Author: Administrator

NABH Submits FY27 IPF PPS Payment Rate and PAI Comments to CMS

NABH this week submitted comprehensive comments and recommendations to the Centers for Medicare & Medicaid Services (CMS) about the agency’s Fiscal Year 2027 Inpatient Psychiatric Facility Prospective Payment Systems (IPF PPS) proposed rule, including the association’s serious concerns with the agency’s Patient Assessment Instrument (PAI) that takes effect next year.

“The proposed IPF-PAI is based on a post-acute model of care and is not appropriate for an acute inpatient psychiatric treatment setting,” NABH wrote in our letter. “While we support Congress’ intent to standardize assessment to enable comparison of quality and outcomes across IPFs, the IPF-PAI is not clinically meaningful, does not address psychiatric hospital quality, will not serve as a tool for treatment planning, and cannot measure mental health outcomes,” the letter continued. “If the Centers for Medicare & Medicaid Services (CMS) implements this tool as proposed, the IPFs will incur a huge burden without any clinical benefit to patients.”

NABH thanks its members, especially those who serve on the NABH Quality Committee, for sending comments that we included in the letter.

ICYMI: CMS Issues Interim Final Rule on Medicaid Community Engagement Requirements

CMS earlier this week issued the interim final rule (IFR) on the Medicaid program’s Community Engagement Requirement for Certain Individuals.

This IFR implements Sec. 71119 of H.R. 1 (also known as the One Big Beautiful Bill Act and the Working Families Tax Cut legislation), which conditioned Medicaid eligibility on completing 80 hours per month of community engagement activities (i.e., work, community service, or educational activities).

Statutory exceptions to community engagement requirements include people who are medically frail, which includes having a substance use disorder (SUD) or disabling mental disorder (DMD). The IFR does not define either SUD or DMD but rather indicates that states will need to adopt lists of qualifying conditions and implement a process for individuals to request an exemption due to a condition excluded from the list. Importantly, the IFR clarifies that people with SUDs would only qualify for the SUD exemption if they have been in recovery for fewer than five years, and active treatment participation is not needed to qualify.

States are required to prioritize assessing exception eligibility using their existing data. For individuals whom states cannot verify as medically frail using their existing data, practitioners can submit documentation to demonstrate eligibility. Otherwise, individuals can self-attest to medical frailty and enroll in Medicaid for six months before information is required to substantiate their attestation. If states grant the medically frail exception, they would need to reassess this exception at least annually.

Congress directed CMS in H.R. 1 to implement community engagement requirements via an IFR, a type of regulation that bypasses a public comment process on a draft version of a rule before it takes effect. 

The NABH team will continue to review the IFR, which takes effect on July 31, 2026, the same day public comments are due. However, states do not need to implement the IFR’s provisions until Jan. 1, 2027.

NABH Weighs in on Managing the High Cost of Mental Healthcare in Kiplinger Article

The finance publication Kiplinger recently contacted NABH for a story about managing the costs of mental healthcare in the fourth of a five-part series that explores the connection between money and health.

The article explained that one of the biggest challenges for people with insurance coverage is finding mental health providers in their plan’s network. The story also acknowledged that evidence is “plentiful” that mental health treatment is still not on par with benefits for medical and surgical care.

“No question, there is a big gap,” says NABH Board Member Mark Covall, who served as the association’s interim president and CEO when Kiplinger reported the story.

SAMHSA Releases Case Study Guide on Postpartum OUD Care Transitions

The Substance Use and Mental Health Services Administration (SAMHSA) has releasedHealthy Starts: Postpartum OUD Care Transitions for Mother and Infant, a publication that summarizes information about the postpartum period and offers practical advice for care teams about comprehensive, collaborative, perinatal care.

According to SAMHSA, the postpartum period is a critical time for connecting mothers, parents, and caregivers with services and support to promote bonding, well-being, and healthy outcomes for families.

The agency also notes that the first postpartum year is an especially high-risk period for women with an opioid use disorder, and that evidence-based treatment options, such as medication for opioid use disorder, can help reduce these risks.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC. 

In the near term, here are some upcoming behavioral healthcare-related events:

• The American Mental Health Counselors Association annual event for professionals will be held June 23–26, 2026 in Portland, Ore.
• The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29, 2026 in Washington, D.C.
• The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC.

Fact of the Week

U.S. drug overdose deaths declined 13.9% in 2025 compared with the previous year, the CDCreports.

For questions or comments about this CEO Update, please contact NABH Operations Coordinator Shelby Liebler.

Deadline to Submit Comments on the Proposed IPF Patient Assessment Instrument is Monday

As part of its Fiscal Year 2027 Inpatient Facilities Prospective Payment System proposed rule, the Centers for Medicare & Medicaid Services (CMS) has developed an inpatient psychiatric facility patient assessment instrument (IPF-PAI) for required reporting that takes effect on Oct. 1, 2027.

NABH has significant concerns about the IPF-PAI and has drafted detailed comments that we will submit to CMS this Monday, June 1. Our letter also includes comments about the payment portion of the proposed rule, including the annual rate increase and proposed changes to the outlier policy.

The proposed instrument is based on a post-acute model of care and is inappropriate for an acute inpatient psychiatric treatment setting. In addition, the IPF-PAI will not address quality, serve as a tool for treatment planning, or measure mental health outcomes. Our comment letter also emphasizes that implementing the IPF-PAI implementation will be incredibly burdensome for IPFs and will not add any clinical benefit.

We urge NABH members to submit their own comments about the proposed IPF-PAI. NABH Vice President of Quality and Regulatory Affairs Sarah Steverman previously sent a comment template and submission information to members of the Quality Committee and Behavioral Health Services within General Healthcare Systems (“Unit”) Committee. Please contact Sarahfor the template or for more information.

Comments are due to CMS by Monday, June 1. 

Coming Soon: H.R. 1/OBBBA’s Interim Final Rule on Medicaid’s Community Engagement Requirements

NABH expects CMS to release its interim final rule on the Medicaid program’s community engagement requirements in the coming days.

For this national policy – which takes effect on Jan. 1, 2027 – CMS requires states to condition Medicaid eligibility for adults between the ages of 19 and 64 in the Medicaid expansion population on demonstrating at least 80 hours per month of community engagement, such as work, job training, education, or volunteering. 

The “medical frailty” standard in the Community Engagement requirements rule (also known as “work requirements”) includes a provision exempting those with substance use disorder and disabling mental illness from the requirements.

NABH will share an analysis with members after CMS releases the rule.

Preview Your IPF Quality Data that CMS Will Release Publicly in July

The CMS Hospital Quality Reporting (HQR) page will allow visitors to preview hospital or inpatient psychiatric facility quality data through June 20 that will appear publicly on Compare tool on Medicare.gov and the Data Catalog on data.cms.gov in July.

Medicare beneficiaries and the public can use these tools to view quality measure data for participating hospitals and facilities.

Members may submit questions to Inpatient and Outpatient Healthcare Quality Systems Development and Program Support through the QualityNet Question and Answer Tool. CMS will also take questions by phone; for inpatient questions call (844) 472-4477 or (866) 800-8765 weekdays from 9 a.m. to 5 p.m. ET and for outpatient questions call (866) 800-8756 weekdays from 9 a.m. to 5 p.m. ET.

Kaiser Family Foundation Analysis Highlights Mental Illness Prevalence Among States

Oregon, Vermont and Washington, DC have the highest prevalence of any mental illness (AMI) among the states, while New Jersey, Hawaii, and South Carolina have the lowest, according to a new analysis from the Kaiser Family Foundation (KFF). 

KFF used data from the Substance Abuse and Mental Health Services Administration’s (SAMHSA) National Survey on Drug Use and Health 2023 and 2024 (NSDUH) and noted that respondents were classified as having AMI if they reported symptoms consistent with a probable mental, behavioral, or emotional disorder in the past year, sufficient to meet criteria based on the fourth edition of the Diagnostic and Statistical Manual of Mental Disorders.

Other states with high prevalence of AMI include West Virginia, Washington, New Hampshire, Tennessee, Utah, Maine, and Arkansas, the data showed.

Reminder: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC. 

In the near term, here are some upcoming behavioral healthcare-related events:

• The American Mental Health Counselors Association annual event for professionals will be held June 23–26, 2026 in Portland, Ore.
• The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29, 2026 in Washington, D.C.
• The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC. 

Fact of the Week

The percentage of youth reporting serious thoughts of suicide decreased to 10.1% from 12.3% between 2023 and 2024, Mental Health America reports. 

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

CMS Releases Medicaid State-Directed Payment Rule

The Centers for Medicare & Medicaid Services (CMS) on Wednesday released a proposed rule on state-directed payments (SDPs) that seeks to align Medicaid payments with Medicare.

CMS’ proposal would cap SDPs at 100% of Medicare rates in states that expanded Medicaid and 110% in non-expansion states for rating periods beginning on or after July 4, 2025.

Hospital industry groups responded to the rule by saying the changes will affect their members’ ability to treat the nation’s most vulnerable patients.

Click here to see the agency’s fact sheet about the proposed rule. 

NABH and Partners Urge Congressional Leaders to Support Children’s Hospitals Graduate Medical Education

NABH this week joined 24 other national organizations in signing a letter urging leaders of the House and Senate Appropriations Committees’ Subcommittees on Labor, Health and Human Services, Education and Related Agencies to provide $1.02 billion in FY 2027 to fund Children’s Hospital Graduate Medical Education (CHGME).

Our letter emphasized that CHGME-funded training is critical for pediatricians and pediatric specialists, including child and adolescent psychiatrists. Since its founding in 1999, the federal CHGME program has helped mitigate our nation’s healthcare workforce shortage through increased pediatric physician training.

Your Feedback Welcome: Please Submit Comments on Draft Drug Testing Consensus Statement

The American Society of Addiction Medicine and the American College of Medical Toxicology have made available for public comment a draft of their updated Clinical Consensus Statement on Drug Testing in Substance Use Disorder Treatment.

This statement provides guidance on the appropriate use of drug testing, including addressing risks such as misapplication, misinterpretation, and potential harm to patients. Comments are due by Tuesday, June 30 for those interested in providing feedback. Click here for detailed instructions and the submission form.  

Please contact Dan Schwartz, NABH’s vice president of public policy, if you have questions.

CMS Finalizes 2027 Rule for Marketplace Plans

CMS this week also issued the 2027 Notice of Benefit and Payment Parameters final rule, which includes several notable changes pertaining to Marketplace plans:

• Expanding requirements for states to defray the cost of all state-mandated benefits based on state actions since 2012. Importantly, CMS clarified in the final rule that states would not need to defray any benefits added to an essential health benefits benchmark plan since 2012 to comply with federal requirements, including the Mental Health Parity and Addiction Equity Act.
• Removing quantitative network adequacy standards for plans in state-based exchanges, state-based exchanges on the federal platform, and states with an effective provider access review program on the federally facilitated exchange.
• Permitting qualified health plan certification for plans without a provider network.
• Raising the cost-sharing limits for bronze and catastrophic plans.

NABH opposed these changes in our comments on the proposed rule.

SAMHSA Awards $255 Million to Vibrant Emotional Health to Administer 988 Lifeline

The Substance Abuse and Mental Health Services Administration (SAMHSA) late last week awarded $255 million to Vibrant Emotional Health, a New York-based operator of crisis hotlines, to administer the 988 Suicide & Crisis Lifeline.

SAMHSA also announced more than $28 million in new funding opportunities, including:

• $15.1 million for Garrett Lee Smith State/Tribal Suicide Prevention and Early Intervention, which supports states and tribes in implementing youth suicide prevention and early intervention strategies;
• $8 million for the Community Programs for Youth and Young Adults at Clinical High Risk for Psychosis (CHR-P), which identifies youth and young adults, age 25 and younger, at clinical high risk for psychosis and provides evidence-based interventions to prevent the onset of psychosis or lessen the severity of psychotic disorder;
• $3 million for the Providers Clinical Support System – Substance Use Disorder Treatment (PCSS-SUD Treatment), which combines two previous grants—Providers Clinical Support System – Medications for Alcohol Use Disorders (PCSS-MAUD) and Providers Clinical Support System – Medications for Opioid Use Disorders (PCSS-MOUD)—into a comprehensive program that focuses on provider education and support for substance use disorders; and
• $2 million for the Disaster Distress Helpline, a national hotline dedicated to providing year-round disaster crisis counseling. The helpline, available via 1-800-985-5990 or www.samhsa.gov/ddh, provides 24/7, toll-free, confidential crisis counseling to individuals in the United States and its territories experiencing emotional distress related to natural or human-caused disasters.

Fact of the Week

60.9% of veterans who died by suicide in 2023 (the most recently available data) had a Veterans Health Administration mental health or substance use disorder diagnosis, the Veterans Administration reports.   

The NABH team thanks all its members and their families who have served in the U.S. Armed Forces. We wish everyone a safe and relaxing Memorial Day weekend!

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

NABH Submits Statement to House Ways and Means Committee on PAI Quality Measure

NABH this week submitted a statement for the record to the House Ways and Means Committee highlighting our serious concerns with the new patient assessment instrument (PAI) quality measure that the Centers for Medicare & Medicaid Services (CMS) proposed in the Fiscal Year 2027 Inpatient Psychiatric Facilities Prospective Payment System rule that takes effect in October 2027.

Our statement notes that the PAI 1) is not clinically relevant to psychiatric care, 2) does not improve the outcomes for psychiatric patients, and 3) is an enormous burden for psychiatric hospitals and units.

“This measure will increase healthcare costs by requiring providers to do unnecessary tests that have no clinical relevance,” our statement said. “However, the real problem for the fiscal solvency of the Medicare program is that CMS intends to consider the results of this measure in how they calculate payments for psychiatric hospitals and units during future rule makings.”

Click here to read our full statement.

Congratulations to NABH Board Member Frank Ghinassi on N.J. Quality Institute Appointment

NABH congratulates board member and NABH 2024 Board Chair Frank Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers University Behavioral Health Care, for his appointment to the New Jersey Health Care Quality Institute’s Board of Directors.

Ghinassi, who also serves as senior vice president of the behavioral health and addictions service line at RWJBarnabas Health, was appointed to the board this week along with former New Jersey State Treasurer Elizabeth Maher Muoio, J.D., and Heather Howard, J.D., a former New Jersey commissioner of health and senior services who now serves as professor of the practice at Princeton University’s School of Public and International Affairs.

“We are thrilled to welcome Frank, Liz, and Heather to our Board,” Linda Schwimmer, president and CEO of the New Jersey Health Care Quality Institute, said in an announcement. ““Each brings a powerful perspective at a critical moment for New Jersey’s healthcare system,” she continued. “From strengthening behavioral health services to understanding how major public programs and purchasers can drive value, to shaping and implementing policy at the state and national level, their leadership will help us advance our mission to improve safety, quality, and affordability of healthcare.”

The New Jersey Health Care Quality Institute has served as an independent, not-for-profit organization devoted to transforming healthcare since 1997.

U.S. Drug Overdose Rates Drop for Third Consecutive Year

Drug overdoses in the United States dropped nearly 14% in 2025, marking a third consecutive year of declines, according to Centers for Disease Control and Prevention provisional datareleased this week.

Nearly 69,973 people died ​from drug overdose in the ​United States in 2025, compared with 81,313 ⁠deaths estimated a year earlier, the data show.

The national not-for-profit organization Shatterproof released a statement that said although the group is encouraged by the CDC’s provisional data, nearly 70,000 lives lost to overdose remains a public health crisis.

Last Call: Please Submit NABH’s Payor Experience Survey by Tuesday, May 19!

Thank you to all members who completed NABH’s payor experience survey, which will help our Washington-based team understand our members’ experiences with increased payor pressures, including reduced approved lengths of stay/treatment, pre- and post-payment review, revenue cycle challenges, and administrative denials.

We will close the survey on Tuesday, May 19. Please respond today if you haven’t yet!

Reminder: CMS to Explore Strategies for Rural Health Financial Sustainability in Upcoming Webinar

CMS will host a 45-minute webinar later this month that provides strategies to strengthen and sustain rural health systems.

The webinar will examine how the rural emergency hospital model and technical assistance support access and financial sustainability, key shifts to value-based and alternative payment models, and what’s next for rural health.

Click here to register for the webinar, which starts at 1 p.m. ET on Wednesday, May 20.

Fact of the Week

35% of non-elderly adults enrolled in Medicaid have a mental illness, including 10% with a serious mental illness, the Kaiser Family Foundation reports.

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

White House Releases 2026 National Drug Control Strategy

The White House Office of National Drug Control Policy this week released its 2026 National Drug Control Strategy (NDCS) that describes the federal government’s approach to address the nation’s illicit drug crisis.
 
The NDCS identified several action items related to substance use disorder (SUD) treatment, including enhancing early intervention, promoting treatment availability, ensuring access to evidence-based treatment for non-opioid SUDs, improving outcomes for people with SUD involved in the criminal-legal system, and pursuing national consensus-based standards for SUD treatment.
 
The NDCS also emphasized the value of faith in supporting drug use prevention and SUD treatment.

MACPAC Offers Recommendations to Address Residential Behavioral Health Treatment for Children in Medicaid

The Medicaid and CHIP Payment and Access Commission (MACPAC) on Thursday included specific recommendations for residential behavioral health treatment for children in Medicaid in a draft chapter the commission will include in its June 2026 report to Congress.
 
Draft Recommendation 1 suggests Congress require HHS to develop and maintain a directory of youth residential treatment facilities to ensure states, families, and providers have complete, accurate, and updated information about residential treatment facilities and bed availability; and Draft Recommendation 2 recommends the Centers for Medicare & Medicaid Services (CMS) report on the use of residential treatment services, including non-psychiatric residential treatment facilities and out-of-state providers.
 
Click here for more detailed information from MACPAC’s presentation on Thursday, May 7.

NABH Sends Feedback on BRIDGES Act Discussion Draft to U.S. Senate Finance Committee

NABH on Thursday sent comments to the U.S. Senate Finance Committee about a discussion draft of the Better Results through In-community Delivery, Greater Enforcement, and Stronger Services (BRIDGES) for Kids Act, a proposal that Sen. Ron Wyden (D-Ore.), the panel’s ranking member, released last December.
 
Our letter emphasized that the United States lacks sufficient capacity to serve children with behavioral health conditions across all levels of care, and that this lack of capacity is disproportionately concentrated within the higher levels of care, creating a mismatch where children with the most severe conditions are the least likely to get treatment.
 
“Access to youth residential treatment is a prime example of this problem,” our letter said. “Many children can be treated successfully in community-based outpatient programs; however, some children have more severe conditions that require higher-intensity services, including residential treatment. Accessing residential treatment is increasingly difficult because the number of centers has sharply declined to only 461 in 2024 from 848 in 2012. Despite NABH members’ best efforts, we need federal action to ensure children can access medically necessary residential treatment. We encourage the Committee to consider policies that support this.”
 
We also explained that NABH members are expanding access to the full behavioral healthcare continuum so children with serious emotional disturbances and substance use disorders receive timely, medically necessary treatment.
 
Our thanks to members of the NABH Youth Services Committee who contributed helpful information that we included in our letter.

NABH and Coalition Partners Comment on President’s Fiscal Year 2027 Budget Proposal

Also this week, NABH joined more than 90 national and state organizations in urging the leaders of the House and Senate Appropriations Committees to maintain strong, dedicated federal investments in overdose prevention, SUD treatment, and recovery support services in the FY 2027 appropriations process.
 
Our collective comments follow President Trump’s recent fiscal year 2027 budget proposal and ask congressional leaders to maintain total funding for these programs at no less than FY 2026 enacted levels; preserve substance use and overdose prevention and response as specific and protected priorities; strengthen accountability for overdose-related outcomes; retain states’ capacity to fund evidence-based treatment at scale; and ensure agencies retain sufficient staffing to implement, monitor, and evaluate the programs effectively.

NABH Board Treasurer Stuart Archer of Oceans Healthcare Testifies at La. Field Hearing

Oceans Healthcare CEO and NABH Board Treasurer Stuart Archer, M.B.A., FACHE on Wednesday testified in the Senate Health, Education, Labor & Pensions (HELP) Committee’s field hearing to discuss mental health and substance use treatment across the care continuum.
 
Archer joined four other expert witnesses, including Arthur Kleinschmidt, Ph.D., M.B.A., LPC, former principal deputy assistant secretary for mental health and substance use at the Substance Abuse and Mental Health Services Administration, at the hearing in Metairie, La.

CMS to Explore Strategies for Rural Health Financial Sustainability in Upcoming Webinar

CMS will host a 45-minute webinar later this month that provides strategies to strengthen and sustain rural health systems.

The webinar will examine how the rural emergency hospital model and technical assistance support access and financial sustainability, key shifts to value-based and alternative payment models, and what’s next for rural health.

Click here to register for the webinar, which starts at 1 p.m. ET on Wednesday, May 20.

Fact of the Week

The Health Resources and Services Administration reports the supply of adult psychiatrists is expected to decrease 20% by 2030, while demand for their services is expected to rise by 3%, leaving a shortage of more than 12,000 fully trained psychiatrists.

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

May is Mental Health Awareness Month!

Starting today, May 1, NABH is pleased to recognize and promote Mental Health Awareness Month, which the United States has observed since 1949.

We will honor the month by posting a mental health-related fact or figure each day on X and Bluesky and weekly on LinkedIn. Please engage with us by sharing our information and promoting mental health awareness!

Also, please visit our Mental Health Awareness Month landing page to access information from some of our partner organizations this month.

Reminder: Please Submit NABH’s Payor Experience Survey!

Thanks to our members who have submitted our recent patient experience survey. 

Last week NABH sent a message to members explaining that some NABH members have reported worsening experiences with treatment and claims approvals, and our Washington-based team wants to understand if this is a widespread problem.

If you haven’t yet, please complete this brief survey to report changes you’ve seen between early 2025 and early 2026.

To help us compare across facility types, please answer for only one facility type per survey. If you oversee multiple facility types, please submit a separate survey for each.

Please contact NABH Vice President of Quality and Regulatory Affairs Sarah Steverman if you have questions.

Kaiser Family Foundation Releases Analysis on Medicaid Eligibility and Renewal Policies

The Kaiser Family Foundation (KFF) on Thursday released two documents that examine upcoming Medicaid changes from H.R. 1, also referred to as the One Big Beautiful Bill Act (OBBBA) using data from an annual survey KFF and Georgetown University Center for Children and Families (CCF) conducted with state Medicaid and CHIP program officials between January and March 2026.

KFF published its annual report on Medicaid and CHIP Eligibility, Enrollment, and Renewal Policies as States Prepare for Major Medicaid Policy Changes. The 24^th annual survey provides a baseline of state Medicaid and CHIP policies in place as of January 2026 as the Centers for Medicare & Medicaid Services starts preparing to implement H.R. 1 changes.

KFF and Georgetown University CCF found that states continue to expand use of electronic and online strategies for enrollment, tools that have been shown to ease administrative burden and could help states and beneficiaries navigate reenrollment and community engagement requirements.

KFF used the annual survey data to develop An Early Look at Policy Decisions as States Get Ready to Implement Work Requirements, which reported that of the 43 states with community engagement requirements, most states are seeking to adopt less restrictive policies, although three states –  Iowa, Montana, and Nebraska – plan to implement work requirements before the Jan. 1, 2027 deadline.

Arkansas plans to implement changes in July but will not disenroll any beneficiaries not meeting the requirements until January 2027. Other states – Idaho, Indiana, and New Hampshire – reported plans to use more restrictive compliance verification policies than the statute requires. 
The report highlights data complexities states are encountering in their plans, including ways to verify medical frailty, which includes beneficiaries with disabling mental disorders and substance use disorders (SUD). States overwhelmingly reported needing guidance from CMS about exemptions and verification methods, which we expect CMS will publish in an interim final rule due June 1, 2026.

KFF, Georgetown University CCF, and National Association of Medicaid Directors experts provided an overview of their findings on a webinar on Thursday.

Mental Health Outcomes Issues Report on Key Behavioral Health Performance Metrics

The consultancy Mental Health Outcomes (MHO), which specializes in designing and implementing custom outcomes measurement in behavioral health programs, recently released a data report highlighting key behavioral health performance metrics. 

The report notes that many factors influence key performance metrics, with some operating at the patient level, such as symptom severity or engagement, and others operating at the facility level, such as staffing models and culture.

Using MHO’s data on inpatient discharges from 2025, the firm’s researchers examined common behavioral health metrics, including patient satisfaction, likelihood to recommend, clinical outcomes, and seclusion and restraint rates.

“There is substantial variation in patient scores while facility averages are largely similar,” the report noted. “Exploring patient-level data and focusing on who needs improving is more likely to yield actionable changes precisely where needed.”

Mental Health Outcomes Issues Report on Key Behavioral Health Performance Metrics

The Substance Abuse and Mental Health Services Administration (SAMHSA) GAINS Center will host a webinar next Thursday, May 7 to instruct behavioral health providers, judges, attorneys, court security officials, and others about practical, trauma-informed strategies for responding to mental and substance use disorders.

The Hon. Marcia Hirsch, former presiding judge of the Queens Treatment Courts, and Jennifers Johnson, founder and principal of J.K. Johnson Advisors, will lead the discussion.

The 90-minute webinar will begin at 3 p.m. ET on May 7. Click here to register.

ICYMI: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC. 

In the near term, here are some upcoming behavioral healthcare-related events: 

• The American Mental Health Counselors Association annual event for professionals will be held June 23–26, 2026 in Portland, Ore.
• The McDermot HealthEx will include sessions highlighting Medicaid, capital flows in behavioral health, SUD, and autism care. The expo will be held May 20-21 in Nashville, Tenn.
• The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29 in Washington, D.C.
• The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC.

Fact of the Week

18.1% of people experiencing homelessness in the United States have a serious mental illness, the National Alliance on Mental Illness reports.

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

We Want Your Feedback: Please Submit NABH’s Payor Experience Survey!

Some NABH members have reported worsening experiences with treatment and claims approvals, and our Washington-based team wants to understand if this is a widespread problem.

Please complete this brief survey to report changes you’ve seen between early 2025 and early 2026.

To help us compare across facility types, please answer for only one facility type per survey. If you oversee multiple facility types, please submit a separate survey for each.

Please contact NABH Vice President of Quality and Regulatory Affairs Sarah Steverman if you have questions.

NABH Participates in HHS Panel Examining Health IT

NABH’s Sarah Steverman joined an HHS panel discussion about health IT this week, reaffirming our commitment to evidence-based care and ensuring providers have a seat at the table in these discussions.

Steverman participated in the roundtable discussion with HHS Secretary Robert F. Kennedy Jr. and others to assess the current federal and state policy environment for behavioral healthcare and the role of information technology (IT) to advance progress.

Related to the discussion, HHS’ Office of the National Coordinator for Health Information Technology released a report this week about electronic health record adoption and exchange capabilities among substance use and mental health treatment facilities. The data came from the Substance Abuse and Mental Health Administration’s 2024 National Substance Use and Mental Health Services Survey.

“In recent years, rising prevalence of behavioral health disorders has led to increasing demand for substance use and mental health treatment services,” the report noted. “Electronic health record use is critical to improving clinical care, quality of care, and patient outcomes, as well as facilitating the exchange of health information.”

The report said in 2024, 75% of substance use and mental health treatment facilities did not participate in health information exchange organizations, while 25% of all substance use and mental health treatment facilities used paper patient records at least some of the time.

NABH Provides Comments to Sen. Wyden on BRIDGES Act Discussion Draft

NABH this week sent Senate Finance Committee Ranking Member Ron Wyden (D-Ore.) feedback on Wyden’s Better Results Through In-community Delivery, Greater Enforcement, and Stronger Services (BRIDGES) for Kids Act discussion draft.

NABH noted the United States lacks sufficient capacity to serve children with behavioral health conditions across all levels of care. “This lack of capacity is disproportionately concentrated within the higher levels of care, creating a mismatch where children with the most severe conditions are the least likely to get treatment,” the letter said. “NABH members are expanding access to the full behavioral healthcare continuum so children with serious emotional disturbances and substance use disorders receive timely, medically necessary treatment.”

We also noted that access to youth residential treatment is a prime example of this problem. Many children can be treated successfully in community-based outpatient programs; however, some children have more severe conditions that require higher-intensity services, including residential treatment. 

“Accessing residential treatment is increasingly difficult because the number of centers has sharply declined to only 461 in 2024 from 848 in 2012,” NABH wrote. “Despite NABH members’ best efforts, we need federal action to ensure children can access medically necessary residential treatment. We encourage the Committee to consider policies that support this.”

NABH thanks members of the Youth Services Committee who contributed detailed comments that we provided in our letter.

White House Releases Executive Order on Psychedelic Drugs

President Trump on April 18 signed an executive order to make psychedelic drugs more available to treat serious mental illness.

Trump’s order directs $50 million in federal funds to make them more accessible and ordered the U.S. Food and Drug Administration (FDA) to fast track a review of such drugs as psilocybin and ibogaine.

As part of the order, the U.S. Health and Human Services Department’s (HHS) Research Projects Agency for Health (ARPA-H) on Tuesday, April 21 announced the first set of research teams for its Evidence-Based Validation & Innovation for Rapid Therapeutics in Behavioral Health (EVIDENT) initiative, which will collectively fund up to $139.4 million to help advance new, effective therapies for behavioral health.

EVIDENT will allocate at least $50 million to match state government investments in psychedelic research for populations with serious mental illness.

DOJ Reschedules Medical Cannabis

The U.S. Justice Department (DOJ) on Thursday announced it has rescheduled medical cannabis products to Schedule III from Schedule I, including products that the FDA has approved (of which there are currently none) and products regulated under a state medical cannabis license.

Nonmedical cannabis products – including those that states have approved for recreational use – are still classified as Schedule I.

The Drug Enforcement Administration will hold a hearing on June 29 to consider broader rescheduling of medical cannabis.

These actions help carry out the 2025 executive order on increasing medical marijuana and cannabidiol research.

CMS to Host IPFQR Program Webinar Next Week on FY 2027 IPF PPS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) will host a webinar on the Inpatient Psychiatric Facility (IPF) Quality Reporting Program: FY 2027 IPF PPS Proposed Rule on Thursday, April 30 at 2 p.m. ET.

The webinar slides will be available for download from under “Upcoming Events” on CMS’ Quality Reporting site the day before the presentation.

Click here to register.

Two Groups to Host Virtual Session Next Week on Promoting SUD Care Transitions Across Healthcare Settings

The Center for Dissemination & Implementation at Stanford and the Prevention Science & Methodology Group will co-host a virtual session next week that explores promoting substance use disorder care transitions across healthcare settings.

The lecture will present findings from a multi-method research program intended to characterize and advance Opioid Use Disorder care transition implementation strategies.

Noa Krawczyk, Ph.D., assistant professor at New York University’s Grossman School of Medicine, will present the 90-minute session on Tuesday, April 28 starting at 1 p.m. ET. Clickhere to join the session on Zoom.

ICYMI: Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC. 

In the near term, here are some upcoming behavioral healthcare-related events:

• The American Mental Health Counselors Association annual event for professionals will be held June 23–26, 2026 in Portland, Ore.
• The McDermot HealthEx will include sessions highlighting Medicaid, capital flows in behavioral health, SUD, and autism care. The expo will be held May 20-21 in Nashville, Tenn.
• The Association of Clinicians for the Underserved annual conference will focus on expanding access to care from July 26-29 in Washington, D.C.
• The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC.

Fact of the Week

From July 2022 through December 2024, observed suicide mortality nationwide among individuals aged 15 years to 34 years old was lower than expected based on pre-988 Lifeline trends, JAMA reported on Wednesday. As quoted in Scientific American this week, the study’s lead author Vishal Patel, M.D., M.P.H. said “This is one of those rare moments in [this area of] public health where we can say that something might actually be working.” Patel studies healthcare policy at Brigham and Women’s Hospital and Harvard Medical School.

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

A Message from NABH President and CEO Scott Dziengelski

I’m grateful for the warm welcome our members and the NABH team have given me during my first week back at NABH. Thank you. It feels good to be back.
 
Before returning to NABH this week, I thought a lot about the origins of NABH. In 1933, nine physician leaders realized no group or professional association was advocating for the interests of their patients. Driven by their devotion to their patients, they formed a different association to serve as an advocate for their vision of psychiatric care. They formed the National Association of Private Psychiatric Hospitals.
 
More than nine decades later, we now call ourselves NABH—and that different vision for behavioral healthcare in 1933 still drives our advocacy. We are a strong, unified, consistent voice for our members who provide the highest quality behavioral healthcare. No other group or association is quite like us.
 
I’m confident that together we will achieve our different vision because the path ahead for NABH is clear, the team is energized, and we are ready to take on the toughest challenges in behavioral healthcare.

CMS to Release Key Regulations in Coming Weeks

As NABH prepares comments for the FY27 IPF PPS rule, we’re looking ahead to other important regulations that we expect from the Centers for Medicare and Medicaid Services (CMS) in the weeks and months ahead.

The Office of Management and Budget is currently reviewing the following regulations, signaling CMS will release these proposed rules soon: the Outpatient Prospective Payment System rule, which contains payment rates for partial hospitalization programs and intensive outpatient programs; the Physician Fee Schedule with the payment rate for Opioid Treatment Programs; the rule on Medicaid state-direct payments. Also at OMB is CMS’ H.R. 1/OBBBA’s Community Engagement interim final rule.

Please contact NABH Vice President of Quality and Regulatory Affairs Sarah Steverman or NABH Vice President of Public Policy Dan Schwartz if you have questions.

University Programs Addressing Behavioral Healthcare Workforce Gaps

A handful of university programs are addressing workforce gaps in behavioral healthcare by expanding certificate and degree programs.

The University of Pittsburgh, Campbell University in North Carolina, Northeast Ohio Medical University, and Mesa Community College are offering programs to offer solutions to the workforce shortage, an article in Becker’s Behavioral Health reported this week.

ICYMI: MACPAC Calls for CMS to Develop Transparent Plan for Community Engagement Requirements

The Medicaid and CHIP Payment Advisory Commission (MACPAC) on April 9 releasedImplementing Community Engagement Requirements in Medicaid, a draft chapter and recommendation that identifies policy and operational considerations for states and the Centers for Medicare & Medicaid Services (CMS) as they implement Community Engagement (CE) in requirements in Medicaid.

In the draft chapter, MACPAC recommends “The Secretary of the U.S. Department of Health and Human Services should direct the Centers for Medicare & Medicaid Services (CMS) to develop a transparent plan for monitoring and evaluating community engagement requirements in Medicaid that provides insight into how such policies affect eligibility and enrollment, health status, employment, state and federal administrative spending, and the attainment of other identified policy goals.”

The recommendation also said CMS should identify new metrics for state reporting (as needed) and build upon existing data collection activities to minimize administrative burden. MACPAC said CMS also should ensure timely publication of monitoring and evaluation results to inform policy and operational decision making.

MACPAC will vote on this recommendation next month.

Mark Your Calendars for These Upcoming Behavioral Healthcare Events

Please remember to save the date for the NABH 2027 Annual Meeting from March 1-3, 2027 at The Ritz-Carlton Washington, DC.

In the near term, here are some upcoming behavioral healthcare-related events: 

• The American Mental Health Counselors Association annual event for professionals will be held June 23–26, 2026 in Portland, Ore.
• The McDermot HealthEx will include sessions highlighting Medicaid, capital flows in behavioral health, substance use disorder, autism care, and more. The expo will be held May 20-21 in Nashville, Tenn.
• The Association of Clinicians for the Underserved will focus on expanding access to care at its annual conference from July 26-29 in Washington, D.C.
• The American Psychological Association will host its annual conference Aug. 6-8, 2026 in Washington, DC.

Fact of the Week

Suicides and drug overdoses likely contribute significantly to Arkansas’ maternity mortality rate, although stigma and lack of data make reporting difficult, UAMS Health psychiatrist Shona Ray, M.D. recently reported to Axios.

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

MACPAC Calls for CMS to Develop Transparent Plan for Community Engagement Requirements

The Medicaid and CHIP Payment Advisory Commission (MACPAC) on Thursday released Implementing Community Engagement Requirements in Medicaid, a draft chapter and recommendation that identifies policy and operational considerations for states and the Centers for Medicare & Medicaid Services (CMS) as they implement Community Engagement (CE) in requirements in Medicaid.

In the draft chapter, MACPAC recommends “The Secretary of the U.S. Department of Health and Human Services should direct the Centers for Medicare & Medicaid Services (CMS) to develop a transparent plan for monitoring and evaluating community engagement requirements in Medicaid that provides insight into how such policies affect eligibility and enrollment, health status, employment, state and federal administrative spending, and the attainment of other identified policy goals.”
 
The recommendation also said CMS should identify new metrics for state reporting (as needed) and build upon existing data collection activities to minimize administrative burden. MACPAC said CMS also should ensure timely publication of monitoring and evaluation results to inform policy and operational decision making.
 
MACPAC will vote on this recommendation next month.

ICYMI: CMS Releases Fiscal Year 2027 Medicare Inpatient Psychiatric Facility Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) on April 2 issued the Fiscal Year (FY) 2027 Medicare Inpatient Psychiatric Facilities (IPF) Prospective Payment System (PPS) proposed rule that includes updates to both the IPF PPS for FY 2027 and the IPF Quality Reporting (IPFQR) Program.
 
CMS proposes to increase the IPF PPS per diem base rate by 2.3% to $912.58, up from $892.87 in FY 2026. The proposed rule does not include changes to the methodology for determining the per diem base rate or patient-level adjustments and only minor technical changes to facility-level adjustments. CMS proposes one major change to payment methodology, establishing a 20% cap on outlier payments under the IPF PPS.

CMS also proposed two updates to the IPFQR Program related to quality reporting. The proposed rule outlines the IPF patient assessment instrument (IPF-PAI), which was statutorily mandated in 2023 for adoption in FY 2028. The NABH Quality Committee previously provided feedback to CMS about the components of the proposed IPF-PAI, and we are concerned about the feasibility and appropriateness of the proposal. In addition to the IPF-PAI, CMS proposes to remove two quality measures beginning with the CY 2026 reporting period, the Alcohol Use Brief Intervention (SUB-2 and SUB-2a) and the Tobacco Use Treatment (TOB-3 and TOB-3a) measures.

CMS published the proposed rule on Tuesday, April 7 in the Federal Register. NABH is developing comments and welcomes feedback from NABH members. NABH must submit comments by June 1.

Now Available: Joint Commission Webinar on Sentinel Event Transition

The Joint Commission (TJC) has released the “Alignment Overview” segment of its Sentinel Event Transition webinar series, which is available on demand.
 
The webinar series focuses on the changes related to sentinel events that will take effect on Jan. 1, 2027, and TJC is preparing to launch the remainder of the webinar series.
 
Click here to watch the first segment.

ICYMI: Recording Available for Webinar About Leveraging Regulatory Flexibility for Methadone Take-Home

The Center for Prevention Implementation Methodology for Drug Abuse and HIV recently hosted a webinar about leveraging regulatory flexibility for methadone take-home dosing to improve retention in opioid use disorder (OUD) treatment.
 
Recent federal regulatory changes have relaxed criteria for methadone take-home dosing, offering an opportunity to improve the OUD experience for patients.

Click here for more information and a recording of the late-March webinar.

Fact of the Week

Rep. Troy Carter, Sr. (D-La.) has introduced H.R.7787, the Mental Health Workforce Act, which addresses the mental health workforce shortage and urgent need for diversity among mental health providers in the United States. The bill would help raise the number of mental health providers, diversify the mental health workforce pipeline, and get care to communities who need these services the most.

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

CMS Releases Fiscal Year 2027 Medicare Inpatient Psychiatric Facility Prospective Payment System Proposed Rule

On Thursday, April 2, the Centers for Medicare & Medicaid Services (CMS) issued a proposal to update Medicare payment policies and rates for Inpatient Psychiatric Facilities (IPF) under the IPF Prospective Payment System (PPS) (CMS-1847-P) for fiscal year (FY) 2027. 

The IPF PPS proposed rule includes updates to IPF payment rates for FY 2027 and the IPF Quality Reporting (IPFQR) Program. For FY 2027, CMS proposes to increase the IPF PPS per diem base rate by 2.3% to $912.58, up from $892.87 in FY 2026. CMS estimates payments to IPFs would increase by $50 million in FY 2027 compared to payments in FY 2026.

The IPF PPS proposed rule also includes the long-awaited details on the IPF patient assessment instrument (IPF-PAI). Additionally, CMS proposes to remove two measures beginning with the CY 2026 reporting period, the Alcohol Use Brief Intervention (SUB-2 and SUB-2a) and the Tobacco Use Treatment (TOB-3 and TOB-3a) measures.

CMS has posted a summary of the rule on their website. The rule will officially be published on Tuesday, April 7 in the federal register, with comments due June 1. We will provide detailed analysis shortly on the PPS and IPFQR portions of the proposed rule.

NABH Responds to CMS’ RFI About Preventing & Identifying Fraud in Medicaid & CHIP

NABH this week responded to the Centers for Medicare & Medicaid Services’ (CMS) Request for Information about how to help states better prevent, identify, and address fraud, waste, and abuse in Medicaid and the Children’s Health Insurance Program (CHIP).
 
“NABH member organizations are subjected to extensive licensing and reporting requirements. In fact, inpatient psychiatric facilities (IPFs) must meet more stringent Medicare conditions of participation than general hospitals, and many states require IPFs and other behavioral healthcare settings to undergo more stringent licensing and certification than other healthcare provider types,” NABH’s comments noted. “We urge CMS to review existing state licensing and certification requirements before adding new ones to avoid duplication and undue burden on behavioral healthcare organizations already held to high Medicare and Medicaid standards.
 
Our comments also noted that a lack of health information technology (IT) investment may have affected CMS’ understanding of the risk for fraud in the behavioral health field.
 
“Federal investment in certified EHRs for behavioral health providers would improve transparency and reduce unintentional billing errors, allowing CMS, payors, and behavioral health organizations to better account for service provision, costs, and outcomes,” NABH said in our response.

U.S. Supreme Court Strikes Down Conversion Therapy Ban

In an 8-1 vote Tuesday, the U.S. Supreme Court ruled against Colorado’s law banning conversion therapy for minors.
 
In Chiles v. Salazar, the High Court’s majority said Colorado’s law likely violates the First Amendment because it restricts what therapists are allowed to say. 

Federal Lawmakers Introduce ‘Child Suicide Prevention Act’

U.S. Reps. Kim Schrier, M.D. (D-Wash.) and Lauren Underwood (D-Ill.) together with Sen. Brian Schatz (D-Hawaii) on Tuesday introduced the Child Suicide Prevention Act to address suicide among children and young adults by providing evidence-based training to current and future healthcare professionals.
 
Suicide is currently the second leading cause of death for young people ages 10-24, and the Centers for Disease Control and Prevention reported that suicide rates among young Americans increased 52% between 2000 and 2021.
 
The legislation also would create a centralized database of resources where at-risk youth and their families, medical and nursing schools, and healthcare professionals can access for best practices in suicide prevention.

ICYMI: NABH Statement on Illicit Drug Policies to House Energy & Commerce Health Subcommittee

NABH last week submitted a statement to the House Energy and Commerce Health Subcommittee for the panel’s hearing, Policies to Protect Our Communities from Illicit Drug Threats.
 
In our statement, NABH highlighted major concerns about H.R. 5629, the focus of the hearing, which we believe will have significant adverse effects for the more than 650,000 people receiving treatment from Opioid Treatment Programs (OTPs).
 
“H.R. 5629 would nullify nearly all of a final rule that the Substance Abuse and Mental Health Services Administration (SAMHSA) promulgated several years ago,” the statement said. “This rule corrected federal overregulation of delivering medical care for patients with opioid use disorder (OUD) and aligned federal standards with significant evolutions in OUD treatment since the first rule was promulgated in 2001,” it continued. “If signed into law, H.R. 5629 would bring back a federal government-imposed, one-size-fits-all approach to OTP care, restoring excessive and counterproductive regulation that unduly burdened patients and providers. And most importantly, it would be a massive step backward in our nation’s effort to combat America’s addiction and overdose crises.”
 
Read NABH’s full statement here.

Fact of the Week

Using medical or recreational marijuana to ease mental health conditions doesn’t work, according to a study published in the April 2026 edition of The LancetPsychiatry. “We found no evidence any form of cannabis is effective in treating anxiety, depression or post-traumatic stress disorder, which are three of the leading reasons for which cannabis is prescribed,” said Jack Wilson, the study’s lead author and a postdoctoral research fellow at the University of Sydney’s Matilda Centre for Research in Mental Health and Substance Use.

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

NABH Submits Statement on Illicit Drug Policies to House Energy & Commerce Health Subcommittee

NABH this week submitted a statement to the House Energy and Commerce Health Subcommittee for the panel’s hearing, Policies to Protect Our Communities from Illicit Drug Threats.
 
In our statement, NABH highlighted major concerns about H.R. 5629, the focus of the hearing, which we believe will have significant adverse effects for the more than 650,000 people receiving treatment from Opioid Treatment Programs (OTPs).
 
“H.R. 5629 would nullify nearly all of a final rule that the Substance Abuse and Mental Health Services Administration (SAMHSA) promulgated several years ago,” the statement said. “This rule corrected federal overregulation of delivering medical care for patients with opioid use disorder (OUD) and aligned federal standards with significant evolutions in OUD treatment since the first rule was promulgated in 2001,” it continued. “If signed into law, H.R. 5629 would bring back a federal government-imposed, one-size-fits-all approach to OTP care, restoring excessive and counterproductive regulation that unduly burdened patients and providers. And most importantly, it would be a massive step backward in our nation’s effort to combat America’s addiction and overdose crises.”
 
Read NABH’s full statement here.

Congratulations to NABH Board Chair – Elect Andrew Lynch on His Appointment to Federal Healthcare Advisory Committee

NABH is pleased to announce NABH Board Chair – Elect Andrew Lynch, Ph.D. from Acadia Healthcare has been appointed to the U.S. Health and Human Services Department’s (HHS) and the Centers for Medicare & Medicaid Services’ (CMS) Healthcare Advisory Committee.
 
The new Healthcare Advisory Committee is composed of leaders across the healthcare system and will advise HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Mehmet Oz, M.D. on ways to improve how federal programs finance and deliver care in the Medicare and Medicaid programs. Congratulations, Andrew!

Congratulations to NABH Board Member Frank Ghinassi on His Election as Chair of New Jersey Association of Mental Health and Addiction Agencies Board

NABH is pleased to announce NABH Board Member and Quality Committee Co-Chair Frank Ghinassi, Ph.D., A.B.P.P. from Rutgers University Behavioral Health Care and RWJBarnabas Health has been elected chair of the New Jersey Association of Mental Health and Addiction Agencies’ Board of Directors for 2027.
 
Frank’s term will run from July 1, 2026 through June 30, 2027. Congratulations, Frank!

ICYMI: Scott Dziengelski to Lead NABH as President and CEO Starting April 13

Scott Dziengelski will begin serving as president and CEO on Monday, April 13. He brings nearly 20 years of experience in healthcare policy, advocacy, and coalition-building, most recently as a consultant with King & Spalding, where he advised on federal healthcare policy.
 
Dziengelski has a strong track record of advancing strategic policy initiatives and collaborating with diverse stakeholders. He also serves as an adjunct fellow at the Manhattan Institute, focusing on mental health and substance use disorder policy.
 
He previously worked at NABH as director of policy and regulatory affairs from 2017 to 2020 and has experience in the U.S. House of Representatives and the House Energy and Commerce Committee.
 
NABH will release a public announcement about Dziengelski’s position on April 13. Please help us welcome him to his new role!

CMS Introduces Pediatric Care Model

CMS this week announced its Accelerating State Pediatric Innovation Readiness and Effectiveness (ASPIRE) Model to support whole-person care for Medicaid- and CHIP-enrolled children up to age 21 who have or at risk for complex medical and behavioral health needs.
 
ASPIRE is a voluntary, state-based model running for 10 years, with up to five states participating. CMS will release a Notice of Funding Opportunity (NOFO) in 2026.

Fact of the Week

People with schizophrenia spectrum disorder were 21.6 times more likely to have been incarcerated than people with no schizophrenia spectrum disorder, according to a recent study published in Schizophrenia Research. 

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

Scott Dziengelski to Start as NABH’s Next President and CEO on Monday, April 13

NABH is pleased to announce Scott Dziengelski will begin serving as the association’s new president and chief executive officer on Monday, April 13.

Dziengelski brings nearly 20 years of experience in healthcare policy, advocacy, and coalition-building to NABH. Currently he serves as a consultant with the FDA & Life Sciences team at King & Spalding, where he advocates before Congress and the federal agencies — including the U.S. Health and Human Services Department, the Centers for Medicare & Medicaid Services, and the U.S. Food and Drug Administration — for legislative and regulatory issues pertaining to hospitals, drug and device manufacturers, pharmacies, and other healthcare providers.

Throughout his career, Dziengelski has demonstrated a strong ability to create, communicate, and implement strategic policy initiatives while bringing together diverse stakeholders to advance shared goals. His deep understanding of federal policy and regulatory processes will be instrumental in advancing NABH’s mission to improve access to high-quality behavioral healthcare.

In addition to his consulting work, Dziengelski serves as an adjunct fellow at the Manhattan Institute, where he examines policies and regulations affecting individuals with serious mental illnesses and substance use disorders (SUD), with a focus on quality, access, and outcomes.

Dziengelski is no stranger to NABH. From May 2017 until January 2020, he served as NABH’s director of policy and regulatory affairs, where he helped shape the association’s policy agenda. Dziengelski also brings with him his previous experience as a legislative director in the U.S. House of Representatives and his work with the House Energy and Commerce Committee, which has jurisdiction over healthcare issues.

“Scott’s extensive policy expertise, leadership experience, and longstanding commitment to behavioral healthcare make him uniquely qualified to lead NABH at this critical time,” said NABH Interim President and CEO Mark Covall, who also serves on the association’s Board of Trustees. “We are thrilled to welcome him back to the association and look forward to his leadership in advancing our priorities.”

Dziengelski earned a bachelor’s degree in public policy from American University and a master’s degree in psychology from Pepperdine University. His contributions to public service and mental health policy have resulted in a Medal of Merit from the United States Capitol Police and the Friend of Children’s Mental Health Award from the American Academy of Child & Adolescent Psychiatry.

“I am honored to return to NABH and serve as its president and CEO,” Dziengelski said. “NABH plays a vital role in advocating for policies that expand access to high-quality behavioral healthcare. I look forward to working with our team, members, policymakers, and partners to address the nation’s most pressing mental health and substance use disorder challenges.”

Sen. Cassidy Introduces Bill to Eliminate Medicare’s 190-Day Lifetime Limit

Senate Health, Education, Labor, and Pensions (HELP) Committee Chair Bill Cassidy, M.D. (R-La.) this week introduced the Removing Medicare Mental Health Impatient Limitations Act to eliminate the Medicare program’s 190-day lifetime cap on psychiatric care services, a longstanding NABH priority.
 
If passed and signed into law, the bill would remove the existing cap in the Social Security Act and help ensure individuals have complete and uninterrupted access to the mental healthcare services they need.

NABH Sends Comments About Behavioral Health & Healthcare Costs to House Subcommittee

NABH this week submitted a statement for the congressional record as part of the House Energy and Commerce Subcommittee on Health’s hearing, Lowering Health Care Costs for All Americans: An Examination of the U.S. Provider Landscape.
 
After highlighting that mental health and SUD are common in the United States, NABH drew the connection between unmet treatment needs and rising healthcare costs.
 
“Individuals with untreated mental illness incur two to four times higher total medical costs than those without such conditions,” our comments noted. “While timely access to behavioral healthcare can improve outcomes and mitigate costs to the system, the total overall healthcare cost of not treating behavioral health disorders to the healthcare system exceed $290 billion annually in the United States alone.”
 
NABH also wrote that behavioral health conditions are associated with up to a threefold increase in spending among individuals with otherwise similar physical disease burden. “The impact is greatest among patients with high-cost physical health conditions,” our comments said. “More than half of patients with high-cost medical conditions also have a behavioral health condition, and these conditions are linked to increased medical spending for chronic pain, cardiovascular disease, and diabetes.”

Health Affairs Study Analyzes U.S. National Spending on Mental Health and Substance Use Disorder Treatment from 2000-2021

A new Health Affairs study concluded that from 2000 through 2021, mental health and SUD nominal spending grew to $139.6 billion from $40.9 billion and mental health and SUD accounted for 4.5% of all medical services spending in 2000 and 5.5% in 2021.
 
“Our decomposition analysis showed that mental health and SUD spending growth was driven primarily by increases in the number of people receiving treatment (representing 87.3% of the growth) and to a much lesser extent by increases in the cost per case (12.7% of the growth),” the study noted. “However, because disease severity was unobserved, these patterns may partly reflect increased treatment of less severe cases rather than unchanged severity-adjusted treatment costs.”

Johns Hopkins Study Finds Increase in Depression & Suicidal Ideation Among College Students

Results from a recent analysis of health survey data from more than 560,000 U.S. college students show that depression symptoms have steadily increased during the past 15 years, particularly among women, minorities, and students experiencing financial stress.
 
Researchers from Johns Hopkins Children’s Center, McDaniel College in Westminster, Md., the University of Maryland, and other Maryland academic institutions found that the rate of self-reported depression symptoms continued to grow during the 15 years of the analysis period (2007-2022), extending a trend that many other researchers have reported for the past two decades.
 
Meanwhile, Carol Vidal, M.D., Ph.D., M.P.H., child and adolescent psychiatrist at the Children’s Center, noted that thoughts of suicide, or “suicidal ideation,” increased across all demographic groups regardless of race, age, gender or financial stress, while reports of other symptoms, such as restlessness and lack of concentration rose most steeply among female, financially distressed and minority students.
 
Vidal noted that colleges, universities, parents and health care providers can all play a role in addressing differences in mental health indicators by being alert to those differences, addressing underlying stressors among the most vulnerable populations and seeking services when needed.

The Joint Commission to Host Webinar Series on Its Sentinel Event List Next Week

The Joint Commission (TJC) next week will host the first in a series of webinars about TJC’s Sentinel Event List, which the accrediting body announced in January will align with the National Quality Forum’s updated Serious Reportable Events (SRE) list that takes effect on Jan. 1, 2027.
 
The alignment is intended to streamline safety event reporting and eliminate the need for separate measurement frameworks. TJC’s first webinar will explore the effect of alignment and provide an overview of the SRE technical guidance that will support the 2027 changes.

Click here if you’re interested in registering for the hourlong webinar next Wednesday, March 25 that starts at 1 p.m. ET.

ICYMI: 2026 NABH Annual Meeting Presentations & Photos Available

Following our 2026 Annual Meeting this month, NABH posted presentations from General Session speakers Eric Boles of The Game Changers and Kimberly Brandt from the Centers for Medicare & Medicaid Services.
 
Author and blogger Neil Pasricha’s presentation is not available to post publicly, and NABH’s other General Session speakers did not use slides during their presentations.
 
NABH is also pleased to share photos from this year’s Annual Meeting. If you choose to share a photo publicly, please be sure to credit our photographer Chris Ferenzi.

Fact of the Week

In a nationally and state-representative Gallup survey of nearly 20,000 U.S. adults conducted from June through August 2025, roughly one-third of respondents — or about 82 million Americans — said they have made at least one trade-off with daily living expenses to afford healthcare.

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

Access and Share NABH’s 2026 Annual Meeting Presentations & Photos!

Following last week’s 2026 Annual Meeting, NABH posted presentations from General Session speakers Eric Boles of The Game Changers and Kimberly Brandt from the Centers for Medicare & Medicaid Services.
 
Author and blogger Neil Pasricha’s presentation is not available to post publicly, and NABH’s other General Session speakers did not use slides during their presentations.
 
NABH is also pleased to share photos from this year’s Annual Meeting. If you choose to share a photo publicly, please be sure to credit our photographer Chris Ferenzi.

NABH Coordinates Site Visit for Rep. Jeff Crank in Colorado

NABH recently coordinated Rep. Jeff Crank’s (R-Colo.) visit to NABH system member UHS’ Cedar Springs Hospital in Colorado Springs, Colorado to tour the hospital, learn about the system’s Patriot Support Program (PSP), and discuss ongoing challenges in the TRICARE West Region that could affect the hospital’s ability to provide services to military personnel and their families.
 
Crank, a member of the House Armed Services Committee, previously facilitated a committee briefing with Defense Health Agency (DHA) leadership to discuss provider challenges with TRICARE TriWest and push for agency engagement.  

Cedar Springs CEO Bob Kedelis led the tour and discussion around Cedar Springs services and the number of service members who receive treatment there. Crank, his wife Lisa Brown, and his staff spent an hour at the facility, and later discussed the challenges that UHS and other NABH members are managing with TRICARE TriWest, such as obtaining authorization for services, processing claims, receiving payment, and dealing with customer-service challenges. Rep. Crank pledged to continue working with committee colleagues and NABH to resolve these issues.

NABH staff welcomes the opportunity to work with NABH system members to facilitate site visits with their respective federal lawmakers and their staff to discuss priority issues and learn first-hand from practitioners about the challenges and successes that behavioral healthcare providers manage every day.

Please contact Andy Dodson at andrew@nabh.org to discuss your organization’s outreach efforts.

Congratulations to NABH Quality Committee Co-Chair Karen Johnson!

NABH is pleased and proud to share that Karen E. Johnson, senior vice president and chief clinical officer for the behavioral health division at Universal Health Services, Inc., has been recognized as one of the 10 Most Influential Women in Healthcare in the 2026 edition of Chief Women Leaders magazine.
 
Karen has spent more than 40 years dedicated to the behavioral health field in a career that has been defined by her passionate and tireless commitment to ensuring every individual who walks through a UHS facility receives compassionate, safe and high‑quality care.

Karen also has devoted decades of service to NABH, particularly in her involvement with the Quality Committee, where she serves presently as co-chair. In this role, Karen is helping NABH lead the behavioral healthcare sector in developing quality-outcome measures based on episodes of care.

Please help us congratulate Karen on both her recent achievement and on her many years of service and commitment to improving the health and well-being of others!

Register Today for Upcoming CMS Webinar on the IPFQR Program: Navigating the PIX Survey

CMS will host a webinar later this month to provide a general overview of the Psychiatric Inpatient Experience (PIX) Survey, data collection, and submission processes.
 
The webinar’s objectives include helping participants understand the background of the PIX survey and steps to collect PIX survey data; explain the PIX survey’s scoring methodology; describe how to submit PIX survey data successfully to CMS, and more.
 
CMS will host the webinar on Thursday, March 26 at 3 p.m. ET. Click here to register.

AHA Releases 2026 ‘Costs of Caring’ Report

Workforce pressures, higher input costs – particularly for drugs and supplies – and rising patient volume and acuity continue to drive broad-based, expense growth for hospitals, according to the American Hospital Association’s (AHA) recently released Costs of Caring report for 2026.  
 
In 2025, inpatient volumes increased by 5.3%, meaning hospitals cared for more patients who are increasingly sicker, the report said. Meanwhile, benchmark data showed outpatient visits rose (up 9.8% year over year), reflecting both higher demand and the continued shift to outpatient and ambulatory settings.
 
The study also found that, in the aggregate, more than half (56.1%) of hospital costs are tied to service lines where reimbursements fall short, or is less than, the cost to deliver care, such as behavioral health, obstetrics, infectious disease, and burns and wounds.
 
The study’s conclusion noted “this mismatch between expenses and revenue leaves hospitals increasingly at risk of being able to maintain the full spectrum of services on which communities rely.”

Fact of the Week

Pew recently posted Drug Checking Equipment Can Lead to Healthier Decisions, Saving Lives to highlight tools that offer more information about unpredictable drug supply. The posting is part of Pew’s Substance Use Treatment Prevention Initiative.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

2026 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2026 Annual Meeting that starts Monday, March 2 in Washington, D.C.
 
This year’s meeting theme is Future-Forward Leadership and is meant to help NABH members and guests learn from speakers, breakout sessions, committee meetings, and other events about how to imagine new possibilities in behavioral healthcare, innovate new methods and practices, and transform processes and care delivery in ways that help patients.

To prepare for the meeting, please view our online program, learn about this year’s speakers, and see our list of exhibitors and sponsors.  

Be Sure to Access the 2026 NABH Annual Meeting Online App

Again this year, attendees will have access to all Annual Meeting programming and resources through NABH’s web-based app. Please note: This is an online app, not a mobile app that you need to download.
 
On Monday morning, March 2, NABH will send all attendees an Annual Meeting Alert with a link to the app that includes information about General Sessions, speakers, committee meeting and breakout session locations, registrants, exhibitors and sponsors, and more. Attendees will also be able to access the link through a QR code outside The Ritz-Carlton Ballroom on the hotel’s lower level during the Annual Meeting.

Attend Our New Breakout Sessions on Tuesday, March 3!

NABH is eager to invite you to attend and participate in our new breakout sessions during our Annual Meeting on Tuesday, March 3.

Annual Meeting attendees will have their choice from among four breakout sessions, including two that will run concurrently from 11:15 a.m. – 12:30 p.m. ET (Innovative Approaches to Outpatient Treatment and Exploring Today’s Payor Issues) and two that will run concurrently from 3:30 p.m. – 4:45 p.m. ET (Preparing for Changes to State Medicaid Programs and NABH’s Quality Initiative).

NABH members determined the topics for these sessions through a member poll in CEO Update late last year.

Please be sure to tell us what you think of the new breakouts – and the rest of this year’s Annual Meeting – in a brief evaluation form you can access through your Annual Meeting online app.

Please Make Time for Our Exhibitors & Sponsors!

NABH appreciates the generous support of our exhibitors and sponsors, whose innovative products and services help NABH members deliver quality behavioral healthcare every day to those who need it.

Please make time to visit our exhibitors and sponsors during this year’s meeting.

As a reminder, Annual Meeting attendees will receive a printed version of the 2026 Annual Meeting Exhibitor and Sponsor Guide, which NABH will send to all members after the meeting and post in the “Resources” section of the NABH website.

Fact of the Week

2026 marks the first year NABH will host its Annual Meeting at The Ritz-Carlton Washington, DC in the district’s West End neighborhood. Our NABH team is eager to welcome everyone to our new venue!
 
Please note: NABH will not publish CEO Update next week and will resume on Friday, March 13.
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Former CBO Director Douglas Holtz-Eakin, Ph.D. to Address Attendees at 2026 Annual Meeting

NABH is pleased to welcome former Congressional Budget Office (CBO) Director Douglas Holtz-Eakin, Ph.D. as our afternoon speaker on Day #2 of the 2026 NABH Annual Meeting.
 
Holtz-Eakin has an esteemed record as a researcher and policy adviser, and he served as the sixth CBO director from 2003 to 2005. In 2009, he founded the American Action Forum, where he serves as president. He is also a distinguished fellow at Purdue University’s Daniels School of Business. Holtz-Eakin will draw from his diverse background in policy, politics, academia, and government in his session, Health Policy & The Economy: An Overview.

Please help us welcome him on Tuesday, March 3 from 2:15 – 3 p.m. ET in the ballroom at The Ritz-Carlton Washington, DC and come with your questions.
 
And there’s still time to register for this year’s Annual Meeting if you haven’t yet. We hope you join us!

Please Visit Our Exhibitors and Sponsors at the 2026 Annual Meeting

NABH appreciates the generous support of our exhibitors and sponsors, whose innovative products and services help NABH members deliver quality behavioral healthcare every day to those who need it.

Please make time to visit our exhibitors and sponsors at the Annual Meeting from March 2 -4 at the Ritz-Carlton Washington, DC. Before then, you can view a list of our exhibitors and sponsors on our Annual Meeting homepage, where you can also find program and speaker information.

CMS Releases Toolkit for Children’s Behavioral Health Services and EPSDT

The Centers for Medicare & Medicaid Services (CMS) on Friday released the State Medicaid & CHIP Toolkit for Children’s Behavioral Health Services and the Early and Periodic Screening, Diagnostic and Treatment (EPSDT) Requirements, a toolkit for state Medicaid and CHIP agencies to help ensure children and youth experiencing behavioral health conditions receive the care they need.
 
The toolkit includes strategies for developing a behavioral health care delivery system that can meet a range of children’s needs, promoting early intervention for children’s behavioral health conditions, improving children’s access to behavioral health care through service coordination and integration, and increasing the workforce capacity for children’s behavioral health services.
 
It also includes descriptive information about behavioral health services and models of care, as well as resources related to behavioral healthcare services delivery for children and youth.  

HHS Office for Civil Rights Begins Enforcing 42 CFR Part 2

HHS’ Office for Civil Rights (OCR) on Monday launched its enforcement program for 42 CFR Part 2 (“Part 2”), the regulations for confidentiality of substance use disorder patient records.
 
This coincides with the date in which Part 2 programs must comply with the latest rule from 2024, which largely aligned Part 2 requirements with the privacy regulations associated with the Health Insurance Portability and Accountability Act of 1996.
 
Any complaints alleging Part 2 violations and notifications of Part 2 breaches now will be directed to OCR instead of the U.S. Department of Justice.

KFF Analysis Shows U.S. Health Spending Accounted for 18% of GDP in 2024

A recent analysis from the Kaiser Family Foundation (KFF) found national spending on health rose to $5.3 trillion and 18% of GDP in 2024 and is projected to continue to rise into the future. 
 
In 2025, average annual premiums for employer-sponsored family coverage reached $26,993, with workers paying $6,850 for their coverage, according to KFF’s annual survey of employers.  
 
Meanwhile, hospital care accounted for nearly one-third of national health expenditures in 2024, and more than doubled in nominal terms over the preceding two decades, making hospitals a major driver of health spending growth over time, the analysis said.

ICYMI: Coalition to Strengthen America’s Healthcare Intensifies Messaging About Insurer Practices in New Ad

The Coalition to Strengthen America’s Healthcare has released a new digital advertisement highlighting harmful insurer practices that delay patients’ access to care, create more administrative burden for providers, and increase costs for all Americans.
 
NABH serves on the board of the Coalition, which will run the ad in the coming weeks across digital streaming platforms HBO Max, Amazon Prime, YouTube TV, and Spotify video and will target key policymakers and healthcare influencers inside the Beltway.

Fact of the Week

A recent study published in JAMA Network found that low proportion of telehealth use maintains primary care quality comparable to that of in-person care; however, a high proportion of telehealth use was associated with lower quality, especially for services needing in-person care (e.g., vaccines).

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

Please View our 2026 Annual Meeting Program!

The 2026 Annual Meeting – Future-Forward Leadership: Imagine. Innovate. Transform. – is in a little more than two weeks, and we are eager to share this year’s Annual Meeting program!
 
Please join us on Day #1, Monday, March 2 to learn about effective leadership practices from former NFL wide receiver Eric Boles, founder and CEO of The Game Changers, and on Day #2 to hear from two-time Pulitzer-Prize finalist and CNN political analyst Ron Brownstein and award-winning author and blogger Neil Pasricha. Learn more about our speakers here.
 
You also won’t want to miss our new breakout sessions on Tuesday, March 3 and our policy breakfast featuring behavioral healthcare champion Rep. Paul Tonko (D-N.Y.) on Wednesday, March 4.
 
Please visit our Annual Meeting homepage and register for the meeting if you haven’t yet. We look forward to seeing you in Washington!

Join Us for New Breakout Sessions on Day #2 of the Annual Meeting

2026 NABH Annual Meeting attendees will have their choice from among four breakout sessions on Tuesday, March 3, including two that will run concurrently from 11:15 a.m. – 12:30 p.m. ET and two that will run concurrently from 3:30 p.m. – 4:45 p.m.

NABH members determined the topics for these sessions through a member poll in CEO Update late last year. The session topics include: 1) innovative approaches to outpatient care, 2) payor issues, 3) policy (focused on Medicaid), and 4) quality (focused on NABH’s new quality initiative).

There’s no need to register separately for these breakout sessions. Please join us!

CMS Finalizes Medicaid Provider Tax Rule

CMS finalized a rule on Jan. 29 to implement the Working Families Tax Cut (WFTC, also known as H.R. 1) legislation’s provider taxes provision.
 
Every state except Alaska use provider taxes – taxes and assessments on hospitals, Medicaid managed care plans, and other providers – to finance a portion of their share of their Medicaid program. CMS’ new rule provides greater detail on the provision prohibiting certain provider taxes that states use to support their Medicaid programs.

The rule prohibits higher tax rates on Medicaid than on non-Medicaid businesses, changing the way some states have applied the taxes. The rule also bars using vague language or complex designs to disguise taxes that target Medicaid.

CMS provides states with a transition period of at least until the end of calendar year 2026 to comply with the new provider tax rules but will vary the length of such transition periods by the type of provider subject to the taxes and by how recently such uniformity waivers were approved or renewed. 

For prohibited taxes on providers including hospitals, CMS said the transition period will be through the end of each state’s fiscal year 2028 with the state needing to comply by the start of the 2029 state fiscal year. 

SAMHSA’s GAINS Center to Host Webinar on Improving Efficiency and Coordination of Hospital-Based Competence Restoration

The Substance Abuse and Mental Health Administration’s (SAMHSA) GAINS Center will host The Virginia Model: Improving Efficiency and Coordination of Hospital-Based Competence Restoration to highlight how Virginia has implemented practical, hospital-based strategies to better manage patient flow, reduce wait times, and optimize competence restoration services.

The 90-minute webinar is scheduled for Tuesday, Feb. 25 starting at 3 p.m. ET. Click here to learn more and register.

Coalition to Strengthen America’s Healthcare Intensifies Messaging About Insurer Practices in New Ad

The Coalition to Strengthen America’s Healthcare has released a new digital advertisement highlighting harmful insurer practices that delay patients’ access to care, create more administrative burden for providers, and increase costs for all Americans.
 
NABH serves on the board of the Coalition, which will run the ad in the coming weeks across digital streaming platforms HBO Max, Amazon Prime, YouTube TV, and Spotify video and will target key policymakers and healthcare influencers inside the Beltway.

Fact of the Week

The American Psychiatric Association recently outlined its approach for revising the fifth edition of the Diagnostic and Statistical Manual of Mental Disorders APA in a series of articles in The American Journal of Psychiatry.

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

CNN Analyst Ron Brownstein to Headline 2026 Annual Meeting Luncheon

NABH is pleased to welcome CNN analyst and two-time Pulitzer Prize finalist Ron Brownstein as our 2026 Annual Meeting Luncheon speaker during this election year.

As a senior political analyst for CNN and opinion columnist, Brownstein produces sharp analysis on politics, policy, the electorate, media, healthcare, and the range of issues informed by his strong sense of American political and national history.

Brownstein also served as the national political correspondent and a columnist for the Los Angeles Times. In his years at the Times, he earned two finalist nods from the Pulitzer Prize Board for his coverage of the 1996 and 2004 presidential elections. He has appeared frequently on Meet the Press, This Week with George Stephanopolous, Face the Nation, The Newshour, and Washington Week in Review. He has also served as an election analyst for ABC.

Brownstein is the author or editor of seven books. His previous book, Reagan’s Ruling Class: Portraits of the President’s Top 100 Officials, was a Washington Post bestseller for five weeks. His articles on politics, public policy, books and culture have also appeared in a number of newspapers and magazines, including The New York Times Magazine, Esquire, Vanity Fair, The Washington Monthly, The Wall Street Journal, The Boston Globe, and The Chicago Sun-Times.

Please be sure to register for this year’s Annual Meeting and help us welcome Brownstein on Tuesday, March 3 at 12:45 p.m. ET at The Ritz-Carlton Washington, DC.

President Trump Signs Appropriations, Health Extenders, Telehealth Extention Package

President Trump on Tuesday, Feb. 3 signed legislation to end the three-day government shutdown. Earlier in the day, the House passed the appropriations minibus that funds five agencies – including  Labor and HHS – through Sept. 30. The bill also includes key Medicare extenders.
 
The package that congressional leaders negotiated last month extends Medicare telehealth flexibilities through 2027, continues mandatory funding for community health centers, reauthorizes a slate of expiring Medicare and public health programs, and delays disproportionate share hospital payments cuts through FY2028. The package also takes a step toward site-neutral pay by requiring off-campus hospital outpatient departments to maintain a separate national provider identity.

This minibus bill’s passage will allow CMS and other key HHS offices to resume operations following the brief lapse in funding. Twenty-one Democrats joined Republicans in passing the minibus, with 21 Republicans bucking against leadership and voting against the package.

Federal Court Issues Amended Remedies in Wit v. UBH

The U.S. District Court for the Northern District of California this week issued an amended remedies order in Wit v. United Behavioral Health (UBH), a landmark case for which in the Court in 2019 found that UBH violated its responsibilities to beneficiaries of applicable plans by imposing medical necessity criteria that misaligned with generally accepted standards of care (GASC) to protect its own interests.
 
The latest order: 1) permanently enjoins UBH from implementing these medical necessity criteria (other than portions that accurately reflect GASC), and 2) for five years directs UBH to align medical necessity criteria with GASC, as established by the court’s findings and in accordance with state law.

President Trump Announces Actions to Begin Implementing SUD Executive Order

Following President Trump’s Executive Order last week that launched the Great American Recovery Initiative – a government-wide effort to coordinate and implement actions to prevent, treat, and support recovery from substance use disorder (SUD) – HHS expanded several new opportunities.
 
The new Safety Through Recovery, Engagement, and Evidence-based Treatment and Supports (STREETS) Initiative through the Substance Abuse and Mental Health Services Administration (SAMHSA) will provide $100 million for “targeted outreach, psychiatric care, medical stabilization and crisis intervention, while connecting Americans experiencing homelessness and addiction to stable housing with a clear focus on long-term recovery and independence.”

Another SAMHSA grant program, Assisted Outpatient Treatment, will receive $10 million to support civil court-ordered outpatient treatment for adults with serious mental illness.

Meanwhile, the Administration for Children and Families announced that medications for opioid use disorder (i.e., methadone, buprenorphine, naltrexone) are now included in the Title IV-E Prevention Program, an optional program that allows states and tribes to receive a 50% federal match for select services that help prevent youth from entering foster care. As a result, states and tribes will have another funding mechanism to support families with children at imminent risk for foster care placement solely due to a parent’s untreated opioid use disorder.

CMS Issues Letter on State-Directed Payments

CMS this week sent a “Dear Colleague” letter related to the Working Families Tax Cuts legislation’s state-directed payments (SDPs) provision.
 
The law (also referred to as H.R. 1 or the OBBBA) requires CMS to lower the payment rate limits for certain SDPs in Medicaid managed care beginning July 4, 2025, while temporarily grandfathering some existing arrangements until 2028. This letter primarily reiterates the statute, noting that certain SDPs from 2024–2026 may qualify for temporary grandfathering if submitted on time or supported by a good‑faith effort to obtain approval.
 
In the letter, CMS said it is exploring the option of expanding the SDP restrictions to other services besides the four in statute (inpatient hospital services, outpatient hospital services, nursing facility services, qualified practitioner services at academic health centers) but did not name other potential services.

CMS said it is developing a notice of proposed rulemaking to implement provision of the law. NABH will continue monitoring this issue and will weigh in with CMS before and during rulemaking.

HHS Selects Nationwide Pilot Programs to Improve Behavioral Health Data Exchange

The Assistant Secretary for Technology Policy (ASTP) and SAMHSA announced it has selected nine nationwide pilot programs to test health information technology (IT) standards to strengthen behavioral and physical health integration through improved data exchange.

Together SAMHSA and ASTP are supporting the pilots through the Behavioral Health Information Technology (BHIT) Initiative, a $20+ million program.  

The pilot program includes 45 exchange partners across nine states (Colorado, Connecticut, Delaware, Florida, Massachusetts, North Carolina, Oregon, Rhode Island, and Washington, D.C.) and will test specific behavioral health data elements in real-world behavioral health settings.

The pilots will be completed by the end of 2026, and their findings will inform future standards, technical specifications, and policy considerations for the broader health provider community and shape future resources for the behavioral health community.

Fact of the Week

Facing an estimated 50% of Olympians and 60% of Paralympians reporting mental‑health concerns, the U.S. Olympic & Paralympic Committee has dramatically expanded its support program ahead of the 2026 Milano‑Cortina Games, USA Todayreported this week.

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

2026 NABH Exhibitor and Sponsor Guide Ad Deadline is Today, Jan. 30!

This is a reminder that all advertisements to be included in NABH’s 2026 NABH Exhibitor and Sponsor Guide are due today, Friday, Jan. 30.
 
The Exhibitor and Sponsor Guide provides an opportunity to showcase your organization’s products and services, elevate your brand visibility, and reach key decision makers. Distributed to all registrants at the 2026 NABH Annual Meeting, the Exhibitor and Sponsor Guide highlights logos, organization descriptions, and additional advertisements.
 
The association will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage and Resources page.
 
Be sure your organization is included today!

Congress Struggles to Reach Government Funding Deal Before Likely Shutdown

On Thursday, Jan. 29, seven Senate Republicans joined all Democrats in blocking a procedural motion forcing the majority and the White House to work on a compromise funding agreement to avoid a government shutdown. Following House passage of a $1.3 trillion spending bill to fund most of the federal government last week, Senate Democrats followed through on their vow to block the package over Department of Homeland Security (DHS) funding. The compromise stripped funding for DHS from the six-bill package and replaced it with a two-week stopgap measure to allow for negotiations over immigration and custom enforcement restrictions. 
 
The Senate convenes today, Jan. 30, to attempt to clear the funding package, which includes $2.79 billion for behavioral health programs under the Substance Abuse and Mental Health Services Administration (SAMHSA), and health extenders, including delaying disproportionate share hospital (DSH) cuts through 2027 and extending Medicare telehealth flexibilities through Dec. 2027. The package does not include any extension of the expired enhanced ACA premium tax credits.
 
Senators have until tonight, Friday, Jan. 30, to secure a deal before the government enters a partial shutdown, but the amended package must go back to the House of Representatives, which is in recess until Monday, making a shutdown almost certain. A partial shutdown will occur because six of the 12 annual spending bills for other major federal departments have already been signed into law. If the shutdown is brief, few, if any, government services will be interrupted.

White House Releases Executive Order Launching a Substance Use Initiative

The White House, on Thursday, Jan. 29, released a new executive order, Addressing Addiction Through the Great American Recovery Initiative. Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr. and Kathryn Burgum, Interior Secretary Doug Burgum’s wife and former first lady of North Dakota, will chair the effort. The administration has appointed Ms. Burgum, who is in recovery from alcohol use disorder and as first lady advocated for substance use treatment access and stigma reduction, as senior adviser for addiction recovery.
 
An executive director will manage the initiative and report to the assistant to the president for domestic policy. This initiative will include officials or their designees from several federal agencies, including the departments of justice, interior, labor, education, veterans affairs, and the Office of National Drug Control Policy. The executive order also names the assistant secretary for mental health and substance use, the head of SAMHSA, as part of the initiative, but the White House has not nominated anyone to fill this role.
 
According to the executive order, the initiative will “coordinate the federal government’s response to the addiction crisis, including by better aligning relevant federal programs, setting clear objectives, and providing data-driven updates to the public on progress towards meeting these objectives.” The initiative will also increase awareness of substance use disorder, advise department and agency leadership on substance use programs and grants, and consult with states, tribes, localities, and other entities to support access to treatment and “celebrate individuals going through the recovery process.”

Medicaid and CHIP Payment and Access Commission Held January Public Meeting

On Thursday, Jan. 29 and Friday, Jan. 30, the Medicaid and CHIP Payment and Access Commission (MACPAC) held its first public meeting of 2026.
 
Among topics relevant to NABH members, MACPAC commissioners discussed findings from Chapter 2 of their June 2025 Report to Congress, which focuses on appropriate access to residential behavioral health treatment for children and youth. To address concerns raised in that report, MACPAC recommended three policy options:

1. Congress will require HHS to develop and maintain a directory of youth residential treatment facilities.
2. The Centers for Medicare & Medicaid Services (CMS) will report on the use of residential treatment services.
3. CMS will revise federal regulations to establish minimum requirements for discharge planning processes.

During the public meeting, MACPAC also discussed considerations and policy options for implementing Medicaid community engagement requirements, children and youth with special health care needs transitions to adult coverage, behavioral health in Medicaid and the state Children’s Health Insurance Program, and Medicaid for justice-involved youth transitions to the community. NABH will monitor these policy recommendations, engage with MACPAC and CMS, and provide updates to NABH members.

Outpatient Drug Acquisition Cost Survey Resources

HHS is requiring hospitals to complete the Outpatient Drug Acquisition Cost Survey (ODACS). ODACS collects the acquisition costs of certain outpatient drugs and biological products that hospitals paid under the Medicare Hospital Outpatient Prospective Payment System (OPPS) purchase. CMS will consider these data when determining the appropriate payment rates for hospitals paid under the OPPS.
 
All hospitals paid under the OPPS between July 1, 2024, and June 30, 2025, must submit data by March 31, 2026. For more information on the ODACS, please see the OPPS ODACS webpage, FAQs, or contact OPPSDrugSurvey@cms.hhs.gov with questions.

Fact of the Week

A recent JAMA survey found that daily generative AI use is linked to a 30% increased likelihood of moderate depressive symptoms by users. Out of 20,847 US adults polled, 10.3% reported using generative AI daily.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Learn from Former Walmart Leadership Director and Author Neil Pasricha at the 2026 Annual Meeting!

NABH is pleased to welcome author and former Walmart leader Neil Pasricha to kick off Day 2 of the NABH 2026 Annual Meeting on Tuesday, March 3 at 10 a.m.

Pasricha’s research and books on happiness, mindset, and human potential have been featured in the Harvard Business Review, The New Yorker, The Sunday Times, CNN, and the BBC.

After graduating from Harvard Business School, Pasricha spent a decade as director of leadership at Walmart. It was during this period that he wrote his 50-million-hit, award-winning blog 1000 Awesome Things and the New York Times bestsellers The Book of Awesome and The Happiness Equation, which have been on international bestseller lists for more than 200 weeks and sold more than 1 million copies. Onstage, he’s known for his high energy and his applicable messages to leaders everywhere.

Please help us welcome Neil and other Annual Meeting speakers in March. We look forward to seeing you in Washington!

2026 Annual Meeting Hotel Reservation Cutoff Date is Approaching!

The hotel reservation cutoff date for the NABH 2026 Annual Meeting – Future-Forward Leadership: Imagine. Innovate. Transform. – is Monday, Feb. 9.

If you haven’t done so, please reserve your hotel room today to secure NABH’s group rate. Also please remember to register for this year’s meeting!

House Passes $1.2 Trillion Spending Bill Before Government Shutdown Deadline on Jan. 30

The House on Thursday passed a $1.2 trillion spending bill to fund the majority of the federal government as the Jan. 30 government shutdown deadline looms.
 
The four-bill minibus includes nearly $117 billion for HHS and $13.7 billion for the U.S. Labor Department and a long-delayed health extenders package.
 
The Labor/HHS bill supports HHS Secretary Robert F. Kennedy Jr.’s “Make America Healthy Again” agenda but does not include funding for the new agency he proposed to create, the Administration for a Healthy America (AHA). Kennedy’s planned AHA is a $19 billion proposal that would include functions of five existing agencies focusing on primary care, maternal and child health, mental health, environmental health, HIV/AIDS, and workforce development.
 
The health extenders package includes:

• A two-year extension of Medicare telehealth flexibilities through December 2027.
• An extension of Medicare add-on payments for low-volume hospitals through fiscal 2028 and the Medicare Dependent Hospital program through Dec. 31, 2026.
• An extension of incentive payments for participation in eligible alternative payment models (APMs) to cover 2028, with the incentive set at 3.1%.
• Multi-year extensions of funding for community health centers, the National Health Service Corps, and teaching health center graduate medical education programs.
• An extension of the Medicare Geographic Practice Cost Index floor through Jan. 1, 2027.
• Medicare Advantage provider directory accuracy requirements, addressing so-called “ghost networks” that have come under scrutiny in recent years.
• Language from the Accelerating Kids Access to Care Act to streamline out-of-state Medicaid provider requirements.
• A reduction in the Medicare Improvement Fund and an extension of Medicare sequestration instructions into fiscal year 2033, both used as budgetary offsets.
• Requirements for a separate identification number and attestation for each off-campus outpatient department.

More comprehensive site-neutral payment policies were omitted, as were two heavily supported bills from Sen. Roger Marshall (R-Kansas) that would have imposed tougher statutory Medicare Advantage prior authorization requirements and strengthened hospital price transparency rules.
 
As NABH expected, the package doesn’t include an extension of the expired enhanced Affordable Care Act premium tax credits. The legislation now moves to the Senate, where it is expected to pass.

SAMHSA Announces Funding Opportunity for 988 Lifeline

The Substance Abuse and Mental Health Services Administration (SAMHSA) recently announced a $231 million funding opportunity to administer the 988 Suicide & Crisis Lifeline.
 
According to the announcement, public and private not-for-profit entities are eligible to apply, and the purpose of the program is to serve as the 988 Lifeline Administrator and manage, enhance, and strengthen the 988 lifeline.
 
Click here for more information. Applications are due by Friday, Feb. 27, 2026.

Fact of the Week

In a randomized clinical trial of 590 adults who had received evidence-based smoking cessation treatment and had abstained for three to 30 days, mobile chat messaging significantly increased six-month, biochemically validated tobacco abstinence compared with text messaging 45.9% versus 35.5%), according to a recent study published in JAMA Internal Medicine.

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

Explore NABH’s Opportunities to Highlight Your Organization in 2026

NABH is eager to feature your organization in conjunction with our 2026 Annual Meeting– Future-Forward Leadership: Imagine. Innovate. Transform.
 
Please take a moment to review the options in our 2026 Exhibitor and Sponsor Opportunities and share this resource with anyone interested in building professional relationships, elevating brand visibility, and generating business development in behavioral healthcare.
 
And please consider advertising in this year’s Exhibitor and Sponsor Guide, regardless of whether you choose to serve as an exhibitor or sponsor at the 2026 Annual Meeting. Please click here for details. All advertisements are due by Friday, Jan. 30, 2026.  
 
We look forward to seeing you at The Ritz-Carlton Washington, DC in March. Please register for the meeting and reserve your hotel room today!

ICYMI: SAMHSA Reverses Course on Grant Funding Terminations

Congressional leaders announced Wednesday, Jan. 14 that the Substance Abuse and Mental Health Services Administration (SAMHSA) will reinstate grant awards the agency had terminated on Tuesday.

SAMHSA had sent termination notices for about 2,800 awards, totaling approximately $2 billion in mental health and substance use funding. Congress showed bipartisan support to reinstate the funding, pressuring HHS Secretary Robert Kennedy to reverse the terminations.
 
In other federal healthcare news this week, President Trump released his healthcare framework, a one-page document that maps out his priorities related to insurance premiums, insurer accountability, and price transparency.

CBO Evaluates Effectiveness of Opioid Crisis Policy Approaches

The Congressional Budget Office (CBO) this week released a report that assesses policy approaches to address the opioid crisis, including policies related to reducing opioid supply, demand, and harms.
 
CBO found that opioid use disorder treatment-related efforts such as expanding Medicaid coverage, increased telehealth, supporting treatment engagement for people involved in the criminal justice system, and enhancing state prescription drug monitoring programs had consistent evidence for several positive outcomes (e.g., treatment engagement, lower drug misuse). Broadening access to opioid overdose reversal medications (e.g., naloxone) also helped reduce deaths, the report said.
 
Meanwhile, efforts to disrupt the supply of illicit opioids had somewhat consistent evidence for reducing hospital admissions, crime rates, and mortality, but some evidence indicated that the effects were temporary.

CMS Releases RFI on Feedback to Modernize Claims Processing System

The Centers for Medicare & Medicaid Services (CMS) has released a request for information (RFI) seeking ways to replace its Medicare claims processing system with a real-time, cloud-based platform.
 
According to the RFI, the new “ClaimsCore” program will redesign Medicare fee-for-service processing by replacing legacy shared systems, including the Multi-Carrier System, Fiscal Intermediary Shared System, and Durable Medical Equipment Claims System, as well as the Common Working File, with a flexible and interoperable platform that puts Medicare beneficiaries at the center of every decision.
 
The changes are meant to improve the beneficiary experience, reduce provider burden, and increase administrative efficiency in the Medicare program.

American Medical Association Releases 2025 Report on Substance Use

In a report released this week, the American Medical Association (AMA) said while opioid-related deaths have dropped to 75,000 from more than 110,000 in 2023, most are still driven by illicitly made fentanyl—and nearly 60% involve more than one dangerous substance.
 
The report, Substance Use and Treatment: Progress, Policy, and Future Directions, also noted that the 2024 decline in overdose deaths is coupled with a complex substance use and overdose epidemic, complicated by increasing prevalence of polysubstance use and an unpredictable illicit drug supply.
 
AMA recommends expanding naloxone distribution and access and removing barriers to substance use treatment access. The organization endorses additional research on emerging threats and identifies their policy priorities, including enforcing parity laws, removing barriers to treatment for pain and substance use disorder, and strengthening overdose prevention efforts.
 
The Chicago-based medical association also commented on the effects of cannabis use nationwide.

“We’re also seeing harms rise even as more states legalize cannabis,” the reported noted. “Emergency visits for cannabinoid hyperemesis syndrome have climbed more than 400% since 2016, and more than 19 million people met criteria for cannabis use disorder in 2023,” it added. “The evidence needs to guide us moving forward. Legal doesn’t mean harmless or useful, and we can’t ignore these trends.”

Fact of the Week

About 38% of Americans plan to make a mental health-related resolution for 2026, according to a new poll from the American Psychiatric Association. The percentage is considerably higher than the 5% of Americans who made the same resolution last year, the survey noted.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Welcomes Jim Shaheen to Second Term as NABH Board Chair

NABH is pleased to welcome NABH Board Chair Jim Shaheen, CEO of New Season, to his second year leading the association’s board of trustees.
 
NABH members voted last month on the association’s 2026 slate of board candidates, and Jim graciously agreed to serve as board chair for another year as NABH continues to move through a staff leadership transition.
 
A longtime NABH member, Jim has served NABH in many capacities, including presently as vice president of the NABH Education and Research Foundation and member of the Substance Use Disorder Treatment Committee. Previously he served as NABH’s board treasurer.
 
Jim leads New Season, a nationwide medication-assisted treatment company that serves more than 33,500 patients in 94 clinics located in 20 states. 
 
NABH board member Andrew Lynch, Ph.D., chief strategy officer at Acadia Healthcare in Franklin, Tenn., is now the association’s board chair-elect and will succeed Jim in 2027.
 
NABH is also pleased to welcome members Gina Sharp, M.B.A., FACHE, president of Endeavor Health Linden Oaks Hospital in Naperville, Ill., and Tanmay Mathur, M.S., M.B.A., vice president of Vanderbilt Behavioral Health in Nashville, who began their NABH board terms on Jan. 1.

Performance Management Coach & Former NFL Player Eric Boles to Open 2026 Annual Meeting

NABH is eager to welcome former NFL wide receiver Eric Boles, CEO and Founder of The Game Changers, Inc., as our keynote speaker at the NABH 2026 Annual Meeting on Monday, March 2.

Boles’s company The Game Changers, Inc. offers a non-traditional approach to performance management through talent development, business strategy, change management, cultural transformation, and peak performance. Under his leadership, Boles helps transform an organization’s most valuable resource – its people – through high-energy and powerful storytelling aimed at unleashing individual potential, navigating change, and leading with purpose.

The company’s recent clients include IBM, FedEx, Motorola, Astra Zeneca, Mayo Clinic, Northwestern Mutual, Medtronic, Motion Industries, Bridgestone Tires, Southeastern Grocers, and Boys & Girls Clubs of America.

Before becoming a sought-after speaker and consultant, Boles learned many of his principles of peak performance, team dynamics, and leadership from his experience as a wide receiver with the NFL’s Green Bay Packers and New York Jets. He is the author of Moving to Great: Unleashing Your Best in Life and Work.

NABH will share information about our other Annual Meeting speakers and program information in future Annual Meeting Alerts each week leading up to the Annual Meeting. Please remember to visit our Annual Meeting homepage to view our Schedule At-A-Glance, register for the meeting, and book your hotel room today!

Advertise in the 2026 NABH Exhibitor and Sponsor Guide!

Showcase your organization’s products and services in the 2026 NABH Exhibitor and Sponsor Guide! Distributed to all registrants at the 2026 NABH Annual Meeting, the Exhibitor and Sponsor Guide features logos, organization descriptions, and additional advertisements. Be sure your organization is included today!
 
All advertisements are due by Friday, Jan. 30, 2026. Please click here for details about advertising opportunities.
 
The association also will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage.

House Passes Bill to Revive ACA’s Enhanced Subsidies for Three Years

Seventeen Republicans joined Democrats in passing legislation Thursday that would revive the Affordable Care Act’s (ACA) enhanced subsidies for three years, rebuffing opposition from GOP leadership.
 
The 230-196 vote followed a procedural vote Wednesday to advance the bill, as nine Republicans joined Democrats in forcing a vote on the House Floor. The enhanced ACA subsidies expired at the end of 2025, leaving the prospect of higher premiums for consumers looming while negotiations dragged into January.
 
While a straight three-year extension of the ACA tax credits is a non-starter with Senate Republicans, the bill is a potential vehicle for compromise legislation. A bipartisan group of senators is moving closer to a deal on extending the subsidies with some reforms. Such a deal will likely be similar to Rep. Brian Fitzpatrick’s (R-Pa.) bill that would extend the subsidies for two years, cap income at 700% of poverty, require a minimum payment, and create a pathway for consumers to choose to put subsidies in health savings accounts (HSAs). The Fitzpatrick bill also cracks down on brokers, implements pharmacy benefit manager (PBM) reforms, and importantly, extends open enrollment through March.
 
Lawmakers continue to project optimism about reaching a deal, though thorny issues remain over how to address the so-called Hyde amendment, which restricts federal funding for abortion. Similarly, some Republicans’ long-held opposition to the ACA could ultimately keep a deal from happening. NABH will keep members apprised of any movement on this legislation.

Senate Confirms Journalist Sara Carter to Lead ONDCP

The Senate on Tuesday voted 52-48 to confirm journalist and former Fox News contributor Sara Carter to lead the White House Office of National Drug Control Policy (ONDCP).
 
A statement from the White House on Tuesday highlighted Carter’s experience as an investigative journalist exposing drug cartels and drug trafficking routes along the U.S.-Mexico border. Trump has spent part of his second term using the fight against illicit drug trafficking to depose Venezuela’s president, Nicolás Maduro, and to threaten other countries in the region with military action.
 
“We will hold accountable the narco-terrorists who infringe upon this right, participating in the deliberate poisoning of tens of thousands of Americans each year,” Carter said in the announcement about her confirmation as the country’s 10^th drug czar. “They will no longer kill our families, friends, neighbors, and even children with impunity,” she continued. “At the same time, I will ensure that every parent, family member, and child have the resources they need to prevent and combat addiction. I will stand with our brave law enforcement officials, and with every family who has lost a loved one to drug overdose. This is my promise to the American people.”

DEA and SAMHSA Temporarily Extend Flexibility for Prescribing Controlled Substances via Telemedicine

The Drug Enforcement Administration (DEA) and Substance Abuse and Mental Health Services Administration (SAMHSA) recently issued another temporary extension of the COVID-19 pandemic-era flexibility to the general requirement for practitioners to conduct an in-person medical evaluation before prescribing a controlled substance.
 
This extension allows practitioners to prescribe controlled substances via telemedicine to patients with whom they have never had an in-person visit through Dec. 31, 2026. The agencies implemented this extension to give them more time to consider further rulemaking on telemedicine, which could include establishing a special registration for telemedicine, as proposed previously.
 
Meanwhile, a final rule is now effective that allows practitioners to prescribe buprenorphine for opioid use disorder via telemedicine for up to 6 months before having an in-person visit or leveraging another regulatory pathway for telemedicine (including any forthcoming rule). However, buprenorphine for opioid use disorder is covered by the temporary extension discussed above, so the 6-month time limit would not be imposed until the extension expires at the end of 2026.
 
Please note that none of the aforementioned regulatory activities affect the use of telemedicine for medications that Opioid Treatment Programs dispense.

CMS Announces $50 Million in Rural Health Transformation (RHT) Program Awards

The Centers for Medicare & Medicaid Services (CMS) announced that all 50 states will receive awards under the Rural Health Transformation (RHT) Program, a five-year, $50 billion initiative established under Working Families Tax Cuts legislation (Public Law 119-21, also known as H.R. 1 or the One Big Beautiful Bill Act).
 
This year CMS will distribute first-year awards averaging $200 million per state. Awards ranged from $147 million in New Jersey to $281 million in Texas. Congress included the RHT program in the July 2025 budget reconciliation bill to mitigate the impact to rural communities of other cuts to the Medicaid program. 
 
CMS has compiled the RHT Program project abstracts each state submitted as part of its application. The Kaiser Family Foundation reported that the first-year RHT funds range from less than $100 per rural residents in 10 states to more than $500 per rural resident in eight states.
 
In December, CMS established the Office of Rural Health Transformation (ORHT) within the Center for Medicaid and CHIP Services (CMCS) to administer the RHT Program.

Fact of the Week

For the fifth year in a row, use of most substances among U.S. teenagers has continued to hover around the low-water mark reached in 2021, according to latest Monitoring the Future, an annual survey of drug use behaviors and attitudes among eighth, 10th, and 12th graders that the National Institutes of Health has supported for 51 years.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

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.

NABH 2026 Board Election Ballots 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 2026 Annual Meeting Registration Opens Next Week; View Our Schedule At-A-Glance

Next week NABH will alert members about preliminary speaker information and open registration for our 2026 Annual Meeting, Future-Forward Leadership: Imagine. Innovate. Transform. at The Ritz-Carlton Washington, DC from March 2-4.
 
Before then, please review our Schedule At-A-Glance to learn the days and times of committee meetings, general sessions, new breakout session, and more.

Senate Rejects Competing Healthcare Bills

The Senate rejected two competing healthcare bills on Thursday, Dec. 11.
 
Both bills fell short of the 60 votes need to pass. Senators voted not to advance a GOP healthcare bill that would have expanded health savings accounts as an alternative to the expiring the Affordable Care Act (ACA) Enhanced Premium Tax Credits. Meanwhile, the Democrats’ bill to extend the enhanced tax credits for three years also did not receive enough votes to pass.

The two votes fell largely along party lines. Sen. Rand Paul (Ky.) was the only Republican to oppose the GOP plan, while Republican Sens. Susan Collins (Maine), Josh Hawley (Mo.), Lisa Murkowski (Alaska) and Dan Sullivan (Alaska) voted to advance the Democrats’ healthcare plan. With time running out, House Republican leaders are expected to introduce a healthcare package this weekend that would expand health savings accounts but does not include an ACA extension.
 
Similarly, a bipartisan group of House lawmakers, led by Rep. Brian Fitzpatrick (R-Pa.), filed a discharge petition Wednesday, Dec. 10 on a bill that would extend the expiring ACA EPTCs for two years; implement income caps and a minimum payment requirement; extend open enrollment through March; add new broker requirements to curb unauthorized enrollments; and allow exchange consumers to establish health savings accounts and elect to send a portion of their tax credits to those accounts. There must be 218 signatures from lawmakers who approve this plan to bring the discharge petition to the House Floor, and House Democratic leaders have not indicated that they support it.
 
Meanwhile, the president’s general disengagement with lawmakers on healthcare talks has effectively doomed chances of a deal before the Dec. 31 expiration of the tax credits, although legislative failures in the Senate could potentially spur more serious negotiations.
 
Earlier this week, NABH sent a letter to senators and contacted their offices about the ACA’s EPTCs and its effect on expanding access to behavioral healthcare.

Senate Advances Resolution that Mandates Public Input on Most HHS Regulatory Activities

The Senate this week voted to advance to a floor vote Senate Joint Resolution 82, which would repeal an HHS policy statement issued in March 2025 that would narrow how HHS regulatory activities are subjected to notice and comment procedures.
 
Under the Administrative Procedures Act (APA), federal agencies are generally required to undertake notice and comment procedures (with exceptions), which consist of publishing proposed rules in the Federal Register, allowing the public to submit feedback on proposed rules, and publishing final rules that include agencies’ responses to public comments on proposed rules. Exceptions to this requirement include regulatory activities “relating to agency management or personnel or to public property, loans, grants, benefits, or contracts;” however, HHS policy since 1971 has been to apply notice and comment procedures to excepted regulatory activities.
 
The 2025 HHS policy statement rescinds the longstanding policy, meaning that some regulatory activities can be pursued without public input. The impact of this policy change is unclear, although other legal requirements may necessitate notice and comment procedures even for regulatory activities excepted under the APA. Meanwhile, the Social Security Act separately requires these procedures for most Medicare regulatory activities.
 
To successfully repeal the HHS policy statement, the House and Senate must pass the Joint Resolution and the President must sign it.

CMS Issues Preliminary Guidance on Medicaid Community Engagement Requirements

The Centers for Medicare & Medicaid Services (CMS) on Dec. 8 provided preliminary guidance to implement the Working Families Tax Cut’s (WFTC) community engagement requirements. The WFTC is also known as H.R. 1 or the One Big Beautiful Bill Act. States will be required to implement community engagement or work requirements for all adults in the Medicaid expansion population by Jan. 1, 2027.
 
The Center for Medicaid and CHIP Services (CMCS) Information Bulletin provides an overview of the WFTC legislation’s community engagement provision but does not provide many details. Importantly, the guidance does not include specific guidance about exempting beneficiaries with disabling mental disorders and substance use disorders.

NABH continues to engage CMS about the best way to ensure coverage continuity for people with behavioral health conditions who rely on Medicaid for their care. We hope our recommendations will support CMS decision-making prior to its publishing an interim final rule with detailed, binding implementation requirements by June 1, 2026.

CMS Seeks Public Comment on a New Safety and Follow-up Plan Measure

CMS on Dec. 5 published a request for public comment on a new measure for potential future inclusion in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program.
 
CMS is developing the Post-Discharge Safety and Follow-up Plan for Patients with Suicidal Ideation measure as part of a broader Behavioral Health Measures Development & Inpatient and Outpatient Measures Maintenance (BHIOMM) project.
 
NABH plans to submit public comments about the Safety and Follow-up Plan measure by CMS’ deadline of Dec. 19. Please contact Sarah Steverman with any feedback or questions.

U.S. Education Department Announces More Than $208 Million for School-Based Mental Health Services

The U.S Education Department on Thursday announced more than $208 million in new grant awards for the Mental Health Service Professional Demonstration and School-Based Mental Health programs.
 
According to the announcement, the new grants will be awarded to 65 recipients
will increase the number of credentialed school-based mental health service providers, delivering mental health services to students in high-need local educational agencies. 
 
Of the 65 new awards, 33 serve rural communities, allocating more than $120 million to rural states and school districts.

Reminder: SAMHSA to Host Webinar Dec. 17 on How Substance Use Trends Affect Child Safety

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar next week 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. 

Fact of the Week

A new National Alliance on Mental Illness poll found nearly 1 in 5 Americans say their mental health is poor right now, NPR reported this week. Meanwhile, nearly 2 in 3 Americans say they don’t think Congress is doing enough about mental health in America.

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

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.

2026 NABH Annual Meeting Update: Engage in Future-forward Leadership!

NABH is pleased to report the 2026 NABH Annual Meeting Program Committee has chosen Future-forward Leadership: Imagine. Innovate. Transform. as the theme of our next Annual Meeting at the Washington, DC-Ritz Carlton from March 2-4, 2026.
 
Our thanks to 2026 Annual Meeting Program Chair Cindy Meyer, M.S.S.W. from Rogers Behavioral Health and Program Committee Members Andrew Gerber, M.D., Ph.D., from Silver Hill Hospital and Lori Scharff, L.I.C.S.W. from Boys Town Behavioral Health Division for their constructive feedback in planning next year’s program.
 
NABH reported in last week’s CEO Update that we’re revising our Annual Meeting format in 2026 and will introduce Breakout Sessions to engage attendees during the meeting in between the General Sessions.
 
If you haven’t done so yet, please answer this one-question survey and rank the listed issue areas from your greatest priority (1) to your lowest priority (8).
 
Thank you for your time, and please read upcoming issues of CEO Update for more 2026 Annual Meeting information.

Trump Signs Spending Bill that Extends Certain Healthcare Policies Through January 2026

The longest government shutdown in U.S. history came to an end Thursday evening when President Trump signed into law a short-term spending package to fund the government through Jan. 30, 2026, and provide full-year appropriations (until Sept. 30, 2026) for the U.S. Agriculture and Veterans Affairs Departments and legislative operations.
 
The Continuing Resolution, or CR, also included several healthcare extenders but failed to extend the Affordable Care Act (ACA) subsidies that expire at the end of this year. Appropriators will need to work immediately to avert another shutdown cliff in just two months.
 
Senate Majority Leader John Thune (R-S.D.) promised to give Democrats a vote on the expiring marketplace subsidies in December. With Republicans largely against the ACA, the measure is not expected to pass in the Senate. However, negotiations are underway in the House and Senate to develop a compromise before the subsidies expire at the end of the year.
 
GOP moderates would like to see the subsidies extended at least temporarily with some additional guardrails, while GOP hardliners have sought to steer conversation away from the enhanced premium tax credits in favor of more sweeping alternative proposals that could reshape U.S. health insurance markets.
 
The CR extended major healthcare-related policies extended through Jan. 30, 2026. The new law:

• Funds community health centers.
• Resumes inpatient payments for Medicare low-volume hospitals and Medicare-dependent hospital payments.
• Delays Medicaid disproportionate share hospital payment cuts enacted under the ACA.
• Extends Medicare telehealth flexibilities through Jan. 30 and retroactively extends the flexibilities to when the programs had lapsed on Oct. 1.
• Exempts the package from statutory PAYGO (Pay-as-You-Go) and Senate PAYGO requirements to prevent Medicare sequestration cuts.
• Funds implementation of the No Suprises Act with a boost of $14 million.

The CR also includes three yearlong funding bills, collectively called a “minibus,” which fund the U.S. Agriculture Department, Legislative Branch Operations, and Military Construction/Veterans Affairs (VA). For the last of those three areas, the bill allocates $37 billion on non-VA medical care by private doctors, a record amount of funding from VA medical services to [non-VA] community care.

Trump Administration Proposes Cuts to Housing Grants; Shifts Funds to Program that Prioritizes Work Requirements and SUD Treatment

The Trump administration this week announced a shift of billions of dollars from housing aid for the nation’s homeless population to short-term programs that would impose work rules, help the police dismantle encampments, and require homeless individuals to accept treatment for mental illness or substance use disorders.
 
On Thursday, the U.S. Housing and Urban Development Department (HUD) released a 128-page notice and grant opportunity about this major change in policy that would allocate about $3.9 billion in a new Continuum of Care (CoC) Program. The program is intended to quickly rehouse homeless individuals, families, persons fleeing domestic violence, dating violence, sexual assault, and stalking, and youth while minimizing the trauma and dislocation caused by homelessness; to promote access to and effective utilization of mainstream programs by homeless individuals and families; and to optimize self-sufficiency among those experiencing homelessness.
 
The notice includes grant program criteria that seeks “management, substance use treatment, mental health treatment, and employment assistance) will ensure that the participant is able to successfully obtain self-sufficiency among those experiencing homelessness.”

Kellogg to Host Webinar on AI Adoption for Business Leaders on Friday, Nov. 21

Northwestern’s Kellogg School of Management will host a webinar titled The Insightful Leader Live: Drive Smarter Adoption with the 3 As of AI next week to help businesses avert common pitfalls and make the most of AI.
 
Kellogg experts will provide strategic solutions to help leaders audit existing workflows; identify where and when AI is most needed; and determine how it can be most effective. Panelists will also highlight three “As” of AI: Automate, which uses AI to handle repetitive tasks and improve efficiencies; Augment, which uses to AI to amplify human creativity and decision-making; and Analyze, which leverages AI to better understand and process large amounts of data to gain insight and support data-driven decision-making.
 
The webinar begins at 1 p.m. ET on Friday, Nov. 21. Click here to register.

Please Submit Your Updates for NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent. Thank you for your time.

Fact of the Week

A new study published in JAMA study found that 13% of surveyed youth between the 12-21 years old said they used generative AI for mental health advice.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Wants to Hear from You: Please Rank the 2026 Annual Meeting Breakout Session Topics!

NABH is revising its Annual Meeting format in 2026 and will introduce Breakout Sessions to engage attendees during the meeting in between the General Sessions.
 
Please take a moment to answer this one-question survey and rank the listed issue areas from your greatest priority (1) to your lowest priority (8).
 
Thank you for your time, and please read upcoming issues of CEO Update for more 2026 Annual Meeting information.

CMS Incorporates NABH Recommendations in the Final 2026 Physician Fee Schedule Rule

NABH is pleased to report the Centers for Medicare & Medicaid Services (CMS) incorporated some of the association’s recommendations in the final calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) rule the agency released on Oct. 31. 

In our comments to CMS on the proposed rule, NABH supported adding the three new HCPCS G-codes to incentivize and compensate for collaborative care for behavioral health conditions for Advanced Primary Care Management (APCM) services. CMS finalized the three new codes, expanding coverage to address comorbid physical health conditions that are common among people with behavioral health conditions.

NABH is also pleased that CMS finalized coverage for digital mental health treatment (DMHT) devices used in the treatment of Attention-Deficit/Hyperactivity Disorder. Presently, CMS covers DMHT devises that have received U.S. Food and Drug Administration (FDA) clearance, approval, or authorization. In the proposed rule, we expressed concerns with CMS expanding coverage for digital tools that have not been subjected to FDA oversight. In the final rule, CMS did not establish coding for a broader set of digital tools intended as complements to mental health treatment but will consider doing so in future rulemaking.

CMS finalized its proposed policy to include marriage and family therapists (MFTs) and mental health counselors (MHCs) as practitioners who can bill Medicare directly for Community Health Integration services (HCPCS codes G0019 and G0022), Principal Illness Navigation services (HCPCS codes G0023 and G0024), and Principal Illness Navigation – Peer Support (HCPCS code G0146).

NABH also supported CMS’ proposal to extend or make permanent certain telehealth flexibilities, including permanently removing frequency limitations for subsequent inpatient visits. CMS finalized that proposal, as well as a proposal to adopt permanently a definition of direct supervision to include virtual presence via appropriate audio/video real-time communication technology.

Finally, NABH urged CMS to consider extending the waiver allowing providers to report practice addresses instead of home addresses when they perform telehealth services from their home. We are disappointed CMS did not address this issue in the final rule.

Please see CMS’ fact sheet about the final PFS rule for more information.

Center for Connected Health Policy Releases 2025 State Telehealth Policy Summary

The Center for Connected Health Policy (CCHP) recently released its 2025 State Telehealth Policy Summary.
 
The Fall 2025 Summary Report includes state telehealth laws and Medicaid program policies and links to an updated online Policy Finder tool. The report provides a national overview of state telehealth policy and the Policy Finder offers state-specific information for the 50 states, District of Columbia, Puerto Rico, and the Virgin Islands.
 
The report includes laws, regulations, and policy documents on an array of telehealth topics, including Medicaid and Medicare reimbursement, private payer laws, professional requirements, and federally qualified health centers (FQHCs). 

AAPC to Host Webinar on Improving Accuracy & Documentation in Behavioral Health Claims

Experts from firm AAPC – the nation’s largest education and credentialing organization for medical coders, billers, auditors, practice managers, documentation specialists, compliance officers, and revenue cycle managers – will host a webinar next week to share insights into how credentialed professionals can navigate behavioral health compliance challenges.

The webinar will help attendees learn how to recognize documentation and coding pitfalls, prevent payor denials through staff credentialing and structured training, strengthen audit readiness, and more.

Click here to register for the webinar on Tuesday, Nov. 11 at 1 p.m. ET.
 
Please Submit Your Updates for NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent. Thank you for your time.

Fact of the Week
North Carolina Gov. Josh Stein (D) signed a law this past summer requiring the North Carolina Department of Health and Human Services to suspend, rather than terminate, Medicaid coverage for people entering jails, bringing the state in line with federal requirements that become effective on Jan. 1, 2026. This distinction is notable because Medicaid generally does not pay for health care provided in state and local prisons and jails. Learn more here from a Pew report about the issue.

Many Thanks to All Veterans!

As Veterans Day approaches, NABH thanks its members and their families who have served or are serving in the U.S. military. We appreciate your sacrifice and service.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

American Foundation for Suicide Prevention Launches New Collection of Resources

The American Foundation for Suicide Prevention (AFSP) recently launched The Upright, a collection of research, program, and policy resources that aim to advance health equity in suicide prevention. The resources are meant to support localities, organizations, and individuals wishing to develop suicide prevention strategies in underserved communities.
 
As part of the launch, AFSP will host The Summit, three virtual events featuring local and national experts who have supported suicide-prevention strategy implementation. The events will highlight community-based programs that have shown measurable impact on suicide outcomes.

AFSP will host the first of the three events on Tuesday, Oct. 28, from 2– 4:15 p.m. ET. The event will feature suicide prevention experts with experience embedding health equity into suicide-prevention efforts.

CMS Instructs Medicare Administrative Contractors to Lift Claims Holds

The Centers for Medicare & Medicaid Services on Oct. 21 provided updated guidance that instructs all Medicare Administrative Contractors (MACs) to lift the claims hold CMS announced at the start of the government shutdown and process claims with dates of service of Oct. 1, 2025, including claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, Federally Qualified Health Center (FQHC) claims, and telehealth mental health services claims.
 
Specifically, the new guidance instructs MACs to lift the claims hold for “telehealth claims that CMS can confirm are definitively for behavioral and mental health services.” CMS directed MACs to continue to hold claims for other non-behavioral health telehealth services and for acute Hospital Care at Home claims.

This latest guidance follows the agency’s Oct. 15 guidance on new in-person visit requirements, which requires all new Medicare patients receiving mental health treatment via telehealth to have received an in-person visit within the past six months and every 12 months after the initial telehealth visit. As reported in last week’s edition of CEO Update, CMS clarified that established telehealth patients do not need to have had an in-person visit within six months and only must receive an in-person visit in the next 12 months to continue mental health treatment via telehealth.

NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.
 
Thank you for your time and all you do to advance NABH’s Vision and Mission!

Fact of the Week

A new ballot initiative in California – the California Kids AI Safety Act – would restrict kids’ access to AI chatbots without safety guardrails, establish statutory damages for AI harms, and limit the sale of minors’ data and require third-party audits of AI tools, Politico reported this week.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Please Help Us Identify New NABH Board Members by Monday, Oct. 20

As the NABH Selection Committee prepares to consider possible nominees, please help us identify potential candidates for: 

     ► Board Chair-Elect and
     ► One Board seat that will open in 2026

The Selection Committee is interested particularly in identifying senior managers who represent the broad diversity of NABH’s membership, including various levels of care, organizational structures, and size.   

Please download a nomination form to recommend individuals you would like to see included in the single slate for 2026. Please attach a curriculum vitae (CV) for each person you recommend. This will help the Selection Committee in its deliberations. You are welcome to suggest yourself. 

Please return this form (and candidates’ CVs) by Monday, Oct. 20, 2025, to maria@nabh.org.

Thank you for your time and recommendations!

CMS Releases Additional Guidance on Medicare Telehealth Services

In guidance released Oct. 15, the Centers for Medicaid & Medicaid Services (CMS) said effective as of Oct. 1, Medicare patients initiating mental health treatment via telehealth must have an in-person visit within the previous six months and every 12 months after the initial telehealth visit.

The agency’s latest guidance also noted “… if a beneficiary began receiving mental health services on or before Sept. 30, 2025, then they would not be required to have an in-person visit within 6 months; rather, they will be considered established and will instead be required to have at least one in-person visit every 12 months.”

NABH and partners are urging Congress to continue the Covid-19 pandemic’s flexibilities and retroactively allow telehealth visits for new patients without an in-person visit. Without congressional action, providers who initiate mental health services via telehealth to new patients without an in-person visit may not be reimbursed for the service. CMS recommends providers who perform telehealth services and are unsure if they will be reimbursed should provide beneficiaries with an Advance Beneficiary Notice of Noncoverage, or ABN.

This policy change does not affect telehealth services for substance use or co-occurring treatment, which do not require initial and annual in-person visits. CMS instructed all Medicare Administrative Contractors to continue temporarily holding claims for services provided after Sept. 30, including claims paid under the Medicare Physician Fee Schedule, ground ambulance transport claims, and all Federally Qualified Health Center claims. This policy change does not affect Medicaid, commercial, PHP/IOP, or IPF claims.

Federal Agency Reductions in Force Draw Scrutiny from Lawmakers as Government Shutdown Enters Week #4

Friday, Oct. 17 marks Day #17 of the federal government shutdown and there’s no resolution in sight to break the impasse.

Senate Majority Leader John Thune (R-S.D.) continues to force Senate lawmakers to vote on the House-passed Continuing Resolution that would fund government operations through Nov. 21. However, Democrats remain firm in resisting the measure and demanding a vote to extend the Affordable Care Act’s tax credits before they support legislation to fund the government.

As the shutdown continues, the Trump administration has initiated reductions in force (RIF) across numerous federal agencies, including HHS and the Substance Abuse and Mental Health Services Administration (SAMHSA), which has raised concerns from lawmakers.

Meanwhile, Democratic Reps. Paul Tonko (D-N.Y.), Don Beyer (D-Va.), Madeleine Dean (D-Pa.), Lori Trahan (D-Mass.), Brittany Pettersen (D-Colo.), and Andrea Salinas (D-Ore.) – all mental health and substance use disorder treatment champions – this week urged HHS to immediately reinstate fired SAMHSA staff and provide information about the effects of the departmental reorganization and RIF on the agency’s operations,

In their letter to HHS Secretary Robert F. Kennedy, Jr., the lawmakers wrote these actions — which have reduced SAMHSA’s staff by more than half since the start of the Trump administration — run contrary to bipartisan congressional intent and undermine the nation’s response to its mental health and substance use disorder crises. These lawmakers each serve as leaders in either the Addiction, Treatment, and Recovery (ATR) Caucus, the Bipartisan Mental Health and Substance Use Disorder Task Force, or the Mental Health Caucus.

NABH will continue to keep members informed as we learn new developments regarding government funding and agency staffing and services. Please contact Andy Dodson if you have questions or face challenges related to federal programs and services.  

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.

Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.

To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.

Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.

Thank you for your time and all you do to advance NABH’s Vision and Mission!

Attention All ‘Unit’  Committee Members: Register Today for NABH’s Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

A new JAMA Psychiatrystudy that examined the efficacy of heart rate variability biofeedback, or HRVB, in treating 115 adults with SUD found that those who received HRVB experienced significant reductions in negative affect, craving, and alcohol and other drug use relative to controls. The findings suggest that HRVB practice may disrupt moment-level associations between craving and substance use, highlighting its potential as an adjunctive SUD treatment.

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

Please Help Us Identify New NABH Board Members

As the NABH Selection Committee prepares to consider possible nominees, please help us identify potential candidates for: 

     ► Board Chair-Elect and
     ► One Board seat that will open in 2026
 
The Selection Committee is interested particularly in identifying senior managers who represent the broad diversity of NABH’s membership, including various levels of care, organizational structures, and size.   
 
Please download a nomination form to recommend individuals you would like to see included in the single slate for 2026. Please attach a curriculum vitae (CV) for each person you recommend. This will help the Selection Committee in its deliberations. You are welcome to suggest yourself. 

Please return this form (and candidates’ CVs) by Monday, Oct. 20, 2025, to maria@nabh.org.

Thank you for your time and recommendations!

Please Submit Updates for the NABH’s Online Membership Directory

NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
 
The original deadline for changes was Oct. 3; however, the NABH team is glad to receive this information at any time because it is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
 
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent.
 
Thank you for your time and all you do to advance NABH’s Vision and Mission!

Uncertainty Remains After Oct. 1 Telehealth Changes Arrive

NABH and its members are looking to CMS for additional guidance after the agency’s telehealth requirements became effective on Oct. 1.
 
For the last several years, Congress extended telehealth policies set to expire on Sept. 30 to allow continued Medicare reimbursement for telehealth services that were not allowed before the Covid-19 public health emergency (PHE).

That changed on Oct. 1 after Congress failed to extend those telehealth flexibilities and CMS furloughed staff during the federal government shutdown, leaving providers confused about what they should bill Medicare for and how.

Thanks to previous congressional action, mental health and substance use services delivered through telehealth services continue to be covered in many cases. For instance, substance use services and services provided for co-occurring mental health and substance use conditions may be delivered via telehealth, regardless of a patient’s geographic location or originating site (i.e., physical location, such as a person’s home).

As of Oct. 1, 2025, CMS requires that if patients receive a mental health telehealth visit, they must have had an in-person visit within the past 6 months (and every 12 months after the initial telehealth visit). When this requirement was imminent at the end of the PHE on May 11, 2023 (before Congress acted to extend flexibilities), CMS said it would waive the requirement for established patients to have received an in-person visit within the past 6 months, requiring only an annual in-person visit thereafter (this requirement was also delayed through Sept. 30, 2025).

Presently, without further guidance, providers cannot be certain if CMS will grandfather established patients and only require an in-person visit within the preceding 6 months for new telehealth patients.

Meanwhile, for new and established patients receiving mental health services via telehealth, CMS allows the required in-person service to be administered by a colleague in the same sub-specialty within the same group practice if the original practitioner is unavailable. In addition, patients and providers may agree to waive the in-person visit if the “risks and burdens of travel outweigh the benefits of an in-person encounter,” according to CMS. If the patient and provider waive the in-person visit, the practitioner must document the reason for this decision in the patient’s medical record.

NABH had hoped CMS would provide information about this policy change; however, since the government shutdown began, CMS has not released additional guidance. As a reminder, this policy change only affects Medicare mental telehealth visits billed to the Physician Fee Schedule and does not impact Medicaid, commercial, PHP/IOP, IPF, or substance use services.
The Center for Connected Health Policy released an FAQ Resource Document to address complex questions Medicare providers may have.

NABH urges members to consult their billing and legal experts to determine their approach to the uncertainty, and we will keep members apprised of any new information we learn.

HHS OIG Recommends Changing Medicare OTP Funding Methodology to Lower Expenditures

A report from the U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) this week showed if the Medicare program’s Opioid Treatment Program (OTP) bundled payment methodology had better reflected the frequency of services delivered, the program could have saved Medicare $301.5 million (53% of total payments to OTPs) between Jan. 1, 2020 and Sept. 30, 2022.
 
The HHS OIG provided several recommendations to the Centers for Medicare & Medicaid Services (CMS), including that the agency should: 1) consider revising its methodology for the non-drug component of the bundle, 2) consider developing additional HCPCS codes for bundles based on the types and frequency of services provided, and 3) perform monitoring activities to ensure that Medicare only pays when OTPs have properly documented treatment services in patients’ treatment plans.
 
CMS has implemented the first recommendation and indicated it will consider revisions to the bundled payment methodology each year during the rulemaking process. Meanwhile, CMS did not concur with the second or third recommendations. For recommendation #2, CMS said the recommendation is outside the scope of CMS’ statutory authority; and for #3, CMS said it does not require treatment plans as a condition of payment.

Digital Medicine Society Releases Blueprint for Implementing AI in Healthcare

The Digital Medicine Society has released The Playbook, a guide to implementing AI that the organization says is meant to help providers navigate the complexities of AI into clinical care and deliver better outcomes for patients.
 
The new resource guides users through three, interconnected sections: 1) Identify the Problem and Assess Your Readiness, 2) Source, Evaluate, and Choose the Right AI Tool, and 3) Implement AI Across Your System.
 
In related news, the U.S. Food and Drug Administration (FDA) announced last month it will convene an advisory committee on AI and mental health devices. Reuters reported in September that the FDA Digital Health Advisory Committee expected to meet on Nov. 6 to examine how these digital tools could help address a widening gap in access to mental health services in the United States, while also exploring the unique risks they pose.

Attention All NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

A recent survey from the International Academies of Emergency Dispatch found most mental health crisis calls in the United States still go to 911, not 988: the findings showed that in 2023, Emergency Crisis Centers (ECCs) across the United States received at least 24 million calls involving a mental health crisis, compared with the 17 million calls, texts, and chats the 988 Suicide & Crisis Lifeline received since its launch in 2022.

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

Shawn Coughlin Retires; Previous NABH President and CEO Mark Covall Named Interim Leader

Shawn Coughlin retired as NABH’s president and CEO this week after nearly six years in the position. The NABH Executive Committee named Mark Covall as interim president and CEO as it engages an executive search firm to find Coughlin’s successor.
 
Coughlin served previously as the association’s executive vice president of government relations and policy from 2017 until he began his role as president and CEO in January 2020. In all, he has spent 14 years working directly for or with NABH as a leader or consultant.
 
“It has been an honor to lead the preeminent behavioral healthcare association in the country,” Coughlin said in a statement NABH released this week. “Having started my leadership role with the association during the opioid crisis and guiding it through the Covid-19 pandemic, it is time for me to turn my attentions to other opportunities.”
 
Covall retired from NABH in December 2019 after more than 35 years with the association and 24 years as its president and CEO. He began his interim role on Oct. 1.
 
“On behalf of the NABH Board of Trustees, we thank Shawn for his years of service to our association,” NABH Board Chair Jim Shaheen said in the statement. “His passion for lobbying has helped guide our members through some critical times and several legislative and regulatory changes,” he continued. “We all wish Shawn continued success.”

No Major Changes Expected for Behavioral Healthcare Providers as Government Shutdown Continues

The federal government is ending week one of its shutdown and there appears to be no end in sight as negotiations continue.
 
NABH does not expect legislative or regulatory changes that would affect behavioral healthcare providers’ work during the shutdown. Meanwhile, the NABH Government Relations team continues to contact congressional offices about extending the expiring enhanced Affordable Care Act (ACA) tax credits, eliminating cuts to the Medicaid Disproportionate Share Hospital (DSH) payments, and extending Medicare’s telehealth flexibilities. 
 
The shutdown officially began Wednesday, Oct. 1 at 12:01 a.m. ET after senators rejected competing Democratic and Republican bills to keep the government open. Previously, House lawmakers passed a continuing resolution (CR) that would have funded the government until Nov. 21 and contained several healthcare extenders. In the Senate, lawmakers needed seven Democratic votes to meet a 60-vote threshold for the measure to pass. That didn’t happen after Democrats demanded extending ACA credits and repealing H.R. 1 health policies in exchange for their votes, which the Senate rejected.
 
In addition to lapsed federal funding, the legal authority allowing Medicare to provide reimbursement for some non-behavioral health telehealth services delivered to patients in their home also lapsed, as well as the Oct. 1 deadline that marks the start of cuts to Medicaid DSH funding. In the past, federal lawmakers reauthorized these programs retroactively after the shutdown ended; however, this practice creates uncertainty in the interim.

In guidance this week, CMS directed all Medicare Administrative Contractors to implement a temporary claims hold. “The hold prevents the need for reprocessing large volumes of claims if Congress acts after the statutory expiration date and should have minimal impact on providers due to the 14-day payment floor,” the guidance noted. Providers may continue to submit claims; however, payment will not be released until the hold is lifted. NABH continues to analyze the guidance and will keep members apprised when we have more information.

Senate Majority Leader John Thune (R-S.D.) this week continued to bring the House CR to a vote on the Senate floor. Although the measure failed repeatedly, several additional Democratic senators supported passing legislation.
 
Meanwhile, a bipartisan group of senators is working on a deal that would extend ACA credits while simultaneously reducing costs and fraud in federal healthcare programs to reach a compromise. Other lawmakers have proposed extending the subsidies for one year and follow that with a one-year phasedown as a way to return the tax credits to pre-pandemic levels.
 
Within the federal agencies, HHS has said it has the necessary staff to execute mandatory activities. The shutdown leaves the Centers for Medicare & Medicaid Services (CMS) with only 53% of its workforce, according to HHS’ recently published 2026 contingency plan. The Medicare program will still cover claims during the shutdown; however, the contingency plan notes that enrollment education and outreach will slow down, which would happen just weeks before the Medicare annual enrollment period kicks off.
 
NABH has learned the Veteran Affairs Department (VA) has not been affected as other federal agencies have because Congress has already provided appropriations for this agency. The VA will continue to process benefits checks, and medical appointments at VA health centers will not be disrupted. However, the VA is closing several support phone services and regional VA benefits offices temporarily during the shutdown.
 
As NABH noted to members earlier this week, we will continue to keep you informed as we learn new developments. Please contact Andy Dodson if you have questions or face challenges related to federal programs and services.  

States Advance Applications for the Rural Health Transformation Program

CMS held a webinar on Tuesday, Sept. 30 to provide states and relevant stakeholders with guidance about the Rural Health Transformation (RHT) Program as all federal offices faced a looming government shutdown at 11:59 p.m. ET that day. 
 
CMS staff said 27 states had submitted optional letters of intent as of Tuesday morning.
 
The agency said it intends for the RHT Program to provide funding to states and their subrecipient organizations for infrastructure, including investing in workforce, updating technology, and other innovations. States may only use 15% of grant funds for services and those funds cannot be used to supplant current funded services.
 
CMS said it will allow only up to 5% of total funding to be used to replace an electronic medical record (EMR) system if a previous HITECH-certified EMR system was in place as of Sept. 1, 2025. CMS told attendees they plan to release additional guidance on the program’s funding limitations.
 
Applications are due Nov. 5, 2025 and CMS plans to send funding announcements to states by Dec. 31, 2025.
 
CMS has deemed RHT Program staff essential employees during the government shutdown, so they will continue to provide additional guidance and technical assistance to state applicants. To stay up-to-date on the RHT Program, sign up for email updates from CMS.

Mental Health America Releases 2025 Report on Mental Health and Well-Being in the United States

Advocacy group Mental Health America (MHA) this week released The State of Mental Health in America 2025 that highlights the latest national data and provides state-level rankings on mental health and well-being in the United States.
 
MHA uses national survey data to measure a community’s mental health needs, access to care, and outcomes, regardless of the differences among states and their varied mental health policies.
 
According to the report, nearly 3 million American youth ages 12-17 have frequent thoughts of suicide and 77% of U.S. adults with substance use disorder did not receive treatment.
 
The report also included some hopeful news, as survey data showed the percentage of youth ages 12-17 who experienced a major depressive episode decreased to 15.4% in 2024 from 18.1% in 2023, while the percentage of youth ages 12-1 who reported serious thoughts of suicide in the past year decreased to 10.1% in 2024 from 12.30% of youth in 2023.
 
The 45-page report provides a comprehensive summary of key findings, state rankings, mental health prevalence among adults and youth, access to care for all ages, and mental health workforce availability.

Attention All NABH ‘Unit’ Committee Members: Register Today for NABH’s 2025 Fall Leadership Forum!

To all NABH members who serve on the Behavioral Health Services within General Healthcare Systems Committee (Unit Committee): join your fellow members for the 2025 NABH Fall Leadership Forum in Tampa, Fla. on Thursday, Nov. 6 through Friday, Nov. 7.
 
NABH thanks our member BayCare Behavioral Health for hosting this two-day meeting, which is designed to provide Unit Committee members with exclusive access to discussions with experts in the field and valuable opportunities for peer-to-peer engagement.
 
Please contact NABH Operations Coordinator Meghan Barrett at meghan@nabh.org for additional details and meeting agenda.

Fact of the Week

New York, Hawaii, and New Jersey (in that order) scored the best across 17 measures of prevalence of mental illness and access to mental health care, according to MHA’s 2025 report on the state of mental health and well-being in America.

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

Reminder: Please Submit Your System’s Information for the NABH 2025 Membership Directory Updates by Next Friday, Oct. 3

NABH is compiling information for its 2025 Membership Directory, which we will publish online only. To help ensure we have the most accurate member information, please use the link to our membership update tool that NABH sent to all system members earlier this month and verify your system’s information.
 
Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership. The answers to these questions will help us provide a more accurate description of our members to policymakers, regulators, partner organizations, and the media.
 
The deadline to submit your changes to NABH is next Friday, Oct. 3.  If you need assistance or the link to be resent, please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104.

NABH & Partner Groups Urge Congressional Leaders to Extend Telehealth Flexibilities and Enhanced Premium Healthcare Tax Credits

NABH and our partners in the Mental Health Liaison Group (MHLG) this week urged House and Senate leaders to establish a two-year or permanent extension of Medicare telehealth services flexibilities and pass an extension of enhanced premium healthcare tax credits.
 
To learn more, please read the MHLG’s telehealth letter and the organization’s tax credits extension letter.

HHS-OIG Urges CMS to Help States Better Ensure Children at Risk of Suicide Receive Timely Follow-Up Care

A new report from the HHS Office of Inspector General (OIG) recommended the Centers for Medicare & Medicaid Services (CMS) should assist low-performing states to better ensure children at risk of suicide receive timely follow-up care.
 
The report showed that in half of cases of hospitalization or emergency department (ED) visits for suicidal thoughts or behaviors, children enrolled in Medicaid did not receive a follow-up visit in the week after their discharge—a critical time for intervention.
 
When children did receive follow-up visits, researchers found, most visits occurred with behavioral health providers such as counselors, social workers, and psychiatrists.
 
“Subject matter experts whom OIG interviewed attributed the lack of timely follow-up visits to provider shortages and difficulties connecting children to care,” the report noted. “The experts also shared that brief interventions from any type of provider could support children while they await more comprehensive care from a behavioral health professional (e.g., telephone contacts and safety planning).”

The report also noted suicide is the second leading cause of death for children in the United States. In 2023, nearly 225,000 children aged 10–17 who were enrolled in Medicaid were hospitalized or visited the ED for suicidal thoughts or behaviors.
 
“OIG interviewed experts who told us that a follow-up visit should occur anywhere from 24 hours to 1 week after a child’s discharge from the hospital or ED,” the report said.

Kaiser Family Foundation Report Examines CMS’ Rural Health Fund Announcement

A new report from the Kaiser Family Foundation (KFF) highlights five essential points from CMS’ recent rural health Notice of Funding Opportunity (NOFO).
 
KFF’s analysis notes CMS will distribute $25 billion equally across states with approved applications and the remaining $25 billion based on numerous factors, some more data-driven than others; states will receive more funds if they adopt Make America Healthy Again policies; while the $50 billion fund could help rural communities in a number of ways, the extent to which it will benefit rural hospitals and offset their losses under the reconciliation law is unclear; it remains unclear which states and rural hospitals will benefit the most; and it is unclear how transparent CMS and states will be about the distribution and oversight of the fund, such as by disclosing the flow of dollars to specific hospitals and other entities.
 
“While the NOFO includes many new details about how the funds will be distributed across states,” the KFF report noted, “questions remain about which states will receive funding, the final distribution across approved states, and how well this distribution will align with various definitions of need.”

Fact of the Week

A new JAMA study suggests expanding access to behavioral healthcare may be a financially viable cost-reduction strategy for healthcare buyers.

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

House Passes Short-Term Funding Bill

The House passed a continuing resolution on Friday to fund the federal government through Nov. 21, which would give Congress more time to develop a full-year funding package.
 
The bill now heads to the Senate, where it needs 60 votes to pass, necessitating some Democratic votes in support. Congress must pass the bill by the end of September to avoid a government shutdown.
 
The bill also includes several healthcare extenders, including delaying the expiration date for Medicare telehealth flexibilities and preventing cuts to the Disproportionate Share Hospital (DSH) program, which helps hospitals cover the cost of treating patients who are uninsured or underinsured. This comes amidst growing Congressional concern about the significant potential harms of DSH cuts, with a bipartisan group of 141 Representatives sending a letter to House leadership this week urging that current funding be maintained.
 
However, the bill does not extend the enhanced premium tax credit (EPTC) that improves the affordability of Marketplace plans.

Senate Passes SUPPORT Act Reauthorization

On Thursday, the Senate passed the SUPPORT for Patients and Communities Reauthorization Act of 2025, which reauthorizes billions of dollars in funding to address overdoses, substance use disorders, and mental disorders.
 
A variety of programs are reauthorized through fiscal year 2030, such as grants to address substance use disorders among pregnant and postpartum women, grants to promote housing for individuals in recovery from substance use disorders, and a loan repayment program for certain health care providers treating substance use disorders.
 
Additionally, the bill establishes new requirements for the U.S. Department of Health and Human Services, including establishing a Federal Interagency Work Group on Fentanyl Contamination of Illegal Drugs, and conducting a review of the scheduling of buprenorphine/naloxone combination products under the Controlled Substances Act.
 
The Act previously passed the House on June 4, 2025. With Senate passage, the bill now goes to the President for his signature.

CMS Finalizes New Provide Directory Requirements for Medicare Advantage Organizations

The Centers for Medicare & Medicaid Services (CMS) this week finalized a new rule that will require Medicare Advantage (MA) organizations to submit data on their provider directories, which will be published online as part of the Medicare Plan Finder tool.
 
In addition to providing the data to CMS, MA organizations will need to update their provider directory data within 30 days of discovering any changes, as well as attest to CMS at least annually that the information submitted is accurate.
 
The final rule will be applicable beginning Jan. 1, 2026.

Please Submit Changes for the NABH 2025 Membership Directory by Friday, Oct. 3

NABH is compiling information for its 2025 Membership Directory, which we will publish online only. To help ensure we have the most accurate information on our members, please use the link to our membership update tool that was sent earlier this week to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
 
The answers to these questions will help us provide a more accurate description of our members to policymakers, regulators, partner organizations, and the media.
 
The deadline to submit your changes to NABH is Friday, Oct. 3.  If you need assistance or the link to be resent, please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104.
 
As always, thank you for your time and for all you do to provide quality behavioral healthcare to those who need it most.

CBO Estimates $350 Billion Cost to Permanently Extend EPTC

This week, the Congressional Budget Office (CBO) released a new estimate of the effects of permanently extending the EPTC – a credit that reduces the premiums of Marketplace plans – which is scheduled to expire at the end of calendar year 2025 after first being introduced in 2021.
 
CBO estimates that permanent extension would increase the federal deficit by $350 billion through 2035, and by that year, 3.8 million more people would have health insurance than if the EPTC reverts to its original structure. They also estimate that benchmark plan premiums would be 7.6% lower (not factoring in the tax credit), given that healthier individuals would be more likely to enroll with the EPTC.
 
The original premium tax credit was limited to individuals with incomes between 100-400% of the federal poverty level, while the EPTC eliminated the maximum income threshold for eligibility.

Senate Confirms EBSA Nominee

The Senate on Thursday confirmed Daniel Aronowitz to lead the Employee Benefits Security Administration (EBSA) in the U.S. Department of Labor.
 
Previously, Mr. Aronowitz served as the President of Encore Fiduciary, a fiduciary liability underwriting company.
 
EBSA is the primary federal regulator overseeing employee benefits, including most employer-sponsored health plans. Notably, EBSA is one of three agencies – alongside CMS and the Internal Revenue Service – tasked with implementing the Mental Health Parity and Addiction Equity Act.

CMS Releases Rural Health Transformation Program Funding Opportunity

On Monday, CMS released the Notice of Funding Opportunity (NOFO) for the Rural Health Transformation (RHT) Program. Congress appropriated $50 billion for the RHT Program in H.R. 1, which will be available to states for five fiscal years.
 
CMS will issue cooperative agreements to states with approved applications. States must involve rural stakeholders – which could include NABH members with facilities in rural areas – throughout the application and implementation phases. CMS also requires states to identify the organizations intended to receive RHT funding within their applications. Therefore, NABH encourages all members to review the NOFO and work with their states to support their RHT Program application.

CMS will host two webinars for program applicants and interested stakeholders:

• Friday, Sept. 19 from 3 – 4:30 p.m. ET; register here.
• Thursday, Sept. 25 from 3 – 4:30 ET; register here.

States must submit applications by Nov. 5, 2025. CMS will only have one funding opportunity for this program and will announce awardees by Dec. 31, 2025.

Joint Commission and Coalition for Health AI Issue Guidance for Responsible Use of AI

Joint Commission and the Coalition for Health AI (CHAI) on Wednesday issued guidance on artificial intelligence (AI) use in healthcare, which is intended to “serve as internal governance to help U.S. health systems safely and effectively implement [AI] at scale.”
 
The guidance includes high-level recommendations for responsible use of AI across seven elements: AI Policies and Governance Structures, Patient Privacy and Transparency, Data Security and Data Use Protections, Ongoing Quality Monitoring, Voluntary, Blinded Reporting of AI Safety Related Events, Risk and Bias Assessment, and Education and Training.
 
From these high-level recommendations, Joint Commission and CHAI will develop a series of playbooks to include baseline controls, examples, and challenges to each element. The organizations are soliciting feedback on the initial document and will incorporate community feedback and examples into updates of this guidance and the Playbooks, which they say will be released later this year and into 2026.
 
If any NABH members have feedback on the newly released guidance or how AI is or could be used in their organizations, please contact Emily Wilkins, NABH’s director of government relations (emily@nabh.org).

GAO Releases Report on Administrative Spending for Georgia’s Medicaid Work Requirements

The Government Accountability Office (GAO) released a report this week examining the administrative processes and costs to implement work requirements in Georgia’s Medicaid program.
 
In 2020, CMS approved Georgia’s Medicaid section 1115 demonstration request to expand coverage to adults aged 19-64 contingent on them reporting 80 hours of work or educational activities each month. To implement the demonstration, Georgia needed to make several changes to their administrative eligibility and enrollment systems, conduct specialized outreach efforts, and undertake other administrative tasks prior to opening enrollment in 2023.
 
In the first 4.5 years of the program, Georgia reported spending $80.3 million total, of which $54.2 million were administrative costs. The federal government funded 88% ($47.4 million) of the administrative costs, which GAO warns may have exceeded the allowable match rate. In addition to the high administrative costs to the federal government, GAO found weaknesses in CMS’ oversight of that spending.
 
This report helps shed light on the processes and costs associated with Medicaid work requirements, which is especially important as states begin implementing work requirements and other changes to Medicaid included in H.R. 1.

Fact of the Week

A new study found that individuals with opioid use disorder who received medication during incarceration were more likely to continue treatment six months post-release than those who did not. Medication receipt was also associated with substantial reductions in adverse risks: 52% for fatal opioid overdose, 24% for nonfatal opioid overdose, 56% for all-cause mortality, and 12% for reincarceration.

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

Congress Faces Host of Decisions as Federal Funding Deadline Looms

Congress returned from its August recess last week to a fall agenda that requires lawmakers to
decide on how it will fund the federal government and extend critical healthcare programs.
 
The House has 10 legislative days, and the Senate has 12 legislative days to determine how to fund federal government operations before the Sept. 30 deadline.  
 
Multiple factions within Congress have advocated different funding approaches. The White House this week suggested Congress delay the upcoming government shutdown deadline to Jan. 31, creating a four-month extension that Democrats and many Republican lawmakers oppose.
 
The proposal would couple a funding extension of federal health insurance subsidies set to expire on Jan. 1 with government funding through September 2026. As congressional Republicans continue to manage messaging about pending Medicaid changes included in this summer’s H.R. 1, One Big Beautiful Bill Act (OBBBA), the threat of surging costs for those families who purchase their insurance through the exchanges is becoming clearer. Unless Congress acts, premiums will spike for both subsidized and unsubsidized enrollees. If the enhanced tax credits expire, an estimated 4 million people could stop receiving coverage through the Marketplace by 2026.
 
Meanwhile, Democrats and Republicans alike are paying close attention to pending Medicaid Disproportionate Share Hospital (DSH) cuts, which could be addressed as part of a government funding extension. DSH payments help compensate hospitals that deliver care to a high volume of uninsured individuals and Medicaid beneficiaries, as Medicaid reimbursement is typically well below the actual cost of behavioral healthcare. Medicaid DSH cuts are scheduled to take effect on Oct.1, 2025, unless Congress acts. If this occurs, many behavioral healthcare providers will be forced to reduce services, limit availability of inpatient treatment, or close their doors.
 
NABH sent an Action Alert to members asking them to urge their lawmakers to act by Sept. 30 to avert the DSH cuts before the Oct.1 deadline and also act by Sept. 30 to extend the enhanced tax credits.
 
We also joined our coalition partners in asking our members to urge their representatives to sign a congressional letter to House leaders imploring them to prevent the DSH cuts. NABH sent this Action Alert Thursday and hopes to have several new representatives sign the letter by next week’s Tuesday, Sept. 16 deadline. As of Sept. 11, more than 60 representatives signed the letter to House Speaker Mike Johnson (R-La.) and House Minority Leader Hakeem Jeffries (D-N.Y.).
 
Numerous other healthcare programs are set to expire at the end of September, including extending telehealth authority and reauthorization of the SUPPORT Act. Last week, Rep. Buddy Carter (R-Ga.) and Rep. Debbie Dingell (D-Mich.) introduced H.R. 5081, the Telehealth Modernization Act, bipartisan legislation to establish permanency for telehealth access. NABH continues to push for telehealth permanency and advocates for H.R. 4619, the Medicare Mental Health Inpatient Equity Act, which would eliminate Medicare’s 190-day lifetime limit for inpatient psychiatric hospital services.
 
Meanwhile, Congress’ regular appropriations process continues as congressional leaders address a stop-gap funding measure. A $108 billion funding bill for the U.S. Health and Human Services Department advanced in the House Appropriations Committee by a 35-28 party-line vote on Sept. 10. The bill cuts the agency by 6%, more than $25 billion shy of the reduction President Trump requested.
 
The Trump administration requested more than $20 billion for the Administration for a Healthy America, a proposed unit that would consolidate several HHS agencies, which the bill does not fund. The full Senate Appropriations Committee passed a $116 billion HHS bill in July, which includes a $446 million increase in discretionary funds compared with the current fiscal year. Both the House HHS bill and the Senate HHS bill now await floor votes in both chambers and a Conference Committee to resolve any differences.

NABH Sends Comments to CMS on Agency’s 2026 Physician Fee Schedule Proposed Rule

NABH on Sept. 11 sent a letter to the Centers for Medicare & Medicaid Services (CMS) supporting several policy proposals affecting behavioral healthcare providers that the agency included in its 2026 Physician Fee Schedule rule.
 
In our letter to CMS Administrator Mehmet Oz, M.D., NABH applauded efforts to promote primary and behavioral healthcare integration among Advanced Primary Care Management (APCM) services. While we support CMS’ clarification that Digital Mental Health Treatment (DMHT) codes finalized in CY 2025 can be used for ADHD treatments and all FDA-cleared tools, we noted concern about establishing coding and payment for a broader set of services using digital tools that do not require FDA regulatory oversight.

We also supported the rule’s proposal to include marriage and family therapists and mental health counselors as practitioners who can bill Medicare directly for Community Health Integration and Principal Illness Navigation services.

Finally, NABH expressed support for CMS’ proposal to make permanent certain telehealth flexibilities, including removing frequency limitations for subsequent inpatient visits and adopting a definition of direct supervision to include virtual presence via appropriate audio/video real-time communications technology.

NABH Urges CMS to Ensure the Rural Health Transformation Program Funding Includes Behavioral Healthcare Providers

NABH sent a letter to CMS Administrator Oz, M.D. this week requesting that CMS’ Rural Health Transformation (RHT) Program prioritize a key part of the rural health infrastructure: inpatient and outpatient programs that provide mental health and substance use services.
 
As we posted in last week’s CEO Update, CMS released information about the RHT Program, for which H.R. 1 (OBBBA), has provided $50 billion to be allocated to states over the next five fiscal years starting in 2026. In both H.R. 1 and the RHT Program guidance, Congress and CMS have rightly identified infrastructure and technology investments as necessary for maintaining rural healthcare systems and identified mental health and substance use programs in rural areas as eligible rural healthcare providers.

Because the HITECH Act omitted behavioral healthcare providers from eligibility for the incentives physical healthcare providers received for electronic health record (EHR) system adoption, NABH members are not at parity with physical healthcare providers in their HIT infrastructure.

In our letter, we urge CMS to clarify to states in the RHT Program funding notice and additional guidance that inpatient psychiatric hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, and Opioid Treatment Programs are allowable sub-recipients of RHT Program funds.
 
“If CMS and states exclude behavioral health providers from the RHT Program, we fear the disparities in infrastructure and technology between physical healthcare and behavioral healthcare delivery systems in rural areas will be further exacerbated,” our letter noted.
Click here to learn more about CMS’ RHT program.

Livestream Available for Rural Health Transformation Planning Summit on Sept. 30

Interested NABH members can participate virtually in a Rural Health Transformation Planning Summit at the Watergate Hotel in Washington, D.C. on Tuesday, Sept. 30.
 
The one-day event will convene state and federal officials with organizations investing in new and better ways to reach Americans in rural areas with high-quality healthcare.
 
A host of companies will sponsor and support the summit or provide state grants, including ATI Advisory, Bamboo Health, Barr-Campbell Family Foundation, BioIntelliSense, Epic, Guidehouse, homeward, Horne, Magellan Health, maximus, McKinsey & Company, Philips, Rural Health Innovators, surescripts, Trualta, welldoc.
 
Click here for the livestream registration.

NABH Comments on MAHA Strategy & Report in ‘Behavioral Health Business’

NABH President and CEO Shawn Coughlin was quoted this week in a Behavioral Health Business story about the Trump administration’s Make America Healthy Again (MAHA) Commission’s Make Our Children Healthy Strategy to implement its earlier-released report.
 
Coughlin noted NABH will continue to review the strategy and join our partner organizations in urging the Trump administration to inform every action with thoroughly researched scientific evidence from psychiatrists and other behavioral healthcare practitioners.
 
“We also emphasize that when comparing our practices with practices in other countries,” Coughlin’s statement continued, “differences in prevalence in no way make overdiagnosis and overtreatment ‘empirically evident.’”

SAMHSA and CMS Release State Health Official Letter on Best Practices for Implementing the Continuum of Crisis Services

The Substance Abuse and Mental Health Services Administration (SAMHSA) and CMS’ Center for Medicaid and CHIP Services (CMCS) this week issued guidance to states about the crisis services continuum and how states may support implementing this continuum through Medicaid and CHIP.
 
The letter to state health officials describes specific Medicaid and CHIP authorities and flexibilities to support the full continuum of crisis-response services and suggests strategies for measuring and monitoring crisis response. The letter references SAMHSA’s recently published National Guidelines for a Behavioral Health Coordinated System of Crisis Care.
 
SAMHSA and CMS encourage states to take advantage of Medicaid and CHIP flexibilities for ensuring individuals who are in crisis have access to inpatient, residential, or intensive outpatient services. The letter includes specific financing flexibilities, fee-for-service and managed care considerations, payment strategies, and best practices for measuring and monitoring utilization and outcomes.

SAMHSA and CMS Release State Health Official Letter on Best Practices for Implementing the Continuum of Crisis Service

CMCS released a letter Sept. 9 detailing OBBBA’s provisions directing CMS to reduce the total Medicaid payment rate limit for state-directed payments (SDPs) for four services: inpatient hospital services, outpatient hospital services, nursing facility services, or qualified practitioner services at academic medical centers.
 
CMS published this letter to aid state-planning efforts and noted it will release a notice of proposed rulemaking (NPRM) with more specific directions. As part of the NPRM, CMS is considering changes to the total payment rate limit for SDPs for other services beyond the four services that OBBBA mandates.  
 
The letter provides an overview of Section 71116 of the OBBBA, which requires the total Medicaid payment rate for any SDP for those four services to 100% of the specified total published Medicare payment rate for expansion states or 110% of the Medicare payment rate for non-expansion states. OBBBA included a provision temporarily grandfathering certain SDPs until the rating period beginning on or after Jan. 1, 2028. CMS offered a preliminary interpretation of this provision in its letter.

Study Finds 41% Lower Risk of Death for People Who Receive Contingency Management

A study published this week in the American Journal of Psychiatry found that among veterans with stimulant use disorder, those who received contingency management (CM) were 41% less likely to die within one year than those who did not – a statistic similar to the lower chance of death associated with taking buprenorphine for opioid use disorder.
 
This is the first study to assess the relationship between CM and mortality, and the findings underscore the potential for CM to greatly enhance the outcomes of people with stimulant use disorder.
 
“Our data confirm that wide-scale access to CM for individuals with [stimulant use disorder] can save lives, both reducing all-cause mortality and preventing over­dose deaths,” the authors noted. “This is particularly important given that these findings are from real-world clinical care as opposed to clin­ical trials focused on efficacy, lending support to the asser­tion that wide-scale uptake of CM across health systems and states could potentially help reduce deaths.”

MACPAC to Webcast Public Meeting Next Week

The Medicaid and CHIP Payment and Access Commission (MACPAC) will webcast its two-day meeting next week.
 
MACPAC will host its meeting on Thursday, Sept. 18 from 9:30 a.m. to 4:30 p.m. ET and on Friday, Sept. 19 from 9:30 a.m. until Noon ET.

Click here to register.

Fact of the Week

State lawmakers this week sent Gov. Gavin Newsom (D-Calif.) a bill that would block artificial intelligence chatbots from representing themselves as medical professionals, Politico and other news outlets reported.

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