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White House Proposes Changes IMD Exclusion in 2021 Budget

The White House on Monday released a $4.8 trillion budget for 2021 that would modify Medicaid’s Institutions for Mental Diseases (IMD) exclusion to provide states with flexibility to provide inpatient mental health services to beneficiaries with serious mental illness (SMI).

The budget requests $94.5 billion for HHS, a 10-percent decrease from the 2020 enacted level. Although Congress is likely to reject President Trump’s proposal, the budget is significant for outlining the president’s top policy priorities as he seeks re-election in November. Notably for NABH, those priorities address mental health and addiction treatment services.

These provisions include changes to the IMD exclusion, which under current law states Medicaid cannot pay for certain inpatient stays at IMDs. The president’s budget would provide more than $5 billion in new federal funding to states to ensure the full continuum of care exists to provide help to people with SMI. These changes—which appear in summary tables at the end of the budget proposal—would exempt Qualified Residential Treatment Programs (QRTPs) from the IMD exclusion.

The budget also includes $225 million for Certified Community Behavioral Health Clinics (CCBHC) expansion grants, and would extend, through 2021, the CCBHC Medicaid demonstration programs to improve community mental health services for the eight states participating currently in the demonstration. In addition, the White House has proposed $25 million to expand primary healthcare services to address homelessness. These provisions, together with the changes to the IMD exclusion, are “part of a comprehensive strategy that includes improvements to community-based treatment,” the budget proposal noted.

Meanwhile, the president’s 2021 budget would continue 2020 funding to expand medication assisted treatment (MAT) from a small pilot program to half of all eligible Bureau of Prisons (BOP) facilities and provide an additional $37 million to complete MAT expansion to all eligible BOP facilities.

NABH will continue to analyze the Trump administration’s budget proposal and keep NABH apprised of any additional details regarding the IMD exclusion, MAT funding, and other topics related to the association’s policy priorities.

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ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan

The Office of National Drug Control Policy (ONDCP) has issued its 2020 National Drug Control Strategy (Strategy) and accompanying National Treatment Plan (NTP) that includes action items for federal agencies and external stakeholders to increase access to care and close the addiction treatment gap.

The Strategy is presented using the domains of prevention, treatment and recovery, and supply-side strategies for reducing the availability and consumption of illicit drugs. These domains are established as ‘pillars’ that undergird the federal initiatives of expanding the early intervention, treatment and recovery infrastructure; improving the delivery system; and improving quality.

Specifically, the NTP calls for treatment expansion and improved quality by:

  • Developing protocols for medically managed withdrawal including MAT to prevent relapse and promote stabilization;
  • Increasing emergency department use of addiction medicine specialty services;
  • Exploring the inclusion of stimulant disorder treatment in opioid treatment programs;
  • Increasing access to all medication and psychosocial services, promoting syringe exchange, interim methadone, mobile methadone vans, and peer outreach. One objective of the federal Performance and Reporting System is to make sure 100% of all specialty providers offer MAT by 2020;
  • Adopting model state specialty SUD treatment licensing laws;
  • Developing mobile and online platforms with updated information on treatment slot availability with online appointment capacity;
  • Encouraging public and private payers to cover comprehensive services and improve reimbursement rates where out-of-network rates are higher;
  • Urging providers to subsidize and provide treatment scholarships; and
  • Exploring the idea of developing national consensus standards for addiction treatment to consolidate treatment quality standards.

If you have questions about the Strategy or NTP, please contact Sarah Wattenberg, NABH’s
director of quality and addiction services.

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

The age-adjusted rate of U.S. drug overdose deaths in 2018 was 4.6% lower than the rate in 2017, the Centers for Disease Control and Prevention reported Thursday.

New data from the National Vital Statistics System also show there were 67,367 drug overdose deaths in the United States in 2018, 4.1% fewer than the 70,237 deaths reported in 2017.

Despite the decline in overall drug overdose deaths, there was a 10% increase in the rate of drug overdose deaths involving synthetic opioids other than methadone, such as fentanyl, in 2018 compared with 2017.

Furthermore, the age-adjusted rate of overdose deaths involving cocaine more than tripled from 2012 through 2018, while the rate of deaths involving certain psychostimulants, such as methamphetamine, increased nearly five-fold.

The CDC also reported that decreases in life expectancy between 2014 and 2017 were driven mostly by deaths due to unintentional injuries, suicide, and Alzheimer’s disease.

Improvements in life expectancy between 2017 and 2018, meanwhile, were driven by decreases in  mortality from cancer, unintentional injuries, and chronic lower respiratory diseases. The positive contributions to the change in life expectancy were offset, in part, by the rising number of deaths by suicide, chronic liver disease, and cirrhosis.

Unintentional injuries and suicide remain in the top ten leading cause of death in the United States.

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

WASHINGTONJan. 13, 2020 /PRNewswire/ — The Centers for Medicare & Medicaid Services (CMS) on Monday announced it has streamlined the process to survey the nation’s psychiatric hospitals to review for compliance with participation requirements in one comprehensive survey.

Beginning in March, CMS will send psychiatric hospitals one survey to evaluate their compliance with both general hospital and psychiatric hospital participation requirements. CMS is not making any changes to the special psychiatric Conditions of Participation (CoPs) in this process.

Under this change, CMS will move the interpretive guidelines from State Operations Manual (SOM) Appendix AA, or the special psychiatric CoPs, into Appendix A, the CoPs for general hospitals. Subsequently CMS will delete Appendix AA. This change will allow CMS to issue a single survey and report to hospitals, rather than two.

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NABH Urges Oversight Hearings on Parity Following GAO Report

WASHINGTONDec. 18, 2019 /PRNewswire/ — A key finding in a new Government Accountability Office (GAO) report on government oversight of compliance with parity underscores the need for federal lawmakers to proactively investigate the work of employer-sponsored group plans and ensure they are complying with the landmark 2008 parity law.

Late last week, GAO released a 67-page report that examined and evaluated the practices, policies, and guidance from the U.S. Health and Human Services (HHS) Department and the U.S. Labor Department (DOL), the two federal offices that oversee compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008.

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

The Centers for Medicare & Medicaid Services (CMS) released an Informational Bulletin on Tuesday that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services.

Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time.

To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved.

CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare.

If you have questions, please contact Sarah Wattenberg, NABH’s director of quality and addiction services.

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Milliman Report Highlights Barriers to Accessing Behavioral Healthcare Services

WASHINGTONNov. 20, 2019 /PRNewswire/ — A report from Milliman, Inc. about disparities between physical and behavioral healthcare for both in-network access and provider reimbursement rates underscores NABH’s position that unnecessary barriers continue to deny access to behavioral healthcare for patients who need it.

The Bowman Family Foundation commissioned Milliman to produce Addiction and Mental Health vs. Physical Health: Widening disparities in network use and provider reimbursement, a 140-page report that shows the gap in disparities for employees and their families seeking mental health and addiction treatment versus treatment for physical health conditions widened in 2016 and 2017.

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