CEO Update 209
NABH Expresses Serious Concerns About MOTAA in Letter to House and Senate Leaders
NABH this week sent a letter to House and Senate leaders that reinforced the association’s concerns that the Modernizing Opioid Treatment Access Act (MOTAA) [S. 644/ H.R. 1359] is a misguided attempt to deregulate opioid treatment programs (OTPs), the effective standard of treatment for opioid use disorders (OUDs).
In our letter, NABH highlighted three areas of potential, unintended consequences and harms that may result from legislation proposing such abrupt and expansive regulatory changes: the risk of diversion and increases in overdose deaths, the risk of relying on community pharmacies to fill the gap in patient access to care, and the potential for significant harm to populations that already suffer from health inequities.
“In addition to the noted dangers, the wholesale regulatory change that would result from this legislation would be difficult to implement,” the letter said. “Other organizations share this practical concern, including law enforcement leaders who note that the proposed changes in MOTAA would lead to more overdose deaths and diversion of methadone…”
NABH suggested a more cautious approach to addressing concerns about access to methadone, such as pausing to study carefully the effects of the significant recent efforts to expand access, with a specific focus on understanding the root causes behind incremental of OUD-related overdoses as well as the disproportionate harm suffered by marginalized populations; and encouraging new models of care whereby OTPs can collaborate with local pharmacies to allow stable patients and patients living in rural settings to pick up their OTP-prescribed methadone outside of OTPs.
SAMHSA Releases OTP Guidelines that Align with Regulations Released This Year
The Substance Abuse and Mental Health Services Administration (SAMHSA) on Wednesday released Federal Guidelines for Opioid Treatment Programs to provide recommendations and best practices for OTPs related to the implementation and compliance of regulatory changes in 42 CFR Part 8 that became effective in April and for which OTPs were required to comply starting on Oct. 2, 2024.
The revised regulations took steps to increase access to evidence-based medications for opioid use disorder, or MOUD, and promote practitioner discretion; support patient-centered care; reduce barriers to treatment; and remove stigmatizing or outdated language from the 2001 regulations.
The newly released guidelines replace guidelines published in 2015.
Call for Behavioral Healthcare Clinicians to Help Develop IPF Patient Assessment Instrument
The Centers for Medicare & Medicaid Services (CMS) and its contractor Abt Global are recruiting psychiatrists, psychologists, nurses and other behavioral healthcare clinicians to help develop and test a draft patient assessment tool known as the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).
CMS’ primary objectives for this significant policymaking process to improve both quality of care and payment accuracy. Eventually, the agency plans to require that a common PAI be used during admission and discharge of every IPF patient.
NABH has confirmed with CMS that our members will have multiple opportunities to weigh in on this project. We strongly urge your participation in the alpha stage, during which Abt will identify the PAI data elements to field-test – a critical stage that requires real-world input from our field.
To join the alpha stage of IPF PAI development, please apply here by Dec. 30, 2024.
SAMHSA Issue Brief Offers Information on Co-Occurring Mental Health and Substance Use
SAMHSA has released an issue brief for State Mental Health Authorities (SMHA) about co-occurring mental health and substance use disorders (CODs).
The document highlights the commonality of CODs and negative outcomes in the absence of evidence-based integrated care. It also provides an overview of treatment barriers and potential solutions and the effectiveness of integrated care.
Call for Presenters: NABH to Kick Off AI Webinar Series in 2025
NABH is seeking presenters who have integrated AI in their business operations to share their experiences in the association’s new webinar series about AI in behavioral healthcare scheduled for Spring 2025.
The first webinar will focus on using AI to reduce administrative burden and create efficiencies, and the second webinar will highlight using AI for clinical-decision support.
Please contact NABH Associate Manager for Congressional Affairs Emily Wilkins at Emily@nabh.org by close of business on Monday, Dec. 16 if you want to participate.
ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations
NABH recently hosted a webinar about using hospital data effectively in your negotiations with health plans.
The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. Please click here for the webinar’s recording and here for the presentation slides.
Please Submit Data to NABH’s Denial-of-Care Portal
We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.
Fact of the Week
A study published in Health Affairs this month found that in 2021, 42.8% of U.S. children ages 5-17 lived with an adult who had at least four adverse childhood experiences (ACEs). The report noted that childhood exposure to adult ACEs was correlated negatively with child mental health, particularly among children living in low-income and publicly insured families.
For questions or comments about this CEO Update, please contact Jessica Zigmond.