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Author: Shelby Liebler

NABH Insider: August 18, 2026

Written by Shelby Liebler on . Posted in NABH Insider.

State of Play

Last week, NABH sent out letters to 42 states outlining the association’s recommendations for state-level implementation of the Medicaid Community Engagement Requirement Interim Final Rule, which takes effect on January 1, 2027.

In our letters, we urge state Governors and Medicaid Directors to make key implementation decisions that help ensure beneficiaries with behavioral health conditions maintain their coverage if they are unable to meet community engagement requirements.

NABH recommends that states use ex parte verification to automatically exclude individuals who have accessed intensive behavioral healthcare services within the last 12 months from the work requirements; allow enrollees to self-attest to medical frailty; and adopt the short-term hardship exception for beneficiaries.

We encourage NABH members to use our letters in your state advocacy efforts. Access the full list of the letters here and contact Dan Schwartz (dan@nabh.org) with any questions.

Take Action

2026 NABH Membership Directory: Update your organization’s information in our Membership Directory by Monday, Aug. 31 using the link you received at the beginning of August from mail@nabh.org. Contact Maria Merlie (maria@nabh.org) if you need the update link resent or have questions.

Accessible SUD Care Workgroup: The initial information session for NABH’s new Accessible SUD Care Workgroup will be held on Friday, August 28, from 12 – 12:30pm ET. We encourage participation from both individuals who do and do not primarily work on SUD treatment. Please contact Dan Schwartz (dan@nabh.org) if you would like to attend or have any questions.

On Our Radar

Behavioral Health Business: How Medicaid Requirements Could Fail Patients in Recovery
CMS’ restrictive “medical frailty” definition and the administrative burden of community engagement requirement implementation may leave long-term SUD patients without coverage and at a higher risk of symptom recurrance.

CT Mirror: Connecticut’s First State-funded Methadone Vans Expand Access to Treatment
As the state’s first mobile methadone units begin rolling out, providing care to those who couldn’t otherwise reach a clinic, Connecticut behavioral health providers talk about the impact of investing in opioid treatment programs that provide well-rounded care.

Arizona Center for Investigative Reporting: Arizona Promised Secure Treatment for its Sickest Psychiatric Patients. Seven Years Later, it Still Doesn’t Exist.
The story of Larry Bootsma, who died of an overdose while unable to access consistent treatment, illustrates the importance of fighting for mental health parity to ensure coverage for the entire behavioral healthcare continuum.

Helpful Resources

AI in Behavioral Healthcare Webinar: Becker’s Hospital Review and The Joint Commission will host a webinar entitled “A Guide to Responsible Use of AI for Behavioral Health Settings” on Wednesday, September 16 from 1pm EST – 2pm EST.

Stay Connected

If your organization has had a recent milestone, success story, or achievement, please share them through our Microsoft Form. We would love to feature it in our Member Spotlight series across NABH’s social media channels or in an upcoming NABH Insider.

For questions or comments about this NABH Insider, please contact Shelby Liebler.   

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CMS Issues IPF PPS Final Rule

Written by Shelby Liebler on . Posted in Alerts, News & Insights.

The Centers for Medicare & Medicaid Services (CMS) today issued the Fiscal Year 2027 Medicare Inpatient Psychiatric Facility Prospective Payment System Final Rule (CMS-1847-F). The final rule includes changes to payments under the Inpatient Psychiatric Facility (IPF) Prospective Payment System (PPS) and makes changes to the IPF Quality Reporting Program.

Despite NABH’s opposition, CMS has finalized the proposed IPF patient assessment instrument (IPF-PAI). NABH’s comments are cited throughout the rule, noting the proposed IPF-PAI is clinically inappropriate, does not improve the outcomes for IPF patients, and is an enormous burden for psychiatric hospitals and units.

CMS finalized the instrument as proposed with a few modifications to the timeline and payment requirements. CMS has pushed back mandatory reporting from October 1, 2027 to July 1, 2028. Additionally, instead of requiring 100% IPF-PAI reporting for 80% of patients, CMS lowered the completeness requirement to 50% of the IPF-PAIs submitted at the start of reporting. Beginning with the CY 2030 reporting period, CMS will increase the reporting threshold to 70% of patients. For IPFs not meeting the completeness requirement, CMS will reduce payments by 2%.

While we are pleased with the delayed reporting and lowered completeness requirement, NABH is disappointed CMS did not seek to delay the IPF-PAI indefinitely while NABH and its members can support development of a clinically appropriate tool. We will continue to work with CMS to urge them to further delay and update the IPF-PAI.

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National Association for Behavioral Healthcare Names Tanika Pradhan as Vice President of Communications

Written by Shelby Liebler on . Posted in News & Insights, News Releases.

July 27, 2026

The National Association for Behavioral Healthcare (NABH) today announced that Tanika Pradhan has joined the organization as Vice President of Communications.

A seasoned communications and public relations leader, Pradhan brings nearly a decade of experience driving award-winning communications campaigns, with expertise in mental, behavioral, and community healthcare advocacy.

“We’re thrilled to welcome Tanika to NABH’s leadership team,” said Scott Dziengelski, NABH President and CEO. “She brings a thoughtful, strategic approach to communications that will strengthen our advocacy efforts, elevate NABH’s voice, and expand our impact on behalf of behavioral healthcare providers and the patients they serve.”

Pradhan joins NABH from ROKK Solutions, a bipartisan public affairs firm in Washington, D.C., where she advised organizations across the private, public, and nonprofit sectors on integrated communications and strategic positioning. She previously worked at Weber Shandwick, a global public relations agency.

Pradhan earned a master’s degree in Communications, Culture, and Technology from Georgetown University and a bachelor’s degree from Knox College.

CEO Update | 283

Written by Shelby Liebler on . Posted in CEO Updates.

NABH Welcomes New VP of Communications

The NABH team is thrilled to welcome Tanika Pradhan as our new Vice President of Communications. A seasoned strategic leader, Tanika brings nearly a decade of experience leading high-profile communications campaigns, with expertise in mental, behavioral, and community healthcare. She joins NABH from ROKK Solutions, a bipartisan public affairs firm in Washington, D.C., and previously worked at Weber Shandwick, a global public relations agency. Tanika holds a Master’s degree in Communications, Culture, and Technology from Georgetown University.

You can reach Tanika at tanika@nabh.org. We’re excited to have her on board!

NABH Submits Comments to CMS on State Directed Payments (SDP) Rule

On Tuesday, NABH submitted comments to CMS on the Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments proposed rule. In our comments, we urged CMS not to finalize their proposal to cap SDPs for behavioral healthcare settings at the average Medicare rate.

NABH asserted that CMS has exceeded the Congressional intent of the Working Families Tax Cut (WFTC) legislation (Public Law 119-21, H.R. 1) by extending the capping of SDPs at the average Medicare rate to institutions for mental diseases (IMDs) and non-hospital outpatient behavioral healthcare services. We emphasized that extending SDP caps beyond the WFTC to behavioral healthcare settings will harm access to and quality of care.

Seperately, NABH also joined a letter from hospital-affiliated organizations urging CMS to reconsider their SDP methodology and ensure that states can still use SDPs to promote value. We also signed onto a coalition letter led by colleagues at the Legal Action Center calling on CMS to reconsider the proposed SDP caps for mental health and substance use disorder treatment.

If CMS finalizes the rule as proposed, SDPs for all services in all states would be capped at the average Medicare rate for rating periods beginning on or after Jan. 1, 2029. As CMS reviews the submitted comments, NABH will continue its advocacy efforts with Congress and the Administration on this issue and will keep members informed when the final rule is released.

NABH in the News: Behavioral Health Parity

This week, Behavioral Health Business released a new article entitled “What to do with Behavioral Health’s Paper Tiger Parity Laws.” Scott Dziengelski, NABH President & CEO, spoke with reporter Ashleigh Hollowell for the story and discussed the importance of treating mental health parity as a consumer protection law and ensuring that violations can be documented, tracked, and enforced.

Dziengelski also spoke about considering steps forward on parity, saying “if our consumer protection laws are no longer protecting consumers the way we want them to, at some point, we have to revisit the fact that we may need new consumer protection laws.”

Update on MOTAA 2.0

On Tuesday, July 21, Representatives Donald Norcross (D-NJ), Mike Lawler (R-NY), and Paul Tonko (D-NY) introduced the Modernizing Opioid Treatment Access Act (MOTAA 2.0). This House bill follows the Senate introduction of MOTAA 2.0 by Senators Ed Markey (D-MA) and Rand Paul (R-KY) on June 25.

Scott Dziengelski was quoted in a Behavioral Health Business article last week about MOTAA 2.0. He discussed the importance of focusing on expanding the Opioid Treatment Program (OTP) model to ensure safe, regulated access to methadone for those in recovery.

“What we really need to be thinking about is not how do we get methadone into areas, but how do we get the OTP model into different places … we don’t want to lose those successful parts of the model under the MOTAA 2.0 format,” Dziengelski said.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027, at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related virtual and in-person events:

Fact of the Week

Rates of depression, anxiety, and ADD/ADHD among college students are at a four-year high, according to a recent report released by UnitedHealthcare. Almost 70% of college students reported experiencing a mental or behavioral health concern in the past year.

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

CEO Update | 282

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NABH Joins Others in Comments on Proposed OMB Regulations

NABH and other hospital-related associations on Monday sent a comment letter to the Office of Management and Budget (OMB) regarding a proposed rule overhauling 2 C.F.R. Part 200, the “uniform guidance” that governs the administration of all federal grants and cooperative agreements.

OMB has proposed sweeping changes to the policy, which could implement political review of grant awards, expand termination authority for OMB, and limit grant-funded research on health disparities. In the comment letter, the associations address how these changes could impede operations of healthcare providers across the care continuum and disrupt patient care. The letter additionally requests clarity on the scope of the proposed rule.

NABH is monitoring this proposed rule and will provide updates to members as they become available.

NABH Responds to Essential Health Benefits RFI

NABH on Wednesday responded to a request for information (RFI) from the Centers for Medicare & Medicaid Services (CMS) regarding opportunities to strengthen the Essential Health Benefits (EHB) framework.

The Affordable Care Act included a requirement for non-grandfathered individual and small group (except fully-insured) private health plans, as well as Medicaid Alternative Benefit Plans, to cover 10 benefit categories, known as EHB. One EHB category is “mental health and substance use disorder services, including behavioral health treatment.” States select an EHB benchmark plan, which serves as the basis for EHB design across applicable plans offered in the state.

In the letter, NABH urges CMS to strengthen the scope of benefits included under the Behavioral Health EHB to consider the entire behavioral healthcare continuum, reflect evolving standards in care, and help beneficiaries overcome barriers to care. The letter recommends that CMS align the scope of benefits with the generally accepted standards of care, including the ASAM Criteria and LOCUS, and conveys that coverage for all levels of care ensures that enrollees receive appropriate and effective treatment while promoting efficient resource use.

CMS Releases CY 2027 Physician Fee Schedule Proposed Rule

CMS on Monday released the calendar year (CY) 2027 Physician Fee Schedule (PFS) proposed rule. The PFS provides Medicare rates for most physician and other practitioner services in a variety of settings. CMS sets rates for physicians and practitioners who are qualifying alternative payment (APM) participants (QPs) and one for physicians and practitioners who are not QPs.

Due to a temporary increase of 2.50% for CY 2026 in the PFS conversion factors authorized by the Working Families Tax Cut (WFTC) legislation, CMS is proposing a decrease in payments to physicians by reducing the QP conversion factor by 1.19% and the non-QP conversion factor by 1.68% in CY 2027 compared to CY 2026.

The proposed rule seeks clarification on whether new Medicare codes are necessary for outpatient providers to bill for ASAM Level 1.7, which is medically Managed Outpatient Treatment. CMS has previously established codes (HCPCS codes G2086-G2088) that align with ASAM Level 1.5, Clinically Focused Outpatient Therapy.

CMS also proposes new HCPCS codes and payment for shared medical appointments for physicians to address multiple concerns, including co-occurring behavioral health and prevention and treatment of other chronic illnesses. CMS also proposes to increase payment for smoking and tobacco use cessation and screening, brief intervention, and referral to treatment (SBIRT) services.

We will continue to review the proposed rule and prepare comments, which are due September 14, 2026. Contact Sarah Steverman with questions.

House Ways & Means Committee Bill Markup

The House Ways & Means Committee Wednesday held a markup and advanced multiple bills out of committee, including the Improving Seniors’ Timely Access to Care Act introduced by Rep. Mike Kelly (R-PA) and a bipartisan coalition of lawmakers.

The bill aims to require Medicare Advantage plans to adopt an electronic prior authorization (e-PA) system with standardized transactions, increase transparency around prior authorization use and requirements, and mandate the Department of Health and Human Services and other agencies to report on oversight and further improvements to the e-PA process. NABH endorsed this legislation last year.

NABH is actively monitoring this legislation and will provide updates to members as they become available.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027, at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related virtual and in-person events:

  • CMS and the National Academy for State Health Policy will hold a webinar on Wednesday, July 22 at 12:30 p.m. ET to discuss the Community Engagement Requirement Interim Final Rule. Click here to register.
  • KFF and States Newsroom will hold a virtual event on Thursday, July 23 at noon ET entitled “Medicaid and the Road Ahead: Spending Cuts, Work Requirements and What’s Next for States, Providers and Families.” Click here to register.
  • The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29, 2026, in Washington, D.C.
  • The American Psychological Association will host its annual conference Aug. 6-8, 2026, in Washington, DC.

Fact of the Week

In a new study entitled “Mommy, do you love your phone more than me?”: Parental device use and the adolescent-caregiver attachment bond, NABH member Newport Healthcare found that teenagers who perceive their parents or caregivers as frequently distracted by mobile devices are significantly more likely to exhibit insecure attachment styles. Insecure attachment has been linked with challenges in developing healthy relationships, increased anxiety, and poorer mental and physical health outcomes over time.


For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

CEO Update | 281

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NABH Responds to HHS Request for Information on Behavioral Health

NABH last week submitted a response to the HHS Request for Comment on Chronic Disease of Addiction, which solicited ideas on “research, policy, and strategies to improve the prevention, treatment, recovery of chronic disease of addiction and mental illness and how to promote the Great American Recovery Initiative.”

NABH’s response offers three recommendations: (1) expand Medicaid coverage of Institutions for Mental Diseases via changes to the in lieu of service authority, (2) work with the Drug Enforcement Administration to streamline regulatory requirements for Opioid Treatment Program mobile medication units, and (3) promote access to contingency management for substance use disorders.

States Sue CMS Over Community Engagement Requirement

Democratic attorneys general and governors in 25 states and DC filed a lawsuit on June 29 in the U.S. District Court for the District of Massachusetts against CMS for the Community Engagement Requirement Interim Final Rule (IFR).

The lawsuit alleges that through CMS’ development and issuance of the IFR, the agency:

  • Violated H.R. 1, specifically with (1) the requirement for a health condition under the medically frail exclusion to significantly impair an individual’s functioning, (2) the limitation on the optional short-term hardship exception for declared emergencies to affect individuals’ ability to participate in community engagement activities, and (3) the restrictions imposed on beneficiary self-attestation for exclusions and certain exceptions;
  • Was arbitrary and capricious by providing contradictory information to states, departing from prior guidance without adequate justification, and imposing unreasonable requirements; and

  • Did not provide clear notice of the conditions that states must meet to implement the community engagement requirement because of ambiguity in the IFR and because states could not have reasonably anticipated many conditions based on statutory language and prior CMS guidance.

It is unclear what effect this lawsuit will have on the implementation of the community engagement requirement, which expansion states must incorporate into their Medicaid eligibility requirements by January 1, 2027. NABH will continue to monitor this litigation and keep members informed.

CMS Releases CY 2027 OPPS Proposed Rule

On Thursday, July 2, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Proposed Rule (CMS-1850-P), which includes updates to Medicare payment rates for behavioral health intensive outpatient programs (IOPs) and partial hospitalization programs (PHPs). CMS also released a rule summary.

The proposed IOP and PHP rates are a 9.4% increase from FY 2026 for programs providing 3 services per day and an 11.1% increase from FY 2026 for programs providing 4 or more services per day.

Proposed FY 2027 RatesCMHCsHospital-based
Intensive Outpatient (3 services)$139.81$349.52
Intensive Outpatient (4 or more services)$185.98$464.99
Partial Hospitalization (3 services)                          $139.81$349.52
Partial Hospitalization (4 or more services)$185.98$464.99

NABH will closely review the OPPS proposed rule for PHP and IOP payment methodology and rate concerns, as well as other policy issues that might impact members. We will provide comments to CMS on the proposed rule, which are due August 31, 2026. Contact Sarah Steverman, VP of Quality and Regulatory Affairs, with questions.

House Ways & Means Committee Bill Markup

The House Ways & Means Committee last Wednesday held a markup and advanced multiple bills out of committee, including the Tax Exempt Hospital Transparency Act introduced by Reps. Greg Murphy (R-NC) and Lloyd Smucker (R-PA). The bill aims to establish additional IRS reporting requirements for nonprofit hospitals.

NABH is actively monitoring this legislation and will provide updates to members as they become available.

Upcoming Webinars on Changes to Medicaid 

Please note these two upcoming virtual events discussing the new Community Engagement Requirement and other changes to Medicaid:

  • The Centers for Medicare & Medicaid Services (CMS) and the National Academy for State Health Policy will hold a webinar on Wednesday, July 22 at 12:30 p.m. ET to discuss the Community Engagement Requirement Interim Final Rule (IFR). During this webinar, CMS staff will explain the new Medicaid requirements, walk through the Interim Final Rule and answer audience questions. Please note that this webinar was rescheduled from its original date, July 9. Click here to register.

  • KFF and States Newsroom will hold a virtual event on Thursday, July 23 at noon ET entitled “Medicaid and the Road Ahead: Spending Cuts, Work Requirements and What’s Next for States, Providers and Families.” The conversation will focus on the broad impacts of the new Medicaid Community Engagement Requirement and other federal policy changes. Click here to register.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027, at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related virtual and in-person events:

  • CMS will host a virtual Connectathon to share updates about patient assessment reporting programs, including the proposed Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI). Alongside other general sessions, the IPF-PAI track will provide a preview of new patient assessment data collection tools. A kickoff call was held on June 22, but registration is still open for informational and demonstration sessions from July 14-16. Click here to register.

Fact of the Week

A new forecast from Vizient projects that behavioral health outpatient volumes will grow 22% over the next decade, more than seven times the 3% increase predicted by population trends alone.

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

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CMS Releases CY 2027 OPPS Proposed Rule with IOP and PHP Rates

Written by Shelby Liebler on . Posted in Alerts, Alerts, News & Insights.

The previous NABH alert on the OPPS proposed rule published on July 2, 2026 included the wrong per diem rates for IOP and PHP. This version published on July 6, 2026 updates those numbers to the current rates from Appendix A of the CY 2027 OPPS proposed rule.

On Thursday, July 2, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Proposed Rule (CMS-1850-P), which includes updates to Medicare payment rates for behavioral health intensive outpatient programs (IOPs) and partial hospitalization programs (PHPs). CMS also released a rule summary.

NABH will closely review the OPPS proposed rule for PHP and IOP payment methodology and rate concerns, as well as other policy issues that might impact members. We will provide comments to CMS on the proposed rule, which are due August 31, 2026. Contact Sarah Steverman, VP of Quality and Regulatory Affairs, with questions.


PHP and IOP Per Diem Rates

Intensive Outpatient (3 services)                                        CMHCs             Hospital-based
2027 Rate                                                                                           $139.81           $349.52
2026 Rate                                                                                           $127.74           $319.38
Intensive Outpatient (4 or more services)                          CMHCs             Hospital-based
2027 Rate                                                                                           $185.98           $464.99
2026 Rate                                                                                           $167.38           $418.45
Partial Hospitalization (3 services)                                     CMHCs             Hospital-based
2027 Rate                                                                                          $139.81            $349.52
2026 Rate                                                                                          $127.74            $319.38
Partial Hospitalization (4 or more services)                        CMHCs           Hospital-based
2027 Rate                                                                                           $185.98            $464.99
2026 Rate                                                                                           $167.38            $418.45

CEO Update | 280

Written by Shelby Liebler on . Posted in CEO Updates.

NABH Medicaid Community Engagement Requirement Webinar

Last Thursday, NABH hosted a webinar to discuss the new Medicaid Community Engagement Requirement Interim Final Rule, with a focus on implications for beneficiaries with behavioral health conditions. The slides from the presentation can be accessed here.

The recording of the webinar is now available, click here to access the video. The webinar is only accessible via this direct link, but members should feel free to share it.

CMS Issues Request for Information on Essential Health Benefits

CMS is requesting information on the Essential Health Benefits (EHB) framework and the requirement for EHB benefits to equal the benefits provided under a typical employer plan.

The Affordable Care Act included a requirement for non-grandfathered individual and small group (except fully-insured) private health plans, as well as Medicaid Alternative Benefit Plans, to cover 10 benefit categories, known as EHB. One EHB is “mental health and substance use disorder services, including behavioral health treatment.” States select an EHB benchmark plan, which serves as the basis for EHB design across applicable plans offered in the state.

The request for information (RFI) includes questions specific to behavioral health benefits, as well as broader topics that relate to behavioral health.

NABH is considering whether to submit comments in response to the RFI. Please reach out to NABH Vice President of Public Policy, Dan Schwartz, by Thursday, July 2 if you have specific information or perspectives that you would like NABH to relay.

MOTAA 2.0 Introduced in the Senate

On Thursday, June 25, Senators Ed Markey (D-MA) and Rand Paul (R-KY) introduced the Modernizing Opioid Treatment Access Act 2.0 (MOTAA 2.0), which differs from the previous version of the legislation. The new version empowers the Department of Health & Human Services to authorize additional providers to prescribe methadone without the need for additional legislation.

NABH is actively monitoring this legislation and will update members as more information becomes available. Please contact NABH Vice President of Public Policy, Dan Schwartz, with any questions.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027, at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related virtual and in-person events:

  • CMS will host a virtual Connectathon to share updates about patient assessment reporting programs, including the proposed Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI). Alongside other general sessions, the IPF-PAI track will provide a preview of new patient assessment data collection tools. A kickoff call was held on June 22, but registration is still open for informational and demonstration sessions from July 14-16. Click here to register by June 30.

Fact of the Week

July marks the 4th anniversary of the 988 Suicide & Crisis Lifeline’s nationwide launch. The 988 Lifeline has routed more than 26 million calls, texts, and chats since 2022.

Happy Independence Day from NABH!

Please note that NABH will not publish CEO Update on Friday, July 3and will resume on Friday, July 10.

The NABH team wishes you, your families, and your teams a happy and safe weekend celebrating our nation’s 250th Independence Day!

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

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NABH Webinar on Medicaid Community Engagement Requirement Interim Final Rule

NABH held a webinar yesterday on the new Medicaid Community Engagement Requirement Interim Final Rule, providing an overview of key provisions in the interim final rule, including exclusions for people with behavioral health conditions.

Thank you to all who attended the webinar. Click here to access the slides presented.


 SAMHSA Announces $700 Million in Funding Opportunities

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week more than $700 million in potential funding for grants and cooperative agreements. The notices of funding opportunity (NOFOs) include a new $96 million initiative, the Safety Through Recovery, Engagement, and Evidence-based Treatment and Support (STREETS) program, along with $612 million in funding opportunities for additional behavioral health programs. 

SAMHSA announced that the new STREETS program will provide eight communities with up to $3 million per year for four years to “develop multisector, state-of-the-art care systems for people who are homeless and have substance use disorders, serious mental illness, or co-occurring disorder.”

SAMHSA also released NOFOs to establish new Certified Community Behavioral Health Clinics (CCBHCs), enhance services at established CCBHCs, and several other programs, including grants to support 988/crisis services, suicide prevention, and substance use treatment and recovery services.

CMS Issues Final Rule on Oversight of Accrediting Organizations

The Centers for Medicare & Medicaid Services (CMS) on June 12 issued a final rule revising how the agency conducts oversight of accrediting organizations (AOs) that ensure healthcare providers are in compliance with the Medicare Conditions of Participation. The final rule phases out the use of “look-back” validation surveys, replacing them with direct validation surveys conducted by both AOs and state agencies. The rule also implements several policies intended to improve consistency in the survey process. These changes will take effect on June 16, 2027.
 
Click here to read the final rule.

New Medicaid Reimbursement Analysis from AJMC

The American Journal of Managed Care (AJMC) on June 12 released a new analysis comparing healthcare resource utilization and costs for Medicaid patients with serious mental illness between states with low and high reimbursement rates for psychiatric services. The study found that higher state Medicaid reimbursement rates were associated with reduced healthcare resource utilization and cost.
 
Read the full analysis here.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related virtual and in-person events:

  • CMS will host a virtual Connectathon to share updates about patient assessment reporting programs, including the proposed Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI). Alongside other general sessions, the IPF-PAI track will provide a preview of new patient assessment data collection tools. A kickoff call will be held on June 22, followed by informational and demonstration sessions from July 14-16. Click here to register.
  • A webinar presented by the National Training and Technical Assistance Center (NTAC) at CMS will be held on Thursday, June 25 at 3 p.m. E.T., designed for state Medicaid staff and others involved in state-level crisis service initiatives. Click here to register.
  • The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29, 2026 in Washington, D.C.
  • The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC.

Honoring Juneteenth

Today we honor Juneteenth, recognizing the day in 1865 that the final enslaved Americans were freed. At NABH, we remain committed to advancing and expanding access to quality, accountable behavioral healthcare for all. Learn more about the history of Juneteenth by clicking here.

Fact of the Week

From 2019 to 2024, the percentage of American adults seeking mental health counseling rose by almost 5%, the CDC reports.

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler

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Upcoming NABH Webinar on Medicaid Community Engagement Requirements Interim Final Rule

On Thursday, June 18 from 12-1 p.m. ET, NABH will host a webinar for members on the new Medicaid Community Engagement Requirements Interim Final Rule. We will provide an overview of key provisions in the interim final rule, including exclusions for people with behavioral health conditions.
 
Click here to register for the webinar.

NABH Submits Comments on FY27 IPPS Proposed Rule to CMS

NABH this week submitted comments and recommendations to the Centers for Medicare & Medicaid Services (CMS) about the agency’s Fiscal Year 2027 Inpatient Prospective Payment Systems (IPPS) proposed rule. In the IPPS rule, CMS asked for information regarding the appropriateness of including the Emergency Care Access and Timeliness eCQM (electronic clinical quality measure) in the Inpatient Quality Reporting Program. The letter addresses the association’s concern that the measure does not account for the complexity of staffing and operating an inpatient unit serving patients with behavioral healthcare needs.
 
Read the full letter here.

CMS Connectathon Featuring IPF-PAI Reporting Tool

The Centers for Medicare & Medicaid Services (CMS) will host a virtual Connectathon to share updates about patient assessment reporting programs, including the proposed Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI). As CMS explores using Fast Healthcare Interoperability Resources (FHIR) for statutory quality reporting, the Connectathon will showcase the Patient Assessment Reporting Interoperability Tool (PARIT), a FHIR-based web application designed to support standardized collection and submission of patient assessment data.
 
Alongside other general sessions, the IPF-PAI track will provide a preview of PARIT and demonstrate the collection and submission of patient data. A kickoff call will be held on June 22, followed by informational and demonstration sessions from July 14-16. Click here to register.
 
Please contact Sarah Steverman, Vice President of Quality and Regulatory Affairs, with questions.

CMS NTAC Webinar: Medicaid and Mobile Crisis Response in Rural Areas

CMS will host a National Training and Technical Assistance Center (NTAC) webinar on Thursday, June 25 at 3 p.m. ET. Designed for state Medicaid staff and others involved in state-level crisis service initiatives, the webinar will discuss leveraging Medicaid policy and scaling services for Mobile Crisis Response in rural areas. Click here to register.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC.
 
In the near term, here are some upcoming behavioral healthcare-related events:

Fact of the Week

35% of US teens are extremely or very concerned about the mental health of their peers, according to the Pew Research Center.

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

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CMS Issues Interim Final Rule on Medicaid Community Engagement Requirements

Written by Shelby Liebler on . Posted in Alerts, Alerts, News & Insights.

CMS issued the interim final rule (IFR), Medicaid Program: Community Engagement Requirement for Certain Individuals, after the market closed on Monday, June 1.
 
This IFR implements Sec. 71119 of H.R. 1 (also known as the One Big Beautiful Bill Act and the Working Families Tax Cut legislation), which conditioned Medicaid eligibility on completing 80 hours per month of community engagement activities (i.e., work, community service, or educational activities).
 
Statutory exceptions to community engagement requirements include people who are medically frail, which includes having a substance use disorder (SUD) or disabling mental disorder (DMD). The IFR does not define either SUD or DMD, but rather indicates that states will need to adopt lists of qualifying conditions and implement a process for individuals to request an exemption due to a condition excluded from the list. Importantly, the IFR clarifies that people with SUDs would only qualify for the SUD exemption if they have been in recovery for fewer than five years, and active treatment participation is not needed to qualify.
 
States are required to prioritize assessing exception eligibility using their existing data. For individuals whom states cannot verify as medically frail using their existing data, practitioners can submit documentation to demonstrate eligibility. Otherwise, individuals can self-attest to medical frailty and enroll in Medicaid for six months before information is required to substantiate their attestation. If states grant the medically frail exception, they would need to reassess this exception at least annually.

Congress directed CMS in H.R. 1 to implement community engagement requirements via an IFR, a type of regulation that bypasses a public comment process on a draft version of a rule before it takes effect. 
 
The NABH team will continue to review the IFR, which takes effect on July 31, 2026, the same day public comments are due. However, states do not need to implement the IFR’s provisions until Jan. 1, 2027.