CEO Update 254

2026 Annual Meeting Schedule At-A-Glance Now Available!

This month NABH will open registration for our 2026 Annual Meeting, Future-Forward Leadership: Imagination. Innovation. Transformation, which will take place at The Ritz Carlton-Washington, DC from March 2-4, 2026.

Before then, please take a moment to review our 2026 Annual Meeting Schedule At-A-Glance, which includes times for general sessions, committee meetings, time with exhibitors and sponsors, and new breakout sessions focused on new approaches to outpatient treatment, payor issues, policy, and quality. Please note we will not host Hill Day in conjunction with the 2026 Annual Meeting.

We hope you join us, and please look for Annual Meeting updates in member alerts and upcoming issues of CEO Update!

CMS Releases CY 2026 Hospital Outpatient Prospective Payment System Final Rule

Before Thanksgiving, the Centers for Medicare & Medicaid Services (CMS) published the calendar year (CY) 2026 Hospital Outpatient Prospective Payment System (OPPS) final rule, which finalizes hospital outpatient prospective payment rates and updates Medicare payment rates for intensive outpatient program (IOP) and partial hospitalizations program (PHP) services furnished in hospital outpatient departments and Community Mental Health Centers (CMHCs).
 
For both IOP and PHP services, CMS finalized its proposal to maintain the existing rate structures and use OPPS data to calculate costs for three services per day and for four or more services per day. In addition, CMS finalized its proposal to change the methodology for calculating the CMHC IOP and PHP costs based on 40% of the final hospital-based IOP and PHP costs. This change resolves a cost inversion in CMHC cost data that would otherwise result in higher payment for three-service days than for four-service days.. The below table shows the final CY 2026 PHP and IOP per diem costs compared with the CY 2025 costs.

The final rule also includes updates to the Overall Hospital Quality Star Rating; finalizes changes to the Hospital Outpatient Quality Reporting and Rural Emergency Hospital Quality Reporting Programs; and reviews responses to a Request for Information on future measure concepts related to well-being and nutrition.

NABH Will Recommend Medicaid Community Engagement Requirements to CMS

NABH is developing recommendations to advise CMS and states about how to best implement statutory exceptions to the community engagement requirements – commonly referred to as “work requirements” – for people with mental and substance use disorders.

Passed by Congress in July, H.R. 1 exempted people with substance use disorders and disabling mental health conditions, and NABH is urging CMS to promulgate guidance and regulations that minimize disruptions in Medicaid coverage and reduce burden on providers and patients.

NABH staff held a meeting with our members this week to discuss proposed recommendations, and the NABH team is preparing a letter to CMS for NABH members to review. We expect CMS will publish preliminary guidance very soon for states seeking to implement requirements sooner than Jan. 1, 2027, the date by which H.R. 1 mandates states comply. CMS will then publish an interim final rule with detailed, binding implementation requirements by June 1, 2026.

In related news, the Kaiser Family Foundation (KFF) this week launched an interactive tool with key data and policies that will affect how states implement Medicaid community engagement requirements. KFF plans to update the tracker as CMS releases additional guidance and states begin implementation.

While NABH is focused presently on advocating for good policy with CMS, our team believes this tool will be useful for our state-based advocacy to encourage states to implement community engagement requirements that protect Medicaid access for people with mental health and substance use conditions and reduce burden for providers and patients.

Senate Democrats Introduce Plan for Healthcare Vote Next Week

Senate Minority Leader Chuck Schumer (D-N.Y.) on Thursday unveiled Democrats’ plan for a healthcare vote next week on a clean, three-year extension of the Affordable Care Act (ACA) tax credits. The Democratic bill is unlikely to garner the 60 votes needed to pass.

The ACA’s Enhanced Premium Tax Credits (EPTC) for marketplace policies expire at the end of the year, leading to significant cost increases for exchange enrollees in 2026. Senate Democrats who supported ending the government shutdown last month secured a promise from Senate Majority Leader John Thune (R-S.D.) to hold a vote on the issue next week.

Meanwhile, Senate Republicans are still considering whether to present a healthcare counterproposal to vote on next week. If such legislation is proposed, it will likely include income caps and other new restrictions.

Most GOP lawmakers in the House and Senate remain opposed to the ACA and to renewing the enhanced tax credits, which President Joe Biden and the Democratic majority created as a COVID-19 relief measure in 2021. House Speaker Mike Johnson (R-La.) has not pledged to allow a vote in the lower chamber; however, House committee chairs are working to finalize a Republican healthcare plan that could be considered next week. It would likely include various GOP bills aimed at providing more healthcare coverage options outside of the ACA. President Trump has wavered about whether to let the enhanced subsidies lapse.

Although the EPTCs are scheduled to expire Dec. 31, some Members of Congress consider the Jan. 30, 2026 expiration of the current Continuing Resolution as the next deadline for a compromise ACA bill that would be coupled with the next government funding package.

NABH will send a letter to senators and is contacting their respective offices about the ACA’s EPTCs and its effect on expanding access to behavioral healthcare.

SAMHSA to Host Webinar This Month on How Substance Use Trends Affect Child Safety

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar later this month to explore how substance use trends affect child safety and family risk factors.

National experts will highlight insights from the National Opioid Environmental Scan, discuss the rise of fentanyl and other substances, and offer strategies to improve outcomes for families.

The hourlong webinar will begin at 2 p.m. ET on Wednesday, Dec. 17. Click here to register. 

WHO Release Mental Health Report  

The World Health Organization (WHO) recently released guidance on policy and strategic actions to protect and promote mental health and well-being across government sectors.

Based on the premise that every sector – health, culture, arts, sports, defense, veterans, education, environment, and workforce – has a role to play in protecting and promoting mental health, the 236-page document is intended as practical roadmap for action.

”The cost of neglect is high,” the WHO cautions in the guidance. “It undermines individual well-being, family stability, societal cohesion, and economic performance. By contrast, investing in mental health delivers wide-ranging benefits, boosting economic productivity, strengthening communities, improving well-being, and building more equitable and resilient societies.”

Fact of the Week

A recent JAMA Network study of 373 participants found that a one-week social media detox intervention significantly reduced symptoms of anxiety by 16.1%, depression by 24.8%, and insomnia by 14.5%

For questions or comments about this CEO Update, please contact Jessica Zigmond.