Regulatory Relief to Support Access to Behavioral Healthcare
Written by Emily Wilkins (NABH) on . Posted in Letters.
Covid-19 Task Force Letter to Congress
Written by Emily Wilkins (NABH) on . Posted in Letters.
NABH-The Kennedy Forum Op-Ed
Written by Administrator on . Posted in Resources.
CMS Expects FY 2021 IPF Payments to Increase by 2.4%
Written by Emily Wilkins (NABH) on . Posted in Alerts.
HHS Announces $30 Billion in Covid-19 Relief Funding for Providers
Written by Emily Wilkins (NABH) on . Posted in Alerts.
Critical Behavioral Healthcare Recommendations During Covid-19
Written by Emily Wilkins (NABH) on . Posted in Letters.
MHLG Letter to HHS and CMS on Medicare Telehealth
Written by Emily Wilkins (NABH) on . Posted in Letters.
MHLG Telehealth State Coverage Letter 3/25/20 House and Senate
Written by Emily Wilkins (NABH) on . Posted in Letters.
NABH Covid-19 Letter
Written by Emily Wilkins (NABH) on . Posted in Letters.
CSOO Addiction Service Workforce Recommendations
Written by Emily Wilkins (NABH) on . Posted in Resources.
MHLG Supports Medicare Mental Health Inpatient Equity Act
Written by Emily Wilkins (NABH) on . Posted in Letters.
DEA Eases Regulations for Mobile Methadone
Written by Emily Wilkins (NABH) on . Posted in Issue Brief.
- Registration
- Registrants notify the local DEA office in writing about intent to operate an mNTP and receive explicit written approval prior to operation.
- The mNTP functions within the same states that the NTP is registered.
- Practitioners maintain a DEA license in each state where they dispense controlled substances.
- Vehicles possess valid county/city and state information on file at the NTP.
- mNTPs are a controlled premise subject to administrative inspection; registrants provide licensing and registration to DEA at time of the inspection and before transportation of substances.
- mNTPs may not serve as hospitals, long-term care facilities, emergency medical service vehicles, or patient transportation.
- Security
- Storage area must not be accessible from the outside of the mNTP vehicle.
- Substances are secured in a locked safe:
- with safeguards against forced entry, lock manipulation, and radiological attacks;
- cemented to the floor or wall such that it cannot be readily removed;
- equipped with an alarm system that can directly signal a protection company, local or State policy agency, or 24-hour registrant-operated control station, or other DEA Administrator approved protection.
- Transportation personnel retain control over the controlled substances when transferring, traveling, and dispensing the substances.
- mNTP is returned to registration location after operations are completed.
- Substances are removed and secured within the registered NTP location.
- Protocols allow for securing substances if the component is disabled.
- Substances are removed and secured if the vehicle is taken to an automotive shop for repair.
- For security breaches such as theft and loss, the NTP must abide by theft and loss reporting requirements.
- NTPs follow state and federal regulations or whichever is more stringent and consults with State Opioid Treatment Authority to ensure compliance.
- Other security controls
- Ensure proper security measures and patient dosage, e.g., enrolled individuals wait in an area of the mNTP that is physically separated from the narcotic storage and dispensing area by a physical entrance.
- If no seating is available, patient will wait outside of the mNTP.
- mNTPs will abide by existing HHS standards for quantity of substances provided for unsupervised use.
- Degree of security is at DEA discretion, based on factors including the location, number of patients, staff, and security guard.
- Disposal of controlled substances is done consistent with all applicable laws and regulations.
- Distribution and delivery of controlled substances to mNTP is only done at the registered location. Persons delivering narcotic drugs to mNTP may not:
- Receive or deliver controlled substances to another mNTP or other entity while deployed outside the registered location.
- Act as reverse distributors (or collectors).
- Ensure proper security measures and patient dosage, e.g., enrolled individuals wait in an area of the mNTP that is physically separated from the narcotic storage and dispensing area by a physical entrance.
- Records and Reports
- mNTP records are maintained in a paper dispensing log at the registered NTP, or
- Use of automated/computerized system if the system:
- maintains the same information as required for paper records;
- has the capability to produce hard copies of the dispensing records;
- the mNTP prints each day’s dispensing log which is initialed by individuals who dispense the medication;
- produces accurate summary reports for any time frame requested by DEA in an investigation;
- Hard copies of summaries are systematically organized at the NTP;
- Computer generated information has off-site back-up;
- DEA approves of the system.
- mNTP maintain records for two years, or longer if required by the state.
NABH 2020 Directory Features Essential Behavioral Healthcare Sources
Written by Emily Wilkins (NABH) on . Posted in News Releases.
A National Plan to Address Opioid Misuse
Written by Emily Wilkins (NABH) on . Posted in Alerts.
Kirsten Beronio Joins NABH as Director of Policy and Regulatory Affairs
Written by Emily Wilkins (NABH) on . Posted in News Releases.
MHLG Supports the Implementation of the National Suicide Hotline Improvement Act of 2018
Written by Emily Wilkins (NABH) on . Posted in Issue Brief.
NABH Supports Nutrition Care Act
Written by Emily Wilkins (NABH) on . Posted in Letters.
White House Proposes Changes IMD Exclusion in 2021 Budget
Written by Emily Wilkins (NABH) on . Posted in Alerts.
ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan
Written by Emily Wilkins (NABH) on . Posted in Alerts.
- 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.
CDC Reports U.S. Drug Overdose Death Rate Down, Opioid Overdose Death Rate Up in 2018
Written by Emily Wilkins (NABH) on . Posted in Alerts.
NABH Sends CMS Recommendations to Reduce Administrative Burden
Written by Emily Wilkins (NABH) on . Posted in Letters.
NABH Supports Expanding Access to Inpatient Mental Health Act
Written by Emily Wilkins (NABH) on . Posted in Letters.
NABH Comments on CMS’ New Survey and Certification Process for Psychiatric Hospitals
Written by Emily Wilkins (NABH) on . Posted in News Releases.
NABH Urges Oversight Hearings on Parity Following GAO Report
Written by Emily Wilkins (NABH) on . Posted in Press.
CMS Releases Guidance on Coverage Transition for ‘Dual Eligibles’ Receiving OTP Services
Written by Emily Wilkins (NABH) on . Posted in Resources.
Milliman Report Highlights Barriers to Accessing Behavioral Healthcare Services
Written by Emily Wilkins (NABH) on . Posted in Press.
NABH Analysis: OTP Provisions in 2020 Physician Fee Schedule
Written by Emily Wilkins (NABH) on . Posted in Analysis.
OTP Provisions in 2020 Physician Fee ScheduleCMS finalized provisions for the nation’s opioid treatment programs (OTPs) in the 2020 Physician Fee Schedule regulation that the agency released on Nov. 1. This NABH Analysis provides a summary of those provisions, which provide for the treatment of opioid use disorders (OUDs) with new bundled service codes for OTPs, and for telehealth and opioid use treatment services in office-based settings. The final rule will be published in the Federal Register on Nov. 15. The regulations implement requirements that were included in last year’s Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act. NABH is pleased that the final rule addressed the following issues that NABH mentioned in its comment letter on Sept. 28:
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NABH Issue Brief: CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD
Written by Emily Wilkins (NABH) on . Posted in Issue Brief.
CMS Releases Guidance on IMDs Providing Treatment to Medicaid Beneficiaries with At Least One SUD
The Centers for Medicare & Medicaid Services (CMS) on Wednesday released guidance to state Medicaid directors that clarifies how section 5052 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patient and Communities (SUPPORT) Act permits institutions for mental diseases (IMDs) to provide treatment to Medicaid beneficiaries with at least one substance use disorder (SUD).
NABH was a driving force behind section 5052 becoming law and the NABH team has talked with CMS staff about the law’s implementation.
The guidance from CMS covers five key areas: requirements for beneficiaries, requirements for IMDs, requirements for states, maintenance of effort, and interaction with existing IMD policies. This NABH Issue Brief provides a summary of each of those areas.
Requirements for BeneficiariesAn eligible individual for section 5052 (the new IMD authority) is a person who is:
Requirements for IMDsEligible IMDs must follow reliable, evidence-based practices and make available at least two forms of medication as part of medication-assisted treatment (MAT). The two drugs may be offered on site upon request or furnished off site by a qualified provider in the community that has an arrangement with the IMD. IMDs “should also offer behavioral health services alongside MAT,” CMS noted.Requirements for StatesStates are required to:
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NPRM Part 2 Partnership Comments
Written by Emily Wilkins (NABH) on . Posted in Letters.
NABH, MHA, and NAMI Letter to Congress on Citizens Commission on Human Rights
Written by Administrator on . Posted in Letters.
2020 Annual Meeting
Written by Administrator on . Posted in News Releases, Press.
March 16-18, 2020
Mandarin Oriental Washington, DC
We invite you to use this annual opportunity to learn from, connect with, and influence the decision makers who determine the future of behavioral healthcare services in the United States.
The 2020 Annual Meeting will feature sessions on a variety of issues affecting the U.S. behavioral healthcare industry, with a special emphasis on the barriers to providing and access care.
Learn more and register for the 2020 Annual MeetingShawn Coughlin Named Next NABH President and CEO
Written by Administrator on . Posted in News Releases, Press.
NABH Letter to CMS on OTPs
Written by Administrator on . Posted in Letters.
NABH Letter to CMS on OPPS 2020 Rule
Written by Administrator on . Posted in Letters.
MHLG Letter on Mental Health Professionals Workforce Shortage Loan Repayment Act
Written by Administrator on . Posted in Letters.
NABH Letter to CMS on Reducing Administrative Burden
Written by Administrator on . Posted in Letters.
House of Representatives CHAMPVA Letter to VA
Written by Administrator on . Posted in Letters.
NABH Issue Brief: CMS Proposes Slight Payment Increase for PHPs and CMHCs in 2020
Written by Administrator on . Posted in Issue Brief.
NABH Issue Brief: CMS Addresses OUD Treatment in OTPs and Office Settings in Proposed Rule
Written by Administrator on . Posted in Issue Brief.
OTP Bundled Payment
The proposal implements Section 2005 of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act. The rule proposes:- A definition of OUD treatment services and OTPs, including an explanation that services include access to all FDA-approved medications, counseling and therapy, and toxicology testing;
- Enrollment policies that align with SAMHSA OTP regulation and that do not have additional conditions of participation;
- Bundled payment methodologies that separate drug from non-drug treatment components, account for different medications and variable intensity of services, provide for service add-ons and partial- and full-billing for weekly episodes;
- Use of audio-video communication technology; and
- Zero beneficiary cost-sharing requirement for a time-limited period.
Office-based Care Bundled Payment
The agency also proposed a bundled payment for office-based OUD treatment services, to encourage the expansion of access to OUD care, including:- Coverage of OUD management, care coordination, psychotherapy, and counseling; medication to be billed and reimbursed under existing Medicare Part B or D; toxicology testing to be billed under Clinical Lab Fee Schedule;
- Bundled payment methodologies that are based on monthly billing cycles to better align with office-based practices; one bundle for the initial month of treatment that is more service-intensive; and a second bundle for subsequent “maintenance months,” service add-on codes, and not restricted to addiction specialists;
- Three new HCPCS codes to Category I of the list of Medicare telehealth services for office-based substance use disorder (SUD)/OUD services, permits a patient’s home as a telehealth originating site; and
- No changes to cost-sharing.
Emergency Departments
Also of interest, the proposed rule requests information on emergency department practice patterns related to the initiation and use of MAT, and referral or follow-up care, for developing such bundles in future rulemaking. Comments are due September 27, 2019. NABH has engaged a consulting firm to help analyze the proposed bundled payment methodology and payment rates, and the association will submit comments.MHLG Letter of Support on Mental Health Professionals Workforce Shortage Loan Repayment Act of 2019
Written by Administrator on . Posted in Letters.
NABH Alert: CMS Announces 1.5-percent Increase for Inpatient Psychiatric Facilities for 2020 in Final Rule
Written by Administrator on . Posted in Alerts.
CMS Releases Emergency Medical Treatment and Labor Act (EMTALA) Memorandum
Written by Administrator on . Posted in Alerts.
- How do surveyors evaluate whether a staff person is qualified to perform a Medical Screening Exam?
- The surveyor can review state scope of practice as well as hospital bylaws or rules and regulations to determine if the medical screening exams being performed are within a professional’s scope of practice.
- What is the expectation of a psychiatric hospital when a medical emergency presents in terms of who can conduct a medical screening exam?
- EMTALA requires hospitals to perform medical screening examinations within their capabilities. If the psych hospital doesn’t have the ability to perform a comprehensive medical screening exam (or provide stabilizing treatment), but the screening exam it performs indicates that the patient may have an emergency medical condition, the hospital is required to arrange an appropriate transfer to a facility for further evaluation and treatment. The hospital is expected to use its resources to perform the exam and provide care within its capabilities prior to transfer. This might be as simple as performing ongoing assessments with repeat vital signs and ensuring the patient is in a safe environment.
- What is required in terms of stabilization and transfer for non-psychiatric emergencies?
- There is no expectation that a psych hospital with basic clinical services would be expected to provide the same level of comprehensive medical assessments or treatment as an acute care hospital.
- How does EMTALA intersect with admission?
- If the hospital has the staff and facilities to stabilize the emergency medical condition, it is expected to do so. This includes inpatient admission, as appropriate. Having an empty inpatient bed does not always translate to having the capability or capacity to stabilize the emergency medical condition.
- Can an ER physician in a facility that does not provide psychiatric care conduct the mental health screening?
- It is within the scope of practice for ED physicians and practitioners to evaluate patients presenting with mental health conditions, same with any other medical, surgical, or psychiatric presentation. The ED practitioner may utilize hospital resources to assist with the examination and treatment or arrange appropriate transfers if additional resources are needed.
Support Letter: CREATE Act
Written by Administrator on . Posted in Letters.
Support Letter: BETTER Act
Written by Administrator on . Posted in Letters.
FY 2020 IPPS Rule Comments
Written by Administrator on . Posted in Letters.
MHLG Letter: Mental Health Parity Compliance Act of 2019 (Senate)
Written by Administrator on . Posted in Letters.
MHLG Letter: Mental Health Parity Compliance Act of 2019 (House)
Written by Administrator on . Posted in Letters.
Behavioral Health Information Technology Letter to CMS
Written by Administrator on . Posted in Letters.
Suicide Hotline Letter to FCC
Written by Administrator on . Posted in Letters.
PIC Mental Health Parity Compliance Act
Written by Administrator on . Posted in Resources.
MHLG Letter: Mental Health Parity Compliance Act of 2019
Written by Jessica on . Posted in Letters.
MACPAC RFI – IMD Regs
Written by Administrator on . Posted in Resources.
MHLG Letter: Behavioral Health Coverage Transparency Act (Senate)
Written by Administrator on . Posted in Letters.
MHLG Letter: Behavioral Health Coverage Transparency Act (House)
Written by Administrator on . Posted in Letters.
NABH Analysis: Telebehavioral Health in Medicare
Written by Administrator on . Posted in Analysis.
Behavioral Health Update: May 7th, 2019
Written by Administrator on . Posted in Resources.
Shatterproof Rating System for Addiction Treatment Programs
Written by Administrator on . Posted in Resources.
NQF Quality Innovation: Measuring Quality of Care in Substance Use Disorder (SUD) Treatment Programs
Written by Administrator on . Posted in Resources.
The National Action Alliance for Suicide Prevention: Recommended Standard Care for People with Suicide Risk
Written by Administrator on . Posted in Resources.
CMS April 2019 Patients Over Paperwork Newsletter
Written by Administrator on . Posted in Newsletters.
GAO Report: Research on Healthcare Costs of Untreated Conditions is Limited
Written by Administrator on . Posted in Resources.
Partnership to Amend 42 CFR Part 2 Applauds House and Senate Bills
Written by Administrator on . Posted in Resources.