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CEO Update | 72

CMS Releases FAQ on Qualified Residential Treatment Programs

The Centers for Medicare & Medicaid Services (CMS) on Friday released a Frequently Asked Questions document that clarifies how the Institutions for Mental Diseases (IMD) Exclusion affects Qualified Residential Treatment Programs (QRTPs). CMS released the document following the Family First Prevention Services Act— included in theBalance Budget Act of 2018—which stipulated restrictions on room and board support for foster children in group care settings. The new law limited that support to 14 days unless the child was in certain settings, including the newly defined QRTP. Here are some important highlights from the agency’s FAQ on Sept. 20:
  • CMS has not made a determination that all QRTPs will be IMDs; rather, there are several options for states to consider regarding QRTPs.
  • QRTPs may qualify as IMDs if they are primarily engaged in providing diagnosis, treatment, or care of persons with mental diseases including medical attention, nursing care, and related services, and have more than 16 beds.
  • State Medicaid agencies must review each QRTP, if over 16 beds, to make a determination if the facility meets the definition of an IMD according to Medicaid statute, regulation and guidance in the State Medicaid Manual.
  • QRTPs also likely would not meet the requirements to qualify as Psychiatric Residential Treatment Facilities (PRTFs), which have more stringent standards… If, however, a QRTP meets the applicable requirements and conditions of participation to qualify as a PRTF, then Federal Financial Participation (FFP) would be available.
  • Medicaid managed care rules permit FFP for monthly capitation payments to managed care plans for enrollees that are inpatients in a residential setting that may qualify as an IMD when the stay is for no more than 15 days during the period of the monthly capitation payment and certain other conditions are met.
  • States may consider an existing section 1115 option, which we further clarify in this document, for states to receive Medicaid reimbursement for services to individuals in QRTPs that would be considered IMDs.
  • Under the 1115 waiver, FFP will not be available for room and board costs in QRTPs, unless they are also certified as PRTFs.
  • States interested in including QRTPs in their section 1115(a) demonstrations will need to determine how best to include stays in QRTPs, recognizing that overall the state will be expected to achieve a statewide average of 30 days as part of these demonstrations.
For questions about the FAQ, contact Scott Dziengelski, NABH’s director of policy and regulatory affairs.

CMS Awards Nearly $48.5 Million to State Medicaid Agencies for SUD Treatment Services

CMS this week announced planning grant awards to 15 state Medicaid agencies to increase providers’ treatment capacity to offer substance use disorder (SUD) treatment and recovery services. The agency awarded nearly $48.5 million in awards to Alabama, Connecticut, Delaware, District of Columbia, Illinois, Indiana, Kentucky, Maine, Michigan, Nevada, New Mexico, Rhode Island, Virginia, Washington, and West Virginia as part of the Substance-Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act.

NABH Supports Senate Bill to Address Nation’s Shortage of Mental Health Professionals

NABH was one of more than 50 organizations this week to support the Mental Health Professionals Workforce Shortage Loan Repayment Act of 2019, a bill intended to help build America’s mental and behavioral healthcare workforce. In a letter to Senators Kamala Harris (D-Calif.) and Cory Gardner (R-Colo.), the Mental Health Liaison Group cited statistics from a 2016 Health Resources and Services Administration report that projected the supply of personnel in selected behavioral and mental health fields to be 250,000 workers short of projected demand in 2025. Meanwhile, the National Institute of Mental Health has reported that nearly one in five adults in the United States experienced a mental or behavioral health problem in the last year alone, the letter noted. In addition to the Senate bill, there is a companion bill in the House of Representatives.

ASAM Seeks Public Comment on Clinical Practice Guideline

The American Society of Addiction Medicine is seeking both member and public comment on the draft of the society’s latest clinical practice guideline on alcohol withdrawal management in both inpatient and outpatient settings. Click here to learn about the methodology and for a copy of the draft guideline. The deadline to submit all comments is Monday, Oct. 7.

National Addiction Treatment Week is October 21-27, 2019

The American Society of Addiction Medicine (ASAM) will host National Addiction Treatment Week from October 21-27, 2019 to raise awareness about the gap in certified addiction medicine care and treatment. The week is also meant to expand the qualified workforce and build awareness around the important need for clinicians to enter the field of addiction medicine. To participate, follow @TreatmentWeek on Twitter and use #hashtag #TreatmentWeek to share your messages about addiction care and treatment.

Save the Date for the NABH 2020 Annual Meeting!

Please save the date and plan to attend the NABH 2020 Annual Meeting at the Mandarin Oriental Washington, DC from March 16-18, 2020. NABH will send Save-the-Date cards with details in late September and will alert members when online registration and hotel reservations are available. We look forward to seeing you in Washington next March!

Fact of the Week

Those who abuse drugs are at an increased risk of infective endocarditis (IE), an infection of the heart. There has been a near doubling in prevalence of drug abuse-related IE from 2002 through 2016, as the condition increased alongside the nation’s opioid crisis.   For questions or comments about CEO Update, please contact Jessica Zigmond.