to receive community-based care that cannot be provided by the VA with a primary care, mental health care, or extended care appointment within a 30-minute drive or within 20 days or Veterans with a specialty care appointment within an hour’s drive or within 28 or fewer days.
 
The bill also requires the VA Department to create a “standardized screening process” for veterans to participate in mental health treatment programs; develop a three-year pilot program allowing veterans to access mental health and/or substance use disorder programs in the community without a referral; and establish tracking on wait times and care availability for mental health programs, among other improvements. Both bills are pending full consideration on the House and Senate floors.
 
In addition to The ACCESS Act, the Senate Veterans Affairs Committee passed 24 pieces of legislation to improve the lives of veterans, caregivers, and survivors nationwide. These bills include the Veterans Mental Health and Addiction Therapy Quality of Care Act and External Provider Scheduling Program Act.

S.702, Sen. John Cornyn’s (R-Texas) The Veterans Mental Health and Addiction Therapy Quality of Care Act, requires the VA Department to seek to enter into an agreement with an independent and objective organization outside the VA to conduct a study on the quality-of-care differences between mental health and addiction therapy care that VA healthcare providers offer compared with non-VA providers across various modalities, such as telehealth, in-patient, intensive out-patient treatment, and residential treatment.

And S. 654, The External Provider Scheduling Program Act – also from Sen. Jerry Moran (R-Kan.) – amends title 38 of the United States Code to establish an external provider scheduling program that would assist the VA Department in scheduling appointments for care and services under the Veterans Community Care Program. The program must consist of technology that allows VA schedulers to view the schedules of healthcare providers participating in the program and schedule, in real-time, appointments for such care.
 
Also last week the Senate Appropriations Committee also passed the FY 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act, which included a notable 50% increase compared with the FY2024 enacted level for community care. This increase elevates community care funding to $33 billion, up from $22 billion in FY2024. This is similar to levels the House Appropriations Committee passed in July. Senate leaders and appropriators are now trying to agree on a three-or-four bill package deal of FY2026 government funding bills, including for military construction and VA, with the goal of voting on the measure when lawmakers return from their August recess.

SAMHSA Releases 2024 National Survey on Drug Use

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released the results of its 2024 National Survey on Drug Use and Health (NSDUH), which offers a national view of behavioral health based on self-reported responses from nearly 70,000 people
 
2024 marks the first year since 2020 in which there are at least four years of comparable data for key NSDUH outcomes, adjusting for survey design changes since 2020 and enabling trend reporting for the first time since 2019.
 
The results showed that among adults 18 and older, the percentage who had any mental illness (AMI) or serious mental illness (SMI) in the past year showed no change from 2021 to 2024. Among U.S. adolescents aged 12 to 17, the percentage who had serious thoughts of suicide in the past year declined to 10.1% in 2024 from 12.9% in 2021.
 
Meanwhile, the survey showed mixed results on substance use outcomes, as prescription opioid misuse among people 12 or older declined to 2.6% in 2024 from 3.0% in 2021 and marijuana use in that same age group increased to 22.3% in 2024 from 19.0% in 2021.

CMS Seeking Participants for Hospital Price Transparency Virtual Listening Session: Aug. 11

The Centers for Medicare & Medicaid Services (CMS) is seeking hospital and health system representatives to attend a Hospital Price Transparency (HPT) consumer-friendly display listening session with CMS staff to help the agency better understand how to empower consumers with accessible and actionable pricing information and make more meaningful price comparisons.
 
This session will focus solely on the HPT program’s consumer-friend display requirement, and staff from the federal contractor MITRE will ask several questions about the consumer-friendly format functionality, including required standard data elements to enhance comparability, number and type of services of most interest, patient interaction with the consumer-friendly display, and the intersection with other programs, such as the Transparency in Coverage and No Surprises Act.
 
The listening session will be held on Monday, Aug. 11 from 12:30 p.m. to 2 p.m. ET. Please contact MITRE_HPT@mitre.org if you want to participate.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

Among adolescents aged 12 to 17, the percentage who had a major depressive episode in the past year declined to 15.4% in 2024 from 20.8% in 2021, according to SAMHSA’s latest annual survey on drug use and health.

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

Reps. Tonko & Huizenga Introduce Legislation to Remove Medicare’s 190-day Lifetime Limit

Reps. Paul D. Tonko (D-N.Y.) and Bill Huizenga (R-Mich.) this week reintroduced H.R. 4619, the Medicare Mental Health Inpatient Equity Act, bipartisan legislation that would repeal permanently the Medicare program’s 190-day lifetime limit for inpatient psychiatric care.
 
Despite the enactment of the landmark Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act in 2008, Medicare continues to discriminate against seniors with mental illnesses through this provision. The 190-day lifetime limit in care disproportionately harms individuals who receive Medicare coverage earlier in life due to disability.
 
In its March 2025 report, the Medicare Payment Advisory Commission (MedPAC), the independent agency that advises Congress about the Medicare program, recommended that lawmakers eliminate Medicare’s 190-day lifetime limit.
 
More than three dozen organizations, including NABH, support this critical legislation, which has been referred to the House Ways and Means Committee.
 
“The National Association for Behavioral Healthcare applauds Reps. Paul Tonko (D-N.Y.) and Bill Huizenga (R-Mich.) for reintroducing the Medicare Mental Health Inpatient Equity Act,” NABH President and CEO Shawn Coughlin said in a statement. “We also thank the bill’s original cosponsors Reps. Lloyd Doggett (D-Texas) and Brian Fitzpatrick (R-Pa.). This bipartisan legislation will bring us closer to mental health parity by eliminating Medicare’s 190-day lifetime limit for inpatient psychiatric hospital services, regardless of a patients’ needs,” Coughlin continued. “Experts agree that demand for inpatient care for individuals with the most difficult-to-treat behavioral health conditions far outstrips supply, and denying care can lead to many adverse consequences if those conditions are not addressed. Congress should align with the Medicare Payment Advisory Commission’s unanimous recommendation to eliminate Medicare’s 190-day lifetime limit,” he added. “NABH looks forward to working with the bill’s sponsors to pass this legislation.”
 
NABH applauds Reps. Tonko, Huizenga, Doggett and Fitzpatrick for supporting legislation that would remove a lifetime limit on care that does not exist for any other inpatient healthcare service that Medicare covers, and our team is asking Members of Congress to cosponsor H.R. 4619.
 
We will also issue an Action Alert to you, our members, asking that you contact your congressional representatives and request that they cosponsor this bill. Thank you for your help!

Lawmakers Reintroduce ‘Medicaid Bump Act’ to Increase Reimbursement Rate for Behavioral Healthcare Services

Also this week, Reps. Tonko and Fitzpatrick in the House and Sen. Tina Smith (D-Minn.) in the Senate reintroduced the Medicaid Bump Act, companion legislation that would increase Medicaid’s federal reimbursement rate for mental and behavioral healthcare services.
 
Traditionally, states receive federal reimbursement rates between 50% and 75%. Under the Medicaid Bump Act, Medicaid would reimburse states for 90% of the cost of providing new mental and behavioral healthcare services.
 
In addition, the bill would direct the HHS secretary to define which services qualify as eligible behavioral healthcare services for the enhanced FMAP and require HHS to provide annual reports about the effects of increased federal Medicaid reimbursement on the use of behavioral healthcare services in each state.
NABH is one of 34 organizations that supports the Medicaid Bump Act.
 
Bill numbers have not been assigned to the Medicaid Bump Act; however, the legislation has been referred to the House Energy and Commerce and Senate HELP Committees.

Trump Signs Executive Order to Push Cities to Move Homeless Persons from Streets to Treatment Centers

President Trump on Thursday signed an executive order to push cities and states to remove homeless people from the streets and into treatment centers.
 
The order, “Ending Crime and Disorder on America’s Streets,” directs U.S. Attorney General Pam Bondi to reverse precedents that limit state and local governments’ ability to commit people on the streets who are at risk to themselves or others, according to a fact sheet that The Hill newspaper obtained.
 
USA Today first reported on the order, which also requires interagency work on grants for states to enforce prohibitions on open, illicit drug use, urban camping, loitering and squatting, and to track sex offenders. It also requires redirecting funds to ensure people sleeping on streets and causing public disorder – and suffering from serious mental illness or substance use disorder – are moved to treatment centers, although it’s unclear how much federal funding will be allocated for it.
 
It is part of Trump’s commitment to ending homelessness, according to the fact sheet, and follows a March order that directed the National Park Service to clear homeless encampments and graffiti on federal lands.

Blue Cross Blue Shield Provider Settlement Claim Deadline is Next Tuesday, July 29

A landmark class action antitrust settlement addressing claims that Blue Cross Blue Shield (BCBS) suppressed competition and underpaid providers through its BlueCard Program, according to a BCBS notice.
 
The notice states that those who provided healthcare services, equipment, or supplies to BCBS-insured patients between July 24, 2008, and Oct 4, 2024 may be eligible to receive a portion of this historic settlement.
 
Most U.S. providers who treated BCBS-insured patients during the settlement period qualify, unless employed/owned by BCBS or exclusively by government entities, or limited to specific services (e.g., prescription drugs, standalone dental/vision). Compensation will be based on your BCBS reimbursement amounts, adjusted for estimated antitrust impact.
 
The deadline to submit a claim is Tuesday, July 29. Click here for more information.

Senate Confirms Terry Cole as DEA Administrator

In a party-line vote of 50-47, the Senate this week confirmed Terry Cole to lead the U.S. Drug Enforcement Administration (DEA).
 
Cole’s job will include enforcing the Trump administration’s approach to marijuana rescheduling, which started during the Biden administration and is now uncertain. Advocates for marijuana rescheduling argue it would allow for more research into cannabis and its health effects.
 
Most recently Cole served as Virginia’s secretary of public safety from 2023-2025. Previously he spent 22 years at DEA, which included service in various states and on foreign missions in Colombia, Afghanistan, Mexico and the Middle East.
 
Cole earned his bachelor’s degree from the Rochester Institute of Technology and certificates in leadership from the University of Virginia and the Medoza College of Business at the University of Notre Dame.

Provider Resource: ‘After Your Child’s Suicide Attempt’ Video

The Education Development Center’s Zero Suicide Institute and Parents to Parents, a not-for-profit organization that offers resources to caregivers whose child is struggling with mental health illness, have created After Your Child’s Suicide Attempt, an hourlong movie that addresses the questions parents have and describes best practices in suicide care.
 
The two organizations urge healthcare professionals, school, and community leaders to share the video and accompanying resources with parents.   

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

The 988 Lifeline stopped specialized services for LGBTQ+ youth this week. Since 988 launched three years ago, it has fielded more than 16 million calls, texts and chats, with nearly 10% of those contacts from gay and transgender young people, according to government data. Meanwhile, data from the Centers for Disease Control and Prevention’s Youth Behavior Risk Survey show that LGBTQ+ youth are more likely to experience persistent feelings of sadness and hopelessness compared with their peers, and they are more likely to attempt suicide.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Releases CY 2026 Outpatient Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) on Tuesday, July 15 released its Calendar Year 2026 Outpatient Prospective Payment System (OPPS) proposed rule along with an accompanying fact sheet.

In it, CMS proposed to increase payment rates by 2.4%, reflecting an inpatient market basket increase of 3.2% minus a productivity adjustment of 0.8 percentage point.
 
The agency also proposed collecting hospitals’ median negotiated payer-specific charges with Medicare Advantage organizations by Medicare Severity Diagnosis Related Groups (MS-DRGs), which would be used to inform changes to the Inpatient Prospective Payment System MS-DRG relative weights beginning in Fiscal Year 2029.
 
Other changes specific to behavioral healthcare services are largely limited to partial hospitalization programs (PHPs) and intensive outpatient programs (IOPs) delivered by community mental health centers, for which CMS proposes modifying the payment rate methodology to be 40% of the corresponding hospital-based rates to promote payment accuracy and stability. Meanwhile, the payment rate methodology for hospital-based PHPs and IOPs would remain the same.
 
NABH continues to review the OPPS proposed rule. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.

CMS Proposes Broader Medicare Coverage of Select Behavioral Health Services in CY 2026 Physician Fee Schedule

CMS also released its CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule and accompanying fact sheet earlier this week.
 
The agency CMS estimates that the proposed policy changes would, on average, affect allowed charges for behavioral health specialists as follows:

• Psychiatrists: +6% (non-facility), -9% (facility)
• Clinical psychologists: +5% (non-facility), -3% (facility)
• Clinical social workers: +6% (non-facility), -2% (facility)

These changes can be attributed to broader modifications to reimbursement calculation, such as practice expense methodology changes to capture increased indirect costs of non-facility practitioners, and a higher conversion factor for practitioners participating in a qualifying alternative payment model (+3.83%) compared with those who are not (+3.62%).

NABH is pleased to see the proposed rule aims to improve coverage of certain behavioral healthcare services in various ways, such as creating three optional add-on codes to advanced primary care management that would better enable the provision of behavioral health integration and collaborative care model services; expanding coverage of digital therapeutics to include those to treat attention-deficit/hyperactivity disorder; and permitting clinical social workers, marriage and family therapists, and mental health counselors to bill for community health integration services.
 
CMS is also seeking public comment on the possible expansion of coverage of motivational interviewing; and potential changes to the query of prescription drug monitoring program quality measure, including transitioning the measure from attestation- to performance-based, and expanding the scope of the measure to include Schedule II non-opioids.
 
NABH continues to review the PFS proposed rule and will solicit feedback from members soon. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.

MedPAC Releases 2025 Data Book on Medicare Spending

The Medicare Payment Advisory Commission (MedPAC) has released its 2025 data book, which provides data on Medicare spending, demographics of the Medicare population, beneficiaries’ access to care, and quality of care in the program, among other information.
 
Click here to see the book’s section about acute inpatient services, which includes data about inpatient psychiatric facilities.

ICYMI: CHCS Webinar on Medicaid Innovation to Improve Behavioral Healthcare Access

The Center for Health Care Strategies this week hosted Medicaid Innovation in Improving Access to Behavioral Health Care, 75-minute webinar featuring state leaders from Colorado, Massachusetts, and Wyoming who discussed how they are tackling behavioral healthcare challenges and using Medicaid policy to improve access to high-quality care in their states.
 
Panelists explored how states can expand access, improve coordination, and modernize behavioral healthcare through cross-sector partnerships, workforce development, cross-agency data sharing, and integrated approaches to care.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT) compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.
 
The deadline to respond to the RFI is Monday, July 21.

Fact of the Week

Psychiatric recommendations from four large language models (LLMs) – AI programs designed to understand and generate human language – changed when a patient’s record noted they were African American, researchers recently reported in the journal NPJ Digital Medicine.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Senate Faces Additional Obstacles to Passing its Reconciliation Bill

The pathway for the Senate to pass its budget reconciliation bill became more precarious this week, following increased opposition to Medicaid cuts by a growing number of senators and the Senate parliamentarian’s determinations that several key provisions violate the Byrd rule, meaning they require 60 votes to pass the Senate instead of a simple majority.
 
Provisions deemed to violate the Byrd rule include the proposed reduction in the permissible state provider tax threshold from 6% to 3.5%, limits to federal financial participation in Medicaid for states that offer coverage to non-citizens, and others. Republicans will now have to rewrite or remove these sections of the bill, which were estimated to collectively save hundreds of billions of dollars.
 
The parliamentarian’s determinations come as Senate Republican leaders and President Trump are trying to win over wavering GOP senators to support the Senate bill. Various senators are also proposing a $15 billion stabilization fund to mitigate the bill’s impacts on rural hospitals.
 
Majority Leader Thune is still holding out hope for an initial procedural vote today, followed by an overnight vote-a-rama rolling into a final vote on Saturday. The bill would then go to the House for a vote, though many Republicans there have concerns with the extent of Medicaid cuts.
 
The goal of Congressional Leadership remains for President Trump to sign the bill by July 4.
 
The NABH Government Affairs team is contacting senate offices to oppose the current Senate bill. NABH has also sent several Action Alerts to NABH members with information to support outreach to senators. We urge you to respond to these alerts and encourage your colleagues to do the same.

Insurers Announce Plan to Reform Prior Authorization

A group of health insurance executives joined HHS Secretary Robert F. Kennedy, Jr. and Centers for Medicare & Medicaid Services Administrator Mehmet Oz on Monday to announce plans to change prior authorization practices with the aim to reduce administrative burden and improve patient care. Participating insures pledged to:

• Standardize electronic prior authorization by 2027;
• Reduce the scope of claims subject to prior authorization by 2026;
• Ensure continuity of care when patients change plans by 2026;
• Enhance communication and transparency on determinations by 2026;
• Expand real-time responses to 80% by 2027; and
• Ensure medical review of non-approved requests (in effect now).

Key questions remain about how insurers will implement some of these changes, and how their performance on these commitments will be monitored. Insurers’ approach to implementation could be controversial, such as if they rely further on artificial intelligence to improve response time.

Reminder: Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards Today, June 27!

NABH has released two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest is Wednesday, July 2 and full applications are due Wednesday, Aug. 27.
 
An HHS representative offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline. Please reach out to Dan Schwartz if you are interested in attending such a meeting. If there is a sufficient interest, we will proceed with scheduling.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT) compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

Fact of the Week

A new editorial in JAMA suggests addictive screen use is more strongly linked to negative mental health outcomes than screen time alone. The results emphasize the importance of addressing not just screen time, but also addictive behaviors in adolescents. “Moving forward, targeted policies and interventions, including stronger parental involvement and better age verification measures on social media, are crucial for mitigating the risks associated with screen addiction,” the editorial said.

Happy Independence Day from NABH!

NABH will not publish CEO Update on Friday, July 4 and will resume on Friday, July 11. The NABH team wishes you, your families, and your teams a happy and safe Independence Day weekend!

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

Senate Finance Committee’s Budget Reconciliation Bill Includes Unsustainable Medicaid Cuts

The Senate Finance Committee’s recently passed budget reconciliation package includes significant and burdensome changes to the House-passed budget reconciliation bill and contains unsustainable cuts to Medicaid programs for behavioral healthcare providers.

Notable Medicaid program changes include restricting provider taxes, reducing state-directed payments, mandating work requirements that contain a complex behavioral healthcare treatment carve out, and eliminating the enhanced premium tax credit for Marketplace plans.

The biggest changes include a moratorium on new or increased provider taxes, which propose a significantly deeper cut to states’ ability to use provider taxes to finance Medicaid. As in the House bill, section 71120 of the Senate Finance bill would prohibit states from receiving federal Medicaid matching funds for any new or increased provider taxes enacted after the bill passes unless authorized already.  Notably, the moratorium would apply to increases in the amount of tax on a per-unit basis or the rate of tax imposed with respect to a class of healthcare items or services or increases in the base of the current provider tax. This effectively places a moratorium on using newly enacted or expanded provider taxes to finance the non-federal share of the Medicaid program.

The Senate bill would also modify the “hold harmless” standard for healthcare-related provider taxes under Medicaid, which limits how much states can tax providers without triggering federal penalties. Currently capped at 6%, the Senate bill phases down the threshold for expansion states beginning Oct. 1, 2026, to 3.5% by fiscal year 2031, while preserving the 6% cap for non-expansion states.

Meanwhile, the Senate bill would not affect the “hold harmless” threshold for provider taxes that states impose for nursing facility or intermediate care facility services as long as the tax is effective as of Oct. 1, 2026, within the hold harmless threshold as of May 1, 2025, and the provider tax is not modified or otherwise changed unless to come into compliance with these provisions. The Senate bill clarifies that these provisions only apply to the 50 States and Washington, D.C. (it does not apply to U.S. territories). The bill provides $6 million to HHS for implementation.

The Senate bill also includes modest – and meaningful – changes for the treatment of certain state- directed payments when no published Medicare rate exists. The bill directs HHS to revise Medicaid managed care regulations so that state-directed payments to providers in Medicaid expansion states cannot exceed 100% of the published Medicare payment rate for a given service, while non-expansion states would be permitted to go up to 110%. Rather than directing HHS to use an “equivalent Medicare payment rate” when no published rate exists — as the House bill does — the Senate version instead calls for an equivalent payment under the Medicaid State Plan.

The Senate bill also applies a stricter approach to grandfathered payments. While the House bill would allow grandfathered payments to continue at existing levels, the Senate version phases them down by 10 percentage points annually starting in 2027 until they meet the applicable cap. It also broadens eligibility for grandfathering to include cases where states made a good faith effort to secure prior approval.

The Senate version also includes a notable addition to the Uniform Medicaid Provider Tax Requirement that would allow states to revise existing provider taxes to comply with the new standards without being penalized. Under the bill, states’ ability to obtain waivers from the uniform tax requirement for Medicaid provider taxes would be limited.

Specifically, the bill would prohibit waivers for tax structures that impose lower rates on providers with less Medicaid volume, or higher rates to those with more. The section includes definitions for “Medicaid taxable unit,” “non-Medicaid taxable unit,” and “tax rate group” to help identify impermissible structures and makes clear that attempts to achieve the same effect through indirect language is also prohibited, effectively closing any loopholes to the restriction. These changes would take effect immediately upon the bill’s enactment, with a transition period of up to three fiscal years at the HHS secretary’s discretion. The Senate bill adds that states will not be considered in violation if they are changing their taxes to comply with the new requirements and clarifies that these provisions only apply to the 50 States and Washington, D.C. (again excluding the U.S. territories in this provision).

Other provisions, including work requirements and cost sharing, have behavioral health-focused exemptions that align with the House bill. However, NABH continues to have concerns with the work requirement exemption for people with a “disabling mental disorder,” because this language could imply the need for a formal disability determination. We are also concerned that the Senate bill excludes a provision to extend premium tax credits for Marketplace plans.  

The NABH Government Affairs team is contacting senate offices to oppose the current draft and sent an Action Alert to NABH members urging them to contact their U.S. senators. We hope you will respond to the alert and encourage colleagues to do the same.  NABH is asking senators to:

• Eliminate provisions that (1) create restrictions on the use of provider taxes that states rely on to pay for their share of the Medicaid program, and (2) tie state-directed payments the Medicare payment rate, which is substantially lower than what many providers currently receive. These provisions would inhibit efforts to address systematic underpayment of behavioral healthcare providers and therefore perpetuate access challenges.
• Replace the existing exemption for people with “disabling mental disorders” to people with “serious mental illness.” The term “disabling” could suggest that people must receive a formal disability determination, a complex and potentially yearslong process that often does not capture those with even the most debilitating mental disorders. Using “serious mental illness,” a term more commonly used in both clinical practice and policy to describe disorders that substantially interfere with major life functions, would align with the intent of the existing exemption while eliminating unnecessary red tape.
• Extend the enhanced premium tax credit. If the enhanced tax credits expire, nearly 4 million people could discontinue receiving coverage through the Marketplace by 2026.

The Senate will not mark up its bill before a Senate floor vote and may vote on the legislation next week before it adjourns for the Independence Day recess.

HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest is Wednesday, July 2 and full applications are due Wednesday, Aug. 27.

JAMA Study Finds Addiction to Social Media, Mobile Phones & Video Games Linked to Higher Risk of Suicidal Thoughts

A study published in JAMA on Wednesday found that addiction to social media, mobile phones, and video games is linked to a higher risk of suicidal thoughts and behaviors.

Researchers examined data on more than 4,000 kids from an ongoing longitudinal study following them for years, starting at ages 9 to 10. It found that by age 14, about a third of the kids had become increasingly addicted to social media, about a quarter had become increasingly addicted to their mobile phone, and more than 40% showed signs of addiction to video games.

“It’s an important study and raising awareness about screen addiction,” Jason Nagata, M.D., a pediatrician specializing in adolescent screen use at the University of California, San Francisco, said in an announcement about the study. “It shows that elements of addiction related to screen use are more strongly predictive of poorer mental health and even suicide risk compared to just screen time. So, I think that it provides more nuance.

NIDA Director Nora Volkow Likens ‘the Addicted Brain to a House on Fire’ in Recent Blog

National Institute on Drug Abuse Director Nora Volkow, M.D. this week penned a blog post about her recent commentary in The New England Journal of Medicine that likened “the addicted brain to a house on fire—a crisis requiring urgent efforts to contain the damage and preserve life.”
 
Volkow authored the article with John Kelly, Ph.D. and Howard Koh, M.D. and noted that America’s drug crisis has demanded a sustained focus to extinguish those fires by expanding treatment access and overdose prevention and reversal strategies—and added that data show such efforts have helped overdose fatalities decline since 2023.
 
“However, a house that has had its addiction fire extinguished still smolders and can readily burst into flames again,” Volkow wrote. “After an initial remission of substance use disorder symptoms, it can take as much as 8 years and 4-5 engagements in treatment or mutual support groups to achieve sustained remission, and risk for meeting SUD criteria can remain elevated for several more years after that.”
 
Click here to read the full post.

Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards by Next Friday, June 27!

NABH is releasing two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT)compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

Fact of the Week

Lawmakers are considering changes to the Medicaid program that could lead to at least 8,241 and as many as 24,604 preventable deaths, according to a new study published in the Annals of Internal Medicine.   

NABH Submits FY 2026 IPF PPS Proposed Rule Comments to CMS

NABH on Tuesday submitted comments about the fiscal year 2026 inpatient psychiatric facility prospective payment system (IPF PPS) proposed rule, which includes several payment and quality reporting changes (for more information about the proposed rule, check out our NABH Analysis).
 
NABH’s comments included a recommendation for a greater rate increase to account for forecasting errors over the past few years, support for increases to rural and teaching facility adjustments, information on the need for increased health information technology investment, and feedback on various components of the inpatient psychiatric facility quality reporting program, among other topics.
 
“Generally, IPFs operate on thin margins, and Medicare rates that have failed to account for actual cost increases put an additional strain on these facilities,” the letter said. “Any financial shortfalls mean IPFs are struggling to invest in wage and benefit increases necessary to retain their existing workforce or hire additional staff, particularly considering the burnout among clinical and non-clinical personnel.”

House Committee Advances Military Construction, VA, and Related Agencies Appropriations Act

The House Appropriations Committee on Wednesday approved the Fiscal Year 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act in a near party-line vote of 36 to 27.
 
The bill would provide about $453 billion for the Veterans Affairs Department (VA), an increase of more than $50 billion from the 2025 level. It would spend $37 billion on non-VA community care, which is $3 billion more than the VA requested for fiscal 2026. In 2025, the amount was $22.5 billion.
 
The legislation now moves to the House floor for consideration and eventually will be reconciled with the Senate VA Appropriations bill. The Senate will not begin its appropriations process until after the budget reconciliation process concludes.
 
The VA has also announced that veterans enrolled in the VA and who have been referred to Community Care no longer need a second review from a VA clinician to seek treatment. The provision implements language from the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act. VA officials hope this change will accelerate access to community care.
 
In addition, the Dole Act prohibits VA administrators from overriding a VA physician’s referral for a patient to receive outside the VA. According to the law, the ban on administrative review will remain in place for two years, after which the VA must report on its effects to Congress.
 
The VA announced it would begin training employees to ensure the community care referral process is followed in compliance with the Dole Act, meaning implementation may vary by region. 

SAMHSA Publishes Resources on Medications for Opioid Use Disorder

On Wednesday, SAMHSA released three resources focused on delivering medications for opioid use disorder (MOUD) in nontraditional settings:

• Advisory: Expanding Access to Methadone Treatment in Hospital Settings, which focuses on how hospitals can improve care for patients with opioid use disorder (OUD) by leveraging an existing regulatory flexibility permitting them to provide methadone to patients with OUD who present to the hospital for a different medical condition without registering as an Opioid Treatment Program.
• Guidelines for Implementing Medications for Opioid Use Disorder Treatment in State Prisons, which discusses each MOUD, service delivery approaches, regulatory standards, implementation considerations, and methods to prevent care disruptions when individuals are released from incarceration.
• Advisory: Clinical Considerations for Methadone Treatment of Opioid Use Disorder in Correctional Facilities, which provides information on different models for delivering methadone to patients with OUD in carceral settings and factors for successful implementation.

MACPAC Releases June 2025 Report to Congress

The Medicaid and CHIP Payment and Access Commission (MACPAC) has released its June 2025 Report to Congress on Medicaid and CHIP, which addresses appropriate access to residential behavioral health treatment services for children with Medicaid coverage in Chapter 2 and access to medications for opioid use disorder (MOUD) in Medicaid in Chapter 3.
 
“States are required to provide treatment for individuals with disabilities, including serious mental illness and serious emotional disturbance, in community-based settings if appropriate,” the report noted. “However, for children who need more intense care or pose a safety risk to themselves or their families, it is important that they can access residential treatment when necessary.”
 
Meanwhile, the report’s third chapter highlights recent federal policies and funding that have affected access to MOUD, an overview of MOUD coverage and estimates of use, and barriers to MOUD. The Commission said it plans to investigate further the use of utilization management practices and how they affect Medicaid beneficiaries’ receipt of timely and effective care.

We Want to Hear from You! Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards

NABH is releasing two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

NABH 2025 Annual Meeting Photos Are Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month. NABH requests that you please credit photographer Chris Ferenzi if you use or share a photo.
 
And remember to mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A recent research letter published in JAMA Network reported the 988 lifeline was contacted 16,333,707 times between July 1, 2022 and Dec. 31, 2024. Of those contacts, 70% were calls, 18% were texts, and 11.9% were chats. Meanwhile, 11% of the contacts were re-routed to the Veterans Crisis Line.

House Passes SUPPORT Act; Legislation Moves to Senate for Consideration

The House on Wednesday passed H.R. 2483, the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) in a 366-57 vote to reauthorize bipartisan legislation that would prevent and treat illicit opioid use.
 
Thirty Democrats – many of whom serve on the House Energy and Commerce Committee and are upset with the administration’s cuts for federal addiction treatment programs – and 27 Republicans, mainly fiscal hawks in the House Freedom Caucus, voted against the House bill.
 
Congress reauthorized parts of the SUPPORT Act in a 2024 spending package, including making permanent the state Medicaid requirement to cover medication-assisted treatment for opioid use disorder. Lawmakers also expanded HHS’ state-by-state data collection efforts on behavioral health services and made permanent the state option to circumvent for certain patients the ban on using Medicaid funds for institutions of mental diseases. However, some parts of the 2018 SUPPORT Act remain unauthorized.
 
The legislation would reauthorize billions of dollars in funding for tackling the opioid crisis, which killed nearly 50,000 people last year, according to federal estimates. It would build on the original legislation Congress passed in 2018, which lawmakers have continued to fund even though it lapsed nearly two years ago.
 
Before moving the bill to the Senate, the House approved several amendments and narrowly rejected one amendment. An amendment from Rep. Jen Kiggans (R-Va.) would require the Office of the National Coordinator to convene a public roundtable to examine how the expanded use of electronic health records (EHR) among mental health and substance use disorder service providers can improve outcomes for patients in mental health and substance use disorder settings, and how best to increase EHR adoption among such providers, passed favorably.
 
Rep. Brittany Pettersen’s (D-Colo.) amendment would have codified Biden-era budget neutrality requirements for Section 1115 waivers. The vote failed 213-213, with two Republicans voting to support the amendment.
 
The legislation now heads to the Senate, where the Health, Education, Labor and Pensions Committee in 2023 advanced a version of the bill in a 19-1 vote.

Senate Considers Budget Reconciliation Bill

Following the House’s passage of the budget reconciliation bill, the Senate is now considering the “One Big Beautiful Bill” with the goal of passing the legislation by Congress’ July 4 recess.
 
Senate committees are reviewing their respective portions of the legislation and will soon release potentially amended versions of the House bill which must be reconciled.
 
Also this week, the Congressional Budget Office (CBO) estimated the House-passed bill will add $2.4 trillion to the federal debt over the next decade. The agency estimated the proposed tax cuts in the plan would decrease revenues by more than $3.6 trillion during that period.

CBO estimates Medicaid would be cut $863 billion over 10 years under the last-minute changes to the House reconciliation bill and 10.9 million people would be without health insurance in 2034, about a $75 billion increase from its initial Medicaid savings calculation and 2.3 million more people predicted to become uninsured.
 
CBO also estimates a total of 16 million people could lose health insurance if a House-passed budget bill becomes law, a number Republicans dispute. Other effects of the budget reconciliation bill’s policies that CBO analyzed include:
 
Work requirements: Requirements that recipients work, volunteer or go to school, the largest source of savings in the bill at $344 billion, and would lead to 4.8 million people losing health insurance.
 
Provider tax moratorium: The bill would place a moratorium on any new taxes that states levy on their hospitals. States can use revenue from the taxes to draw down more federal money for Medicaid and make hospitals whole by charging higher payment rates. The moratorium would likely lead states to reduce available resources for their Medicaid programs and change enrollment policies to “make enrollment more challenging to navigate,” the report said. It is anticipated that 400,000 people would lose insurance through 2034.
 
Return of Affordable Care Act (ACA) payments: A last-minute change to the bill returns payments to insurers to reimburse them for covering reduced cost-sharing for low-income customers. However, it would likely end a loophole that plans and states have used to recoup the cost of cost-sharing reductions by inflating the value of income-based tax credits. CBO estimates that 300,000 people would lose their coverage by 2034.
 
Changes to ACA eligibility: The bill includes several other ACA changes, such as ending a special enrollment period for people who earn 150% or less of the federal poverty level, erasing a 2024 rule that enabled them to enroll at any point in the year. This provision would lead to 200,000 losing insurance through 2034. The bill would also prohibit some immigrants from getting income-based subsidies on the exchanges. This would lead to 1 million people losing coverage. Stricter verification requirements for ACA customers to qualify for subsidies would also cause 700,000 people to drop off coverage through 2034.
 
Last month NABH sent a letter to congressional leaders that outlines our concerns about the measure’s healthcare provisions and provides other feedback about the budget reconciliation bill. NABH will continue to focus on members of the influential Senate Finance Committee and other senators who have expressed publicly their concern to make these changes.
 
And NABH will continue to use our grassroots platform to contact members of the Senate Finance Committee to request these legislative changes. We encourage you to act and to engage other colleagues in this effort!

CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT)compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

FTC Wants to Use Enforcement Authority to Hold Social Media Companies Accountable

The Federal Trade Commission’s (FTC) three commissioners want to use the agency’s enforcement authority to hold social media companies accountable for how their platforms affect children’s mental health, Politico and other news outlets reported this week.
 
“As President Trump has emphasized, it’s to our benefit that the United States continue to be the global leader in this kind of innovation. And the President is correct,” FTC Chair Andrew Ferguson said at a policy workshop Wednesday in Washington, according to Politico.
 
The FTC hosted the all-day workshop, The Attention Economy: How Big Tech Firms Exploit Children and Hurt Families, which featured remarks from other commissioners as well as Sens. Marsha Blackburn (R-Tenn.) and Katie Britt (R-Ala.).

SAMHSA Publishes Guidance on Adult Benzodiazepine Use

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released a “Dear Colleague” letter offering guidance on benzodiazepine (BZD) use in older adults.
 
Benzodiazepines are commonly prescribed for anxiety and insomnia; however, older adults face higher risks of adverse events from long-term use, including falls, cognitive decline, and drug interactions. The letter highlights the public health importance of reducing long-term benzodiazepine use among older adults and promotes patient-centered, evidence-informed strategies for evaluating ongoing BZD use.

Federation of American Hospitals President and CEO Chip Kahn to Retire at Year’s End

Chip Kahn, president and CEO of the Federation of American Hospitals for the past 24 years, announced Friday he will retire at the end of 2025.
 
Kahn is the third Federation CEO since the association was established in 1966 and led his organization through five presidential administrations and 13 Congresses. Modern Healthcare selected Kahn to the publication’s “100 Most Influential” list each year since the list was first published 23 years ago.
 
“What an honor to have an opportunity for a quarter century – and during a consequential period of health policy making – to be the play caller for this important hospital sector,” Kahn said in his announcement. “Much has been accomplished,” said Kahn. “Now it is time for a career turn to work on policy from another vantage point. I look forward to engaging in efforts to foster health care affordability, coverage, and quality improvement.”

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

NABH 2025 Annual Meeting Photos Now Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month. NABH requests that you please credit photographer Chris Ferenzi if you use or share a photo.
 
And remember to mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

In a cross-sectional study of 198,417 female parents of children aged 0 to 17 years, researchers observed large declines in self-reported mental health and small declines in self-reported physical health from 2016 to 2023, according to a new report in JAMA Internal Medicine. Mental health declines occurred across all socioeconomic subgroups; however, mental and physical health status was significantly lower for single female parents, those with lower educational attainment, and those with publicly insured children. The study concluded investments are needed to investigate and address the underlying causes of mental health decline among U.S. mothers, particularly for those of low socioeconomic status.

NABH Sends Comments to DOJ About Anticompetitive Regulations

NABH this week sent a letter to U.S. Attorney General Pamela Bondi suggesting opportunities to
to remove, modify, or clarify applying burdensome regulatory requirements that impede behavioral healthcare services to millions of Americans with mental and substance use disorders.
 
The letter covered a variety of topics, including Medicare requirements for inpatient psychiatric facilities, applying the Emergency Medical Treatment and Labor Act to psychiatric hospitals, the Drug Enforcement Administration’s requirements for mobile components to narcotic treatment programs, and other NABH priority issues.
 
Click here to read the full letter.

GAO Study: CMS Oversight of Prior Authorization Criteria Should Target Behavioral Health Services

The Government Accountability Office (GAO) this week released a report recommending the Centers for Medicare & Medicaid Services’ (CMS) target behavioral health services in its program audit prior authorization denial reviews and planned reviews of internal coverage criteria.
 
“According to CMS, processes like prior authorization are designed to help MA (Medicare Advantage) organizations minimize unnecessary services, thereby helping to protect beneficiaries and contain costs,” the report noted. “However, studies have indicated that prior authorization and use of internal coverage criteria may hinder MA beneficiaries’ access to care,” it continued. “CMS is responsible for ensuring that MA beneficiaries generally receive at least the same coverage of benefits as beneficiaries enrolled in traditional fee-for-service Medicare, which does not currently require prior authorization for any behavioral health services.”
 
Click here to access the full report, its highlights, and the GAO’s recommendations.

JAMA Examines VA-Purchased Community Care for U.S. Veterans with Mental Health Conditions

A new JAMA study concluded that among U.S. veterans using Community Care (CC), those with mental health conditions may be less satisfied with CC, emphasizing a need for targeted efforts to improve CC for this subpopulation.
 
Researchers from the University of Pennsylvania examined data from 231,869 veterans surveyed from 2016 to 2021 and found that those with versus those without mental health conditions reported significantly lower ratings of experiences with CC in nine domains, including a 1.8-point lower overall satisfaction rating.
 
“Although ratings of CC improved over time, differences in experiences persisted between veterans with and without MHC,” the study said.

NABH 2025 Annual Meeting Photos Now Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month.
 
Please be sure to credit photographer Chris Ferenzi if you use or share a photo.

ICYMI: NABH Annual Meeting Presentations Are Available

NABH has posted all 2025 Annual Meeting speaker presentations for which we received permission on our Speakers & Presentations page. We will send a link to our Annual Meeting photos at a later date.
 
Please mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A new study published in Health Affairs found that overall, 6.4% of Medicaid Emergency Department visits were associated with a claim for MOUD within 30 days, based on Medicaid claims data from 2016-2020. This rate was highest among non-Hispanic White (7.3) patient%) s and lowest among non-Hispanic Black (4.3%) and Hispanic (4.9%). 

House Passes Reconciliation Bill That Includes Significant Medicaid Changes

The House early Thursday passed President Trump’s sweeping budget reconciliation bill in a 215-214 vote after the House Rules Committee passed a 42-page amendment to the legislation. Notably, the bill includes several significant restrictions on Medicaid eligibility and financing.
 
The Senate will now consider the legislation and is expected to make changes to it.
 
Meanwhile, the Congressional Budget Office (CBO) has yet to provide information about the effects of the House bill, although the CBO’s latest estimate notes that changes in the House Energy and Commerce Committee’s jurisdiction – which includes Medicaid and Marketplace plans – would produce more than $900 billion in savings during the next decade. An earlier analysis estimated that 8.6 million people could become uninsured by 2034.
 
NABH has several major concerns about the bill, including the:

• Moratorium on creating new provider taxes;
• Limits to future state-directed payments;
• Problematic language in behavioral health exemptions to community engagement requirements; and
• Lack of extension to enhanced premium tax credits for Marketplace plans.

NABH sent a letter to Senate leaders today, May 23, that articulates these concerns. We are watching this legislative process closely as the Senate considers the bill, and we will continue to provide updates as the situation evolves.

White House Releases Report on Childhood Chronic Diseases

Also on Thursday, the White House released Make Our Children Healthy Again, a 73-page report from President Trump’s Make America Healthy Again Commission that examines four areas: (1) poor diet, (2) aggregation of environmental chemicals, (3) childhood behavior in the digital age, and (4) overmedicalization.
 
The report covers various topics that impact mental health, such as technology and social media use, poor sleep, chronic stress, family dynamics, and nature exposure. It also asserts various ways in which children are over-diagnosed with mental disorders, including attention-deficit/hyperactivity disorder, depression, and anxiety, as well as over-treated with stimulants, antidepressants, and antipsychotics.
 
Finally, the report mentions a controversial theory that some interventions and approaches, including therapy, social-emotional learning, and trauma-informed care, could over-pathologize emotional experiences, leading to increases in anxiety and depression.

CMS Resource Updates Improper Payment Rate and Denial Reasons for 2023 Reporting Period

The Centers for Medicare & Medicaid Services’ (CMS) Medicare Provider Compliance Tips – a resource from the Medicare Learning Network – reports that the improper payment rate for outpatient psychiatry services was 13.5% with a projected improper payment amount of $186.1 million in 2023, according to the 2023 Medicare Fee-for-Service Supplemental Improper Payment Data.
 
The resource – which includes tips for a host of specialty providers – outlines more information and policy requirements for physicians and non-physician practitioners who bill for outpatient psychiatry services.

Help NABH Develop a Behavioral Health Tech Apprenticeship!

The NABH Education and Research Foundation thanks all who attended last week’s NABH Annual Meeting workforce panel about NABH’s new project to develop and sponsor a behavioral health technician registered apprenticeship program with the U.S. Labor Department.

If you didn’t attend the panel discussion – or if you attended and didn’t participate in the panel’s live poll – please take a moment to submit this four-question survey by Wednesday, May 28 to let us know 1) if you would like to help NABH with this new initiative, and 2) if so, how you would like to participate.

For more information, click here to learn why NABH urges its members to support this model and here to learn NABH’s ten steps to apprenticeship. As always, thank you for your time!

ICYMI: NABH Annual Meeting Presentations Are Available

Last week NABH posted all 2025 Annual Meeting speaker presentations for which we received permission on our Speakers & Presentations page. We will send a link to our Annual Meeting photos at a later date.
 
Please mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A new study from Avalere Health found opioid use disorder costs businesses, governments, and households almost $1 trillion per year and that treatment with medications can lower costs.

The NABH team thanks all its members who have served in the U.S. Armed Forces and wishes everyone a safe and relaxing Memorial Day weekend!

2025 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2025 Annual Meeting that starts Monday, May 12 in Washington, D.C.
 
This year’s Annual Meeting focuses on Behavioral Health is Everyone’s Concern: Constant Care, Changing Times, and our presenters will explore the federal government’s behavioral health strategy, the connection between behavioral health and chronic conditions, practical ways to improve your workforce, how states are advancing behavioral health, the current telehealth landscape, NABH’s new initiatives, and more.

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

Be Sure to Access the 2025 NABH Annual Meeting Mobile App

Again this year, attendees will have access to all Annual Meeting programming and materials through NABH’s web-based app.
 
Early Monday, NABH will send all attendees an Annual Meeting alert with a link to the app that includes information about sessions, speakers, meeting room locations, registrants, exhibitors and sponsors, Hill Day resources, and more. Attendees can also access the link through a QR code near the Registration Desk at the Annual Meeting.

There’s Still Time to Register for Hill Day 2025!

It’s not too late to register for Hill Day 2025 on Wednesday, May 14 from 10:00 a.m. – 2:30 p.m. ET.
 
As always, Hill Day is an excellent opportunity for NABH members to meet personally with Members of Congress and their staff to share our association’s advocacy priorities.
 
How it Works:

After you register and indicate that you will participate in Hill Day, you will receive an email  from the NABH government relations team to better tailor your experience. They will match you with legislators who represent your facility’s footprint. Please email Emily Wilkins with any questions.

CMS Deputy Chief Medical Officer Shari Ling, M.D. to Kick Off 2025 Annual Meeting on Monday

The Centers for Medicare & Medicaid Services (CMS) Deputy Chief Medical Officer Shari M. Ling, M.D. will kick off this year’s Annual Meeting on Monday, May 12.

Dr. Ling serves in the Center for Clinical Standards and Quality, where she is responsible for assisting the agency’s chief medical officer to pursue higher quality healthcare, healthier populations, and lower cost through quality improvement. Dr. Ling’s long-standing focus has been to achieve meaningful health outcomes through delivery of high quality, beneficiary-centered care across all care settings, with a special interest in the care of persons with multiple chronic conditions and functional limitations and reducing health disparities.

At the U.S. Health and Human Services Department (HHS), Dr. Ling represents CMS on the HHS Multiple Chronic Conditions Workgroup and serves as the clinical sub-group lead for the HHS National Alzheimer’s Project Act.

At the Annual Meeting, Dr. Ling will discuss the connection between behavioral health within the context of preventive care and chronic conditions. Please help us welcome her in the Salamander Washington, DC’s Grand Ballroom on May 12 at 3 p.m. ET.

Learn About NABH’s New Project to Sponsor a Behavioral Health Technician Apprenticeship

Immediately following Dr. Ling’s presentation at 3:45 p.m., NABH Immediate Past Board Chair Frank A. Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers Health University Behavioral Health Care and senior vice president of the Behavioral Health and Addictions Service Line at RWJBarnabas Health, will moderate a panel discussion about NABH’s new project to sponsor a behavioral health technician Registered Apprenticeship Program (RAP) with the U.S. Labor Department (DOL).
 
The RAP panel will feature 2025 NABH Board Chair Jim Shaheen, CEO of New Season/Colonial Management Group; John Pallasch, former assistant secretary for employment and training at DOL and founder and CEO of workforce consultancy One Workforce Solutions; and independent consultant Kristen Weeden, who began her career as a child protective case worker. The panelists will explain this new program, how your system will benefit from it, and ways you can help NABH in this process. 

Learn How to Strengthen Supervisor Competencies with Yale Behavioral Health’s Scott Migdole

Day 2 of the Annual Meeting will start on Tuesday, May 13 at 9 a.m. with Yale Behavioral Health & Yale Program on Supervision COO Scott Migdole, M.S.W., LCSW, who will share Yale’s model for strengthening supervisor competencies and shaping supervision practice in health and human service organizations, including hospitals. Migdole’s presentation will cover topics such as the basics of a supervision model, phases and functions of supervision, and managing from the middle.

Explore Behavioral Healthcare Advancements and Challenges in the States with the National Academy for State Health Policy’s Hemi Tewarson

Immediately following Migdole’s presentation, NABH Vice President of Policy Dan Schwartz will engage in a fireside chat with Hemi Tewarson, J.D., M.P.H., executive director at the National Academy for State Health Policy (NASHP). They’ll discuss how NASHP’s work can help NABH members, the effects of potential Medicaid cuts on states, behavioral healthcare advancements at the state level, how states are addressing the nation’s ongoing opioid crisis, the recent shift in states’ top behavioral health priority away from the opioid crisis to mental health, and more. 

Examine Today’s Telemedicine & Telehealth Landscape with the American Telemedicine Association’s Kyle Zebley

At 4 p.m. on Tuesday, the American Telemedicine Association’s Kyle Zebley will offer a presentation that will highlight the present telehealth landscape, the congressional perspective on telehealth services, the U.S. Drug Enforcement Administration and remote prescribing of controlled substances, Medicare telehealth flexibilities, and more.  

Learn About NABH’s New Advocacy Tool with the NABH Government Relations Team

After Zebley’s presentation, NABH Vice President of Government Relations Andrew Dodson and Director of Government Relations Emily Wilkins will conclude Tuesday’s presentations with a discussion about NABH’s new advocacy tool SparkInfluence and help members prepare for Hill Day on Wednesday, May 14.

Fact of the Week

2025 marks the last year NABH will host its Annual Meeting at the Salamander Washington, DC, previously the Mandarin Oriental Washington, DC. Please mark your calendars and join us next
March 2-4 at The Ritz-Carlton Washington, DC for the NABH 2026 Annual Meeting!
 
The NABH team wishes everyone a safe trip to Washington, and we look forward to seeing you soon!
 
Please note: NABH will not publish CEO Update next week and will publish the next issue on May 23.
For questions or comments about this CEO Update, please contact Jessica Zigmond.

House Energy & Commerce Committee Expected to Start FY 2026 Budget Bill Mark-Up on May 12

Continuing – and contentious – negotiations have caused the House Energy and Commerce Committee to postpone its planned markup of the fiscal year (FY) 2026 reconciliation package to Monday, May 12.
 
The Energy & Commerce Committee is considering multiple, significant proposals that would result in reduced federal funding for Medicaid. NABH has focused its advocacy efforts on members of the Energy & Commerce Committee, which must find $880 billion in savings, according to the recently passed FY 2026 budget resolution.
 
These savings will likely result in Medicaid cuts that would have a devastating effect on behavioral healthcare providers, and, most importantly, patients.
 
NABH’s message to Members of Congress urges them to oppose:

• Reducing provider taxes,
• Reducing state-directed payments,
• Capping Medicaid expansion, and
• Mandating work requirements.

Medicaid cuts would directly or indirectly limit or eliminate access to behavioral healthcare services for current beneficiaries in states that must reduce the size of their Medicaid programs due to some combination of these cuts.
 
In addition to government relations team outreach, NABH is also using a new grassroots platform that allows NABH members located in the congressional districts of Energy & Commerce Committee members to quickly and easily e-mail their congressional representative with a prepared letter that opposes Medicaid cuts. NABH members also have the option to personalize their correspondence.
 
NABH will make the same request of all NABH members next week in another action alert.
 
Medicaid cuts and the effects those cuts would have on our patient population will also be the main topic for discussion when NABH members head to Capitol Hill on our annual Hill Day, Wednesday, May 14.

House Energy & Commerce Committee Passes SUPPORT Act

The House Energy & Commerce Committee this week passed H.R. 2483, the SUPPORT for Patients and Communities Reauthorization Act of 2025 which funds critical treatment and recovery programs for opioid abuse and expands access to addiction medicines such as buprenorphine.
 
What typically would have been a unanimous vote resulted this time in a nearly party line vote of 36 -13. The original law authorizing overdose-fighting programs expired more than 18 months ago and Congress has continued to fund it.
 
The Energy and Commerce Committee approved the same bill unanimously in July 2023; however, a majority of Democrats opposed it on April 29, underscoring their frustration that the Trump administration’s Department of Government Efficiency’s cost-cutting campaign is undermining the few areas of bipartisan agreement that still exist in Washington.

Last year, overdose deaths fell from highs that exceeded 110,000 a year during the COVID-19 pandemic, according to the Centers for Disease Control and Prevention. Still, more than 80,000 Americans died from an overdose during the 12 months ending last November.

The original SUPPORT Act authorized $20 billion in treatment, prevention and recovery funding. Its reauthorization was part of a major bipartisan, bicameral health care package during the first Trump Administration. The bill next goes to the House Floor, before consideration in the Senate.

CMS Considers Utilization-Management Changes

Modern Healthcare reported on Tuesday, April 29 that the Centers for Medicare & Medicaid Services (CMS) is considering options to reduce delays in care associated with utilization management controls across health plans.
 
In particular, the agency is exploring ways to limit the use of prior authorization, as well as automate coverage determinations. This effort aligns with statements made by Mehmet Oz, M.D. during his confirmation hearing for CMS administrator, where he suggested streamlining the prior authorization process.

CMS Deputy Chief Medical Officer Shari Ling, M.D. to Kick Off 2025 Annual Meeting

NABH is pleased to announce the CMS Deputy Chief Medical Officer Shari M. Ling, M.D. will kick off this year’s Annual Meeting on Monday, May 12!
 
Dr. Ling serves in the Center for Clinical Standards and Quality (CCSQ), where she is responsible for assisting the agency’s chief medical officer to pursue higher quality healthcare, healthier populations, and lower cost through quality improvement. Dr. Ling’s long-standing focus has been to achieve meaningful health outcomes through delivery of high quality, beneficiary-centered care across all care settings, with a special interest in the care of persons with multiple chronic conditions and functional limitations and reducing health disparities.

At the U.S. Health and Human Services Department (HHS), Dr. Ling represents CMS on the HHS Multiple Chronic Conditions Workgroup and serves as the clinical sub-group lead for the HHS National Alzheimer’s Project Act.

A gerontologist, Dr. Ling received her medical training at Georgetown University School of Medicine and her clinical training in Internal Medicine and Rheumatology at Georgetown University Medical Center. She also completed Geriatric Medicine studies at Johns Hopkins University and received her training in Direct Service from the Ethel Percy Andrus Gerontology Center at the University of Southern California and served as the co-director of the Andrus Older Adult Counseling Center. Dr. Ling volunteers at the Veterans Administration Medical Center in Baltimore.

At the NABH Annual Meeting, Dr. Ling will discuss the connection between behavioral health within the context of preventive care and chronic conditions. Please help us welcome her in the Salamander Washington, DC’s Grand Ballroom on May 12 at 3 p.m. ET.

View This Year’s Annual Meeting Exhibitors & Sponsors!

NABH appreciates the generous support of our exhibitors and sponsors, whose valuable products and services help NABH members deliver quality behavioral healthcare every day to those who need it.
 
New in 2025 is NABH’s Silver Sponsorship, which offers exhibitors and sponsors an opportunity to interact with NABH members during our association’s committee meetings for 30 minutes.
 
You can view a list of our exhibitors and sponsors on our Annual Meeting homepage, and please make time to visit with them at the Annual Meeting from May 12-14 at the Salamander Washington, DC.

Manatt to Host Webinar on Medicaid Cuts on Children and Youth Next Week

Research firm Manatt will host an hourlong webinar next week that will examine the effects of Medicaid cuts on the nation’s children.
 
As Manatt reports, Medicaid covers two in five children and nearly half of all children with special healthcare needs. Despite the extensive research that shows that Medicaid coverage of children contributes to better health outcomes and improved long-term effects on health and educational attainment in adulthood, Congress is actively considering large reductions in Medicaid through the budget reconciliation process.
 
Federal proposals continue to evolve; these include: imposing caps on federal Medicaid funding, eliminating the enhanced federal funding states receive to cover expansion adults (which includes parents), mandating work reporting requirements as a condition of eligibility for parents and childless adults, reducing states’ ability to rely on provider taxes to pay a portion of their share of Medicaid costs, and restricting the ability for states to direct managed care plans to boost provider payments to strengthen access to care.
 
The webinar is scheduled for Tuesday, May 6 from 3:30 p.m. to 4:30 p.m. ET. Click here to register.

Fact of the Week

The National Institutes of Health has funded six projects to develop, test, and validate outcome-focused quality measures for mental health to increase the accessibility and availability of evidence-based mental health treatments. Click here to learn about these projects.

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