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.   

Welcome to the first edition of NABH Insider, from the National Association for Behavioral Healthcare. The Insider is your weekly update on the latest behavioral healthcare policy developments, advocacy efforts, and association news.

We’re excited to introduce this new format and look forward to connecting with you in your inbox every Tuesday.

State of Play

To follow NABH’s comment letter to the CMS on July 31, we joined multiple letters last week outlining our concerns about the implementation of the Medicaid Community Engagement Requirement Interim Final Rule (IFR).
 
The first letter was submitted in partnership with the Mental Health Liaison Group, a coalition of advocacy organizations. We raised concerns that the community engagement requirement could cause millions of Americans – particularly those experiencing behavioral health challenges – to wrongfully lose Medicaid coverage. We urged CMS to provide states with greater flexibility in implementation, protect beneficiary self-attestation, and make implementation data publicly available.

NABH also joined a comment letter to CMS from the Legal Action Center (LAC), highlighting our concern that CMS’ restrictive “medical frailty” exclusion could lead to some beneficiaries being wrongfully included in the community engagement requirement. LAC also emphasized the significant administrative burden the new rule will place on both state governments and Medicaid enrollees.

As the January 1, 2027, deadline approaches for states to begin enforcing community engagement requirements, NABH will continue to monitor the federal regulatory landscape and state-level implementation of the new rule.

Take Action

2026 NABH Membership Directory: Be sure to review your organization’s information and submit any revisions to the 2026 NABH Membership Directory by Monday, Aug. 31. Please use the link you received at the beginning of August from the National Association for Behavioral Healthcare (mail@nabh.org).

We encourage you to include information for all facilities within your system so that our directory reflects the full breadth and diversity of our membership and helps accurately represent our members to policymakers, regulators, partner organizations, and the media.

Need the update link resent or have questions? Contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 – we’re happy to help.

Accessible SUD Care Workgroup: NABH’s Substance Use Disorder (SUD) Treatment Committee is forming a new Accessible SUD Care Workgroup. The group will focus on innovative financing approaches to support service integration, organizational partnerships that promote SUD treatment availability in non-specialty SUD settings, and other services to treat co-occurring conditions within specialty SUD settings. We encourage participation from both individuals who do and do not primarily work on SUD treatment. 

The initial information session will be held on Friday, August 28, from 12:00pm ET – 12:30pm ET. Please contact Dan Schwartz (dan@nabh.org) if you would like to attend or have any questions.

On Our Radar

Becker’s Behavioral Healthcare: Community Behavioral Health Clinics Served 3.4 million People in 2025, up 13% – In 2025, an estimated 3.4 million individuals received care across the nation’s 539 Certified Community Behavioral Health Clinics (CCBHCs), up nearly 13% compared to January 2024.

KFF: Medicaid Work Rule Leaves Homeless People in the Cold – The story of Montana resident Tywon Pugh illuminates how the Medicaid community engagement requirement could create barriers to coverage for those struggling with homelessness and severe illness.

Route Fifty: How States are Preparing for Medicaid Eligibility Changes – As the 2027 deadline for Medicaid community engagement requirement implementation looms closer, states are taking varying legislative and operational approaches to get ready for January 1st.

Helpful Resources

CMS’ Community Engagement Outreach Materials: CMS has recently released outreach materials intended for states, nonprofit partners, and health providers to educate Medicaid recipients about the upcoming changes in community engagement requirements.

Stay Connected

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

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