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Andrew Dodson Joins NABH as Director of Congressional Affairs

WASHINGTONAug. 17, 2023 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) is pleased to welcome Andrew (Andy) Dodson as the association’s director of congressional affairs, effective Aug. 16.

Andy brings to NABH more than 20 years of legislative and regulatory advocacy experience in senior government affairs positions with several national trade associations and a multi-client government affairs consulting firm.

He has advocated for companies and associations in the insurance, technology and telecommunications, real estate, and business aviation industries, and he is eager to represent behavioral healthcare providers.

“We are very excited that Andy has joined our team because he brings with him a keen understanding of Capitol Hill, extensive lobbying experience, and a strong background in regulatory affairs,” said NABH President and CEO Shawn Coughlin. “He is what NABH needs, and we know he will enhance and strengthen our advocacy efforts.”

Most recently Andy led the American Wood Council’s federal, state, and local advocacy efforts, where he developed and implemented successful political campaigns and government relations initiatives.

Andy began his political career working in the Texas legislature and on several statewide political campaigns before he moved to Washington, D.C., where he worked for House Majority Leader Richard Gephardt (D-Mo.) and several Texas lawmakers. He also worked as a regional fundraising director for the Democratic Congressional Campaign Committee and the Clinton/Gore Re-Election Committee.

Andy is a graduate of the University of Texas at Austin. He lives Bethesda, Md. with his wife and two sons.

About NABH

The National Association for Behavioral Healthcare (NABH) represents provider systems that treat children, adolescents, adults, and older adults with mental health and substance use disorders in inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, medication assisted treatment centers, specialty outpatient behavioral healthcare programs, and recovery support services in 49 states and Washington, D.C. The association was founded in 1933.

SOURCE National Association for Behavioral Healthcare

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CMS Final Rule Estimates Overall IPF Payments to Increase by 2.3% in 2024

The Centers for Medicare & Medicaid Services (CMS) on Thursday released its Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) final rule for Fiscal Year (FY) 2024, which is estimated to increase overall payments to IPFs by 2.3%, or $70 million, relative to FY 2023.

While the agency’s final FY 2023 payment update is larger than its earlier proposed 1.9% increase, NABH will continue to push policymakers to recognize fully the high costs that our association’s members face.

The FY 2024 update includes increases in the federal per-diem base rate to $895.63 from $865.63, and in the outlier threshold to $33,470 from $24,630, which will reduce the number of cases that qualify for an outlier payment.

CMS released a fact sheet with the final rule. The NABH team is currently reviewing the rule and will share a more detailed summary in tomorrow’s CEO Update.

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HHS, DOL and Treasury Release Proposed Rules to Strengthen MHPAEA

The U.S. Health and Human Services (HHS), Labor (DOL), and Treasury Departments on Tuesday released proposed rules to bolster the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 and remove obstacles to behavioral healthcare access.

The rules propose several amendments to the 2013 MHPAEA final regulations, as well as provisions that would establish the content requirements of the Non-Qualitative Treatment Limitations, or NQTL, comparative analyses required under amendments to MHPAEA included in the Consolidated Appropriations Act, 2021 (CAA, 2021).

“Today’s rules show the Biden administration’s continued effort to implement the landmark parity law,” said NABH President and CEO Shawn Coughlin. “We’re hopeful these changes will do much to eliminate the illegal restrictions and barriers to behavioral healthcare that exist today, nearly 15 years after the law passed.”

The three departments also released a Technical Release on NQTLs that outlines principles and seeks public comment to inform future technical guidance about the application of proposed data collection and evaluation requirements to NQTLs related to network composition that the rule proposes.

Along with the proposed rules, the departments released the 2023 MHPAEA Comparative Analysis Report to Congress that the CAA, 2021 requires. The report includes information about the agencies’ enforcement efforts and identifies plans and issuers that received final determinations of non-compliance with MHPAEA.

The White House released a fact sheet about the rule and DOL’s Employee Benefits Security Administration posted all the related documents here.

NABH will seek feedback from members and submit comments about the proposed rules and Technical Release.

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CMS Coverage for PHP Telehealth Services Set to End After May 11

As the COVID-19 Public Health Emergency (PHE) draws to a close at the end of Thursday, May 11, the Centers for Medicare & Medicaid Services (CMS) has shared with NABH and other stakeholders the agency’s plans to end telehealth coverage for partial hospitalization program (PHP) services  implemented during the PHE.

In addition, CMS has explained that telehealth coverage will continue through December 2024 for Intensive Outpatient Program (IOP) services that qualify under the outpatient prospective payment system as “remote mental health services.”

NABH continues to communicate with key Members of Congress to clarify the legislative intent behind the telehealth coverage extensions that were authorized in the Consolidated Appropriations Act, 2023 last December. The NABH team understands that some Members of Congress intended for the telehealth coverage extension to include PHP services.

Given the persistent confusion on these matters, NABH has urged CMS to issue clarification in writing. NABH will keep members apprised of our efforts to extend telehealth coverage for PHP services.  

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DEA Extends COVID-19 Telehealth Flexibilities for Prescription of Controlled Medications for Now

The U.S. Drug Enforcement Administration (DEA) on Wednesday said it will extend its COVID-19 telemedicine flexibilities for prescription of controlled medications as the agency works to determine how to move forward in a way that gives Americans access to needed medicine with the appropriate safeguards.

An announcement from DEA noted the agency received a record number of comments on its proposed telemedicine rules, which prompted DEA and HHS to submit a draft temporary rule to the Office of Management and Budget requesting an extension. NABH submitted comments on this matter (see CEO Update, April 28, 2023).

“Further details about the rule will become public after its full publication in the Federal Register,” the announcement said.

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