CEO Update 256
Register Today for the 2026 Annual Meeting and Visit Our Annual Meeting Homepage!
Registration opened this week for the 2026 NABH Annual Meeting, Future-Forward Leadership: Imagine. Innovate. Transform. at The Ritz-Carlton Washington, DC from March 2 – 4, 2026!
Our team in Washington is excited about the 2026 Annual Meeting, and we will e-mail members information about our keynote speakers, new breakout sessions, and more in an Annual Meeting Preview on Friday, Jan. 2.
In the meantime, please visit the Annual Meeting homepage today to view our Schedule At-A-Glance, register for the meeting, reserve your hotel room, and learn about and share our 2026 Exhibitor and Sponsor Opportunities. We look forward to seeing you in Washington!
Reminder: NABH 2026 Board Election Ballots Are Due Wednesday, Dec. 31
NABH asks all system members to please elect new members to the 2026 Board of Trustees by the end of this month.
On Dec. 9, the association e-mailed NABH system members an attachment with NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2026 Board.
If you haven’t yet, please vote for the open NABH Board Chair-Elect position and two available Board seats; sign the ballot; scan it; and send it to nabh@nabh.org or maria@nabh.org no later than Wednesday, Dec. 31, 2025.
Please note your ballot is not valid without a signature. New Board members and the Board Chair-elect will take office in January 2026.
NABH Submits Comments on Proposed Safety and Follow-up Plan Measure
NABH on Dec. 19 submitted comments to CMS about the proposed Post-Discharge Safety and Follow-up Plan for Patients with Suicidal Ideation measure, which the agency is considering including in the Inpatient Psychiatric Facility Quality Reporting Program.
In our comments, we noted our support for safety planning, which has a strong evidence base. However, we did not support including the discharge planning component of the measure, which does not have the same evidence-based support for use among all patients admitted to Inpatient Psychiatric Facilities. We highlighted this lack of evidence as well as the burden of discharge planning in our letter. Meanwhile, we recommended re-examining exclusions.
CMS posted measure information, specific questions, and directions for submitting public comments on its Measures Management System.
NABH to Launch Quality Measure Initiative in 2026
NABH will launch an initiative in 2026 to improve behavioral health quality measurement.
Led by Quality Committee co-chairs Frank Ghinassi, Ph.D., A.B.P.P. and Karen Johnson, M.S.W., NABH will form a subcommittee to review validated quality measures for both mental health and substance use. The subcommittee will identify the best quality measures in key domains, determine gaps in quality measure research, and engage with behavioral health stakeholders to come to a consensus on key quality indicators.
NABH’s ultimate goal is to standardize and improve measurement across the industry. For more information, please contact Sarah Steverman, the NABH staff leader for the initiative.
NABH Urges Strong Federal Enforcement of Mental Health Parity
NABH and a group of behavioral health stakeholders sent a letter this week to the Secretaries of Labor, Health and Human Services, and Treasury – whose respective agencies regulate health plans – recommending they strongly enforce the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA).
The letter describes the high rates of MHPAEA violations and growing congressional scrutiny of utilization management controls (e.g., prior authorization) that impede access to care. The letter also suggests mechanisms to improve compliance, such as requiring insurers to use data to monitor compliance instead of solely self-attestation, issuing more detailed guidance for insurers, and leveraging civil monetary penalty authorities.
President Trump Signs Executive Order to Reschedule Marijuana
President Trump on Thursday issued an Executive Order to reschedule marijuana from Schedule I to Schedule III, which would eventually enable U.S. Food and Drug Administration-approved marijuana products to be prescribed legally for medical purposes under the federal Controlled Substances Act.
Marijuana is one of the most commonly used recreational drugs and marijuana use disorder is a major contributor to the national burden of substance use disorders, with more than 20 million people aged 12 and older reporting a past-year marijuana use disorder in 2024. Meanwhile, anecdotal reports and some research studies have demonstrated a positive clinical effect of marijuana for some conditions, including pain, anorexia related to a medical condition, and nausea and vomiting. Based on this evidence, HHS in 2023 recommended that the Drug Enforcement Administration (DEA) reschedule marijuana to Schedule III.
While states have permitted marijuana to be dispensed for medical or recreational purposes for many years, per federal law, it has been illegal to use outside of research studies. However, in 2013, the U.S. Justice Department issued a memorandum exercising enforcement discretion that has largely stopped prosecutions outside of major trafficking.
To effectuate the Executive Order, the DEA must undergo rulemaking to reschedule marijuana.
CMS Releases Psychiatric Inpatient Experience (PIX) Survey Resources for IPFs
CMS released new resources for the Psychiatric Inpatient Experience (PIX) Survey, a new requirement for the Inpatient Psychiatric Facilities Quality Reporting (IPFQR) Program.
For calendar year (CY) 2025, CMS encouraged voluntary reporting of the PIX Survey; however, the mandatory reporting period begins in CY 2026. CMS posted the resources on the IPFQR Program Resources webpage of QualityNet and the IPFQR Program Resources and Tools webpage of the Quality Reporting Center.
The new PIX Survey Resources are the Comma-separated Value (CSV) Data Collection Template and Instructions, Data Dictionary, Extensible Markup Language (XML) File Layout and Instructions, File Upload Edit Messages, PIX Survey – Spanish Version, and PIX Emoji Scale.
House Passes Healthcare Bill That Does Not Address Expiring ACA Tax Credits
The House passed a conservative healthcare bill Wednesday evening that did not address expiring Affordable Care Act (ACA) tax credits, all but guaranteeing the enhanced subsidies will lapse at the end of the year.
H.R. 6703, the Lower Health Care Premiums for All Americans Act, would expand association health plans by allowing employers to offer their own coverage and would codify a rule permitting employers to fund health reimbursement arrangements for workers purchasing individual-market plans.
The bill would also fund the ACA’s required cost-sharing reductions, eliminating the need for insurers to raise silver-level premiums. The Congressional Budget Office (CBO) estimated that enacting the GOP’s health plan would decrease the number of people with health insurance by an average of 100,000 a year over the 2027-2035 period. This would add to CBO’s previous estimate that 4 million people would become uninsured if Congress allowed the ACA subsidies to expire. Ultimately, NABH expects the bill will be dead on arrival in the Senate.
Hours before the House bill passed, four House Republicans – Reps. Robert Bresnahan (Pa.), Brian Fitzpatrick (Pa.), Mike Lawler (N.Y.), and Ryan Mackenzie (Pa.) — signed onto Minority Leader Hakeem Jeffries’s (D-N.Y.) discharge petition to force a vote on a clean three-year extension of the subsidies, bringing the number of signatures to 218, the threshold required to force a vote on the floor. This sets in motion a January House vote that Democrats and moderate Republicans lawmakers signaled could be a glide path toward a compromise.
NABH sent letters to the House and Senate about the ACA’s positive effects on expanding behavioral healthcare and urged extending the ACA’s enhanced tax credits.
‘American Journal of Managed Care’ Examines Impact of Medicaid’s IMD Exclusion on SMI Outcomes
A new study published in the American Journal of Managed Care concluded that Institutions for Mental Diseases (IMD) exclusion waivers have a “beneficial impact” on psychiatric-specific and all-cause healthcare utilization and costs as well as incarceration rates for individuals with serious mental illness (SMI).
Medicaid’s IMD exclusion forbids federal funding for treatment in facilities with more than 16 psychiatric beds; however, some states have obtained waivers under Section 1115 of the Social Security Act to increase options for treating SMI. This new, retrospective claims study assessed healthcare resource utilization, costs, homelessness, and incarceration among Medicaid beneficiaries with SMI in states with and without waivers.
According to the study, the odds of having psychiatric-specific inpatient admissions and emergency department (ED) visits were lower by 14% and 26%, respectively, in the waiver cohort (n = 130,224) versus the non-waiver cohort (n = 3,102,971). Odds of all-cause inpatient admissions and ED visits were also lower (9% for both) in the waiver cohort, but the odds of having all-cause outpatient visits were 19% greater in the waiver cohort.
“Although the IMD exclusion was put into place to protect patients from prolonged institutionalization, our findings indicate that state waivers allowing treatment in IMDs do not lead to increased psychiatric hospitalization,” the study noted. “Additional state-level policies such as Medicaid Health Homes and Medicaid expansion should be considered by state policymakers and Medicaid administrators when assessing the risk-benefit trade-offs of investing in mental health services.”
Fact of the Week
Among U.S. adults, 41% say they anticipate more stress related to the holidays this year than last year, a notable increase from 2024 (28%) and 2023 (29%), according to a recent APA Healthy Minds poll.
Happy Holidays from NABH!
NABH will not publish CEO Update on Friday, Dec. 26. Instead, please look for a 2026 Annual Meeting Preview on Friday, Jan. 2. CEO Update will resume on Friday, Jan. 9.
The entire NABH staff wishes you, your families, and your teams a very happy, healthy, and safe holiday season!
For questions or comments about this CEO Update, please contact Jessica Zigmond.