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CEO Update 183

Please Help Us Welcome Deputy National Coordinator for Health IT Steven Posnack on May 13!

NABH is pleased to welcome Deputy National Coordinator for Health Information Technology Steven Posnack, M.S., M.H.S., as our first 2024 Annual Meeting presenter on Monday, May 13 at 2:45 p.m. ET in the Salamander hotel’s Grand Ballroom. Posnack advises the national coordinator, executes the Office of the National Coordinator for Health Information Technology’s (ONC) mission, and represents ONC’s interests at a national and international level. Together with the national coordinator, Posnack also oversees ONC’s federal coordination, regulatory policy, public-private initiatives, and the overall implementation of statutory authorities and requirements, including those from the 21st Century Cures Act and HITECH Act. He will discuss behavioral health information technology at our Annual Meeting. Also, please join us for Monday’s workforce panel on Monday, May 13 at 4 p.m. This year’s panel of NABH members and workforce consultants will highlight NABH member best practices to recruit and retain talent as well as how to establish partnerships and “grow your own” programs to address your workforce needs. Please click here to learn about our panelists and other Annual Meeting speakers. And be sure to register for the meeting, reserve your hotel room, and view our preliminary program if you haven’t yet.   We look forward to seeing you in Washington!

Biden Administration Releases First National Strategy for Suicide Prevention

The Biden administration this week released the 2024 National Strategy for Suicide Prevention and accompanying federal action plan to combat America’s deadly mental health and overdose crises. The National Strategy was the result of a combined effort among the Substance Abuse and Mental Health Services Administration, the Centers for Disease Control and Prevention, the National Action Alliance for Suicide Prevention, and more than 20 agencies across 10 federal departments. The National Strategy maps out recommendations for addressing gaps and meeting the needs of at-risk populations, while the federal action plan identifies 200 discrete actions to be initiated and evaluated over the next three years. Actions include identifying ways to address substance use and suicide risk together in the clinical setting; funding a mobile crisis locator for use by 988 crisis centers; increasing support for survivors of suicide loss and others whose lives have been affected by suicide; and evaluating promising community-based suicide prevention strategies. The Biden administration said it will monitor and evaluate these strategies regularly to determine progress and success, and to further identify barriers to successful suicide prevention.

CMS Releases Final Rule on Medicare Managed Care Transparency and Accountability

NABH is pleased with the Centers for Medicare & Medicaid Services’ (CMS) final rule on transparency and accountability for Medicaid managed care plans that the agency released this week. Nearly a year after issuing its proposed rule – and facing firm opposition from healthcare insurance stakeholders – CMS released a rule with provisions that NABH strongly supports, including maximum appointment wait time standards aligned with commercial insurance, including a 10-day wait time standard for outpatient mental health and substance use disorder services. The rule also requires independent annual secret shopper surveys that assess appointment timeliness standards and provider director accuracy. And in an important move toward price transparency, health plans will be required to share their actual expenditures and revenues for state-directed payments and to report any identified or recovered overpayments to states within 30 days. Given the rule’s complex rollout schedule, CMS issued a detailed chart showing the staggered implementation plan for the rule, with effective dates ranging from immediate implementation to four years after its release. Additional information is available in the agency’s fact sheet.

NABH Comments to CMS About Agency’s Accrediting Organization Oversight Rule

NABH recently sent a comment letter to CMS about a proposed rule intended to improve and make more consistent the agency’s oversight of accrediting organizations (AO). NABH supports the rule’s overall direction, which is to improve the accountability and transparency of AO survey and accreditation activities. Of the nine AOs this rule would affect, The Joint Commission is the one of most interest to NABH members. “NABH appreciates that the proposed rule recognizes the current disparity of survey findings among The Joint Commission (and other AOs) and state survey agencies,” NABH wrote in our letter. “Such disparities raise red flags about the misaligned criteria, as well as the reliability of relevant surveyor training programs and preparedness of individual surveyors,” the letter continued. “Current inadequacies have resulted in inconsistent, and therefore at least partially inaccurate, survey findings. This entire process warrants closer examination by CMS of the overall scope and details of these inconsistencies – and the public sharing of related findings with stakeholders.”

NABH Opposes FTC’s Final Rule Banning Non-Compete Agreements

NABH staunchly opposes this week’s final rule banning noncompetes from the Federal Trade Commission (FTC) that the agency said it expects will generate new businesses, raise worker wages, and boost innovation. The FTC estimates that the final rule will lead to new business formation growing by 2.7% per year, resulting in more than 8,500 additional new businesses created each year. The FTC also expects the final will result in higher earnings for workers, with estimated earnings increasing for the average worker by an additional $524 per year; as well as lower healthcare costs by up to $194 billion over the next decade. The U.S. Chamber of Commerce and other business groups filed suit to stop the FTC from banning noncompetes, arguing the FTC doesn’t have the authority to prohibit companies from limiting their employees’ ability to work for competitors.   NABH weighed in on the proposed rule a year ago and acknowledged the FTC’s other efforts to address issues of genuine, unequal bargaining power between certain employers and certain types of workers. However, we opposed the proposed rule for several reasons. “First, the rule proposes an overly simplified, one-size-fits-all approach for all employees across all industries,” NABH said in our March 2023 comment letter. “From a behavioral healthcare perspective, the proposed rule would profoundly alter the healthcare labor market – particularly for physicians and senior hospital executives – by instantly invalidating millions of dollars of existing contracts,” the letter continued. “The rule would affect the full array of NABH members’ employees, including those who are highly trained and lower skilled; as well as both highly compensated and lower-wage employees.”

The Joint Commission Announces New Telehealth Accreditation Program

The Joint Commission this week announced its new Telehealth Accreditation Program for eligible hospitals, ambulatory, and behavioral healthcare organizations. Effective July 1, 2024, the program’s requirements contain many of the standards similar to other Joint Commission accreditation programs, such as requirements for information management, leadership, medication management, patient identification, documentation, and credentialing and privileging. Some requirements specific to the new telehealth program include:
  • Streamlined emergency management requirements to address providing care and clinical support remotely rather than in a physical building.
  • New standards for telehealth provider education and patient education about the use of telehealth platforms and devices.
  • New standards chapter focused on equipment, devices, and connectivity.
The Joint Commission’s announcement noted telehealth use increased by 154% during the COVID-19 pandemic’s early years before stabilizing and presently remaining at levels 38 times higher than they were in 2019.

NABH Telehealth Survey is Due Tuesday, April 30

NABH is eager to learn how your system uses telehealth services in its operations. Please remember to complete this brief survey by Tuesday, April 30, 2024.    Your responses will help guide our advocacy efforts. We also urge you to share this survey with IT colleagues who have insight into how your facilities use telehealth to support your patients. Please email NABH Executive Vice President for Government Relations and Public Policy Rochelle Archuleta if you have questions.

Reminder: The National Academies to Explore Mental Health Services for Anxiety & Mood Disorders in Women

The National Academies Forum on Mental Health and Substance Use Disorder will host a hybrid public workshop in Washington, D.C. and via webcast to explore mental health care services related to anxiety and mood disorders in women on April 29 and 30. Sponsored by the Health Resources and Services Administration, the workshop will examine currently available evidence to identify, define, and prepare strategies for the provision of essential healthcare services related to anxiety and mood disorders in women across the life course. Presentations will also describe health disparities, healthcare finances, and policies related to the quality and access of mental healthcare services available for women.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Researchers have created an AI model that can identify accurately women at risk of child-birth related PTSD, Science Daily reports. The study notes early intervention is critical to prevent progression of a disorder that could carry serious health consequences for as many as 8 million women a year globally.   For questions or comments about this CEO Update, please contact Jessica Zigmond.