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Author: Meghan Barrett

CEO Update 211

NABH Launches ‘Safe Connections’ to Promote Awareness About Youth Mental Health

NABH on Thursday launched Safe Connections, a campaign intended to educate policymakers, parents, and the public about the effects of social media on our nation’s youth and to provide tools and resources to help keep kids safe online.
 
The NABH Youth Services Committee, under the direction of Committee Chair Jameson Norton, M.B.A., FACHE, chief operating officer at Newport Healthcare, oversaw the campaign’s vision and purpose, and Donald Grant, Ph.D., with Newport Healthcare, helped developed the campaign’s resources.
 
Please visit our Youth Services landing page to access our first two resources: Youth Social Media Use and Mental Health and Misinformation, Malinformation, Disinformation, and Fake News. The page also includes the American Psychological Association’s recent recommendations about healthy teen video viewing that Don Grant also helped to develop.
 
NABH will promote the campaign’s resources on X and LinkedIn and will update the Youth Services page to include social media messages for you and your teams to share.
 
Please be sure to look for new resources in the future, starting with two fact sheets about cyberaggression that NABH will release in January.

NABH 2025 Board Election Ballots Due Tuesday, Dec. 31!

On Dec. 16, NABH e-mailed system members an attachment with NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2025 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 Tuesday, Dec. 31, 2024.
 
Please note your ballot is not valid without a signature. New Board members and the Board Chair-elect will take office in January 2025.

Government Shutdown Likely as Lawmakers Fail to Reach Agreement 

The fate of a Continuing Resolution (CR) to fund the government remains uncertain as House and Senate leaders continue to fall short on reaching a spending bill agreement while the deadline looms.
 
The original CR would have funded the government through March 14, 2025 and included a one-year farm bill extension, $100 billion in disaster relief, $30 billion in disaster and economic assistance for farmers, and, most critical for NABH members, the renewal of expiring healthcare programs and a robust package of healthcare policies.
 
Both the House and Senate must pass a bill to fund the federal government past the deadline of 12:01 a.m. on Saturday before it heads to the White House for President Biden’s signature. As of this writing, lawmakers haven’t charted a path forward; however, it appears likely they will vote on a “straight CR,” dropping most, if not all, of the additional funding measures, including healthcare extenders.
 
Lawmakers had agreed to extend through 2026 pandemic-era telehealth rules, a 2.5% payment boost for physicians in Medicare, a one-year delay of cuts to disproportionate-share hospitals, and an extension for five years of the opioid-fighting SUPPORT Act, which expired more than a year ago. Policymakers did not include the Modernizing Opioid Treatment Access Act (MOTAA) in this package.
 
It is unclear what healthcare provisions will be included in another CR, and remaining provisions would have to be addressed in the 119th Congress.
 
NABH has urged Members of Congress to pass the current CR, fully reauthorize the SUPPORT Act, and extend critical telehealth flexibilities that are set to expire.
 
In other year-end congressional developments, the House Veterans Affairs Subcommittee on Health held a legislative hearing to review numerous bills, most of which dealt with the shortfall in veterans’ access to care and specifically the Veterans’ Affairs Department’s (VA) efforts to limit access to care, including behavioral healthcare through the Community Care Program, established with passage of the Mission Act of 2018.
 
VA Committee Chairman Mike Bost (R-Ill.) spoke in favor of his recently introduced legislation,
H.R. 10267 Complete the Mission Act of 2024, which would safeguard (VA) community-based healthcare access by codifying current access standards and would require VA to publish their wait times for all VA medical centers, setting a baseline expectation for timeliness of care. The bill would also establish a defined access standard for the provision of residential substance use treatment, recognizing that time is of the essence when a veteran in an addiction crisis decides help is needed.
 
NABH president & CEO Shawn Coughlin submitted a statement for the record as part of the committee’s proceedings. “We share our members’ growing concern that Veterans Affairs (VA) gatekeepers have presented barriers to veterans receiving the appropriate level of behavioral healthcare services within the amount of time the Mission Act of 2018 promises them,” Coughlin said. “As we understand, veterans who need residential treatment services have faced wait times for services that far exceed the 28-day limit for specialty care, making them eligible to seek community care services. Even then, however, veterans face wait times for behavioral healthcare services that average about two weeks, according to the Government Accountability Office. America’s veterans did not wait to serve our country. We should not make them wait for the behavioral healthcare services they need.”
 
Chairman Bost intends to reintroduce the Complete the Mission Act in the 119th Congress, where both the House and Senate VA Committees will renew scrutiny over the VA’s Community Care System.
 
Meanwhile in the Senate, S. 1351, the Stop Institutional Child Abuse Act, led by Sens. Jeff Merkley (D-Ore.) and John Cornyn (R-Texas) passed in both the Senate HELP Committee and in the full Senate by Unanimous Consent on Dec, 11. The House passed the bill by a vote of 373 – 33 and it now heads to the President Biden’s desk.
 
Introduced in April 2023, the legislation is also known as the “The Paris Hilton Bill” because of the activist’s advocacy on the legislation that will purportedly increase transparency in youth residential treatment facilities. The original bill would have established a federal work group on Youth Residential Programs to improve the dissemination and implementation of best practices regarding health and safety, but it was amended to direct the National Academy of Sciences (NAS) to issue a report no later than three years after the bill’s enactment and every two years after for a period of 10 years to support the development and implementation of education and training resources for professional and paraprofessional personnel in the fields of healthcare, law enforcement, judiciary, social work, child protection, education, child care, and other relevant fields.
 
Finally, the Kids Online Safety Act (KOSA) made it close to the finish line but will not pass before this Congress adjourns after being derailed by big tech companies. KOSA would have required social media companies to remove product features doctors believe harm kids’ health.
 
The Senate passed the bill after several redrafts by sponsors to accommodate First Amendment concerns raised by opponents. In September, the House Energy and Commerce Committee advanced a weak version of the bill; however, it was never scheduled for consideration on the House floor. The U.S. Surgeon General and attorneys general in 35 states, as well as physician groups, including the American Academy of Pediatrics and the American Psychological Association, have all called on Congress to pass KOSA. House Speaker Mike Johnson (R-La.) has promised to address kids’ online safety in the new term.

Call for Behavioral Healthcare Clinicians to Help Develop IPF Patient Assessment Instrument

CMS and its contractor Abt Global are recruiting psychiatrists, psychologists, nurses and other behavioral healthcare clinicians to help develop and test a draft patient assessment tool known as the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).
 
CMS’ primary objectives for this significant policymaking process are to improve both quality of care and payment accuracy. Eventually, the agency plans to require that a common PAI be used during admission and discharge of every IPF patient.

NABH has confirmed with CMS that our members will have multiple opportunities to weigh in on this project. We strongly urge your participation in the alpha stage, during which Abt will identify the PAI data elements to field-test – a critical stage that requires real-world input from our field. 

To join the alpha stage of IPF PAI development, please apply here by Dec. 30, 2024.

SAMHSA Releases Toolkit Before First SUD Treatment Month

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released a toolkit for the first Substance Use Disorder Treatment Month to be observed in January 2025.
 
Substance Use Disorder Treatment Month raises awareness of the benefits and availability of evidence-based treatments for people with a substance use disorder; addresses barriers to treatment, including stigma; and normalizes seeking help.

The toolkit includes information about weekly themes, social media graphics and messaging, a webinar background, and resources that public health organizations, treatment providers, professional associations, and others can use to spread awareness of Substance Use Treatment Month.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

At the population level, pregnant and parenting adolescents of all genders are at a greater risk than adults for mental health problems during and after the perinatal period,  according to a recent study in the journal Health Affairs. The American Academy of Pediatrics recommends that pediatricians screen adolescent mothers and fathers for depression and high stress levels as part of routine well-child care. 

Happy Holidays from NABH!

NABH will not publish CEO Update on the next two Fridays and will resume on Friday, Jan 10. 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.

CEO Update 210

NABH Welcomes Dan Schwartz as New Director of Quality and Addiction Services

NABH is pleased to welcome Dan Schwartz as the association’s new director of quality and addiction services, effective this past Monday, Dec 9.
 
Dan brings to NABH a range of experiences in federal agencies related to addiction services, including most recently in his role as a senior behavioral health policy analyst in the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services (HHS). 
 
In that role, Dan engaged in federal policymaking efforts by providing subject matter expertise about the delivery, financing, and regulation of behavioral health services, with an emphasis on the substance use disorder care continuum, controlled substances, and various mental health topics.
 
Dan also served as the staff lead for the HHS Workgroup on Implementation Strategies for Contingency Management; co-led a workgroup that supported developing legislative proposals related to behavioral health; and was a lead analyst for developing and implementing the HHS Overdose Prevention Strategy.
 
“We are excited to have Dan join our team,” said NABH President and CEO Shawn Coughlin. “He brings energy, experience, and enthusiasm to a critical role in our association.”
 
Prior to working at ASPE, Dan worked at the White House Office of National Drug Control Policy and the Substance Abuse and Mental Health Services Administration.
 
Dan earned a master’s degree in public health from Johns Hopkins University, where he was a Bloomberg Fellow in Addiction & Overdose, and a bachelor’s degree in public health from George Washington University.

ADAW Includes NABH Statement About OTPs in Article Responding to Recent NYT Story

The upcoming edition of the publication Alcohol and Drug Abuse Weekly (ADAW) includes a statement NABH posted to its website last weekend in response to a story in The New York Times (NYT) on Dec. 7 that did not provide a full and fair description of opioid treatment programs (OTPs).
 
“OTP facilities play a vital role in addressing the nation’s opioid and addiction crises, and it is imperative that we continue to support providers who do this important work so people in need can immediately access the personalized care, treatment options, and ongoing support services they need to achieve long-term recovery,” NABH said in its statement, which the association sent to members in an NABH Alert on Monday, Dec. 9.
 
ADAW also included responses and statements from The New York Times, NABH member Acadia Healthcare, and the National Association of Addiction Treatment Providers in its latest issue.

NABH and Other Groups Urge CMS to Strengthen MHPAEA Requirements in Medicaid & CHIP

NABH is one of 67 organizations that sent a recent letter to the Centers for Medicare & Medicaid Services (CMS) recommending ways the agency can strengthen the Mental Health Parity and Addiction Equity Act’s (MHPAEA) Medicaid and Children’s Health Insurance Program’s (CHIP) requirements.
 
The seven-page letter urges CMS to implement a host of measures, such as aligning the Medicaid MHPAEA regulations with those in private insurance and adopting the six-step comparative analysis framework for these templates (codified in the Consolidated Appropriations Act of 2021); strengthening enforcement provisions of MHPAEA in Medicaid and CHIP; amending the templates to require separate analysis and reporting of mental health and substance use disorder; and requiring the collection and evaluation of relevant outcome data to assess MHPAEA compliance in operation.
 
“We would encourage CMS to, at a minimum, post summary documents of these analyses in plain language so Medicaid enrollees and their authorized representatives can get meaningful information about whether and how their plan is in compliance with MHPAEA,” the letter concluded. “These summaries should be accompanied by additional instructions for consumers on how they can get claims processed or reprocessed when a violation has been identified, and how they can enforce their rights if they believe they have been subject to discrimination.”

Call for Behavioral Healthcare Clinicians to Help Develop IPF Patient Assessment Instrument

CMS and its contractor Abt Global are recruiting psychiatrists, psychologists, nurses and other behavioral healthcare clinicians to help develop and test a draft patient assessment tool known as the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).
 
CMS’ primary objectives for this significant policymaking process are to improve both quality of care and payment accuracy. Eventually, the agency plans to require that a common PAI be used during admission and discharge of every IPF patient.

NABH has confirmed with CMS that our members will have multiple opportunities to weigh in on this project. We strongly urge your participation in the alpha stage, during which Abt will identify the PAI data elements to field-test – a critical stage that requires real-world input from our field. 

To join the alpha stage of IPF PAI development, please apply here by Dec. 30, 2024.

NIMH to Host Webinar on Youth Suicidal Behaviors on Monday, Dec. 16

The National Institute of Mental Health (NIMH) will host an hourlong webinar about youth suicidal behaviors this Monday, Dec. 16 starting at 2 p.m. ET.
 
NIMH Acting Director Shelli Avenevoli, Ph.D., and researcher Arielle H. Sheftall, Ph.D. will examine current trends, risk factors, and protective strategies in youth mental health. The two presenters will also highlight research advancements that can shape future efforts to reduce suicide rates among young people in the United States.
 
Click here to register.

Pew Article Highlights How to Reduce Methadone Access Roadblocks in Pharmacies

The Pew Research Center published an article last week outlining federal and state policy changes that could facilitate access to methadone for opioid use disorder in pharmacies by streamlining legal and regulatory requirements to operate Opioid Treatment Program (OTP) medication units.
 
The recommended policy changes focus on approval processes; methadone ordering and storage; and inventory, recordkeeping, and reporting systems.
 
The article was based on a report by the Legislative Analysis and Public Policy Association that analyzes current state and federal laws and regulations that affect access to methadone in pharmacies, with specific consideration of three models for pharmacy-based methadone access: (1) a medication unit in a pharmacy, (2) a mobile medication unit near a pharmacy, and (3) methadone being prescribed by a clinician and dispensed at a pharmacy.

HHS Publishes Report on Wait Time Standards for Behavioral Health Network Adequacy

HHS released a report last week that examined how regulators implemented behavioral healthcare appointment wait time (WT) standards as part of insurance network oversight.
 
The report identified existing wait time standards used in federal and various state programs, including how they are defined, measured, reported, and enforced. Experts interviewed for the project emphasized the importance of using wait time standards to help ensure network adequacy of behavioral health services and acknowledged that further work is needed to refine and interpret standards and properly factor in telehealth and patient preferences.
 
“Regulators interviewed at times have imposed penalties on health plans found to be non-compliant with WT standards,” the report concluded. “However, they prefer to work with health plans to develop corrective action plans and find other strategies to address access gaps, viewing collaborative approaches as more productive than imposing penalties, which could exacerbate access problems for consumers,” it continued. “Regulators also recognize that provider shortages make it harder for health plans to recruit providers to their networks.”

Call for Presenters: NABH to Kick Off AI Webinar Series in 2025

NABH is seeking presenters who have integrated AI in their business operations to share their experiences in the association’s new webinar series about AI in behavioral healthcare scheduled for Spring 2025.
 
The first webinar will focus on using AI to reduce administrative burden and create efficiencies, and the second webinar will highlight using AI for clinical-decision support.

Please contact NABH Associate Manager for Congressional Affairs Emily Wilkins at Emily@nabh.org by close of business this coming Monday, Dec. 16 if you want to participate.   

ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

NABH recently hosted a webinar about using hospital data effectively in your negotiations with health plans.

The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. Please click here for the webinar’s recording and here for the presentation slides.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Deaths involving carfentanil increased sharply to an average of 34.4 a month between July 2023 and June 2024 from an average of 3.3 a month between January 2021 and June 2023, according to a recent report from the Centers for Disease Control and Prevention.

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

Dan Schwartz Joins NABH as Director of Quality and Addiction Services

WASHINGTON, Dec. 10, 2024 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) is pleased to welcome Dan Schwartz as the association’s director of quality and addiction services.

Dan brings to NABH a range of experiences in federal agencies related to addiction services, including most recently in his role as a senior behavioral health policy analyst in the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services (HHS). 

In that role, Dan engaged in federal policymaking efforts by providing subject matter expertise about the delivery, financing, and regulation of behavioral health services, with an emphasis on the substance use disorder care continuum, controlled substances, and various mental health topics.

Dan also served as the staff lead for the HHS Workgroup on Implementation Strategies for Contingency Management; co-led a workgroup that supported developing legislative proposals related to behavioral health; and was a lead analyst for developing and implementing the HHS Overdose Prevention Strategy.

“We are excited to have Dan join our team,” said NABH President and CEO Shawn Coughlin. “He brings energy, experience, and enthusiasm to a critical role in our association.”

Prior to working at ASPE, Dan worked at the White House Office of National Drug Control Policy and the Substance Abuse and Mental Health Services Administration.

Dan earned a master’s degree in public health from Johns Hopkins University, where he was a Bloomberg Fellow in Addiction & Overdose, and a bachelor’s degree in public health from George Washington University.

About NABH
The National Association for Behavioral Healthcare (NABH) represents provider systems that treat children, adolescents, adults, and older adults with mental health and substance use disorders in inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, medication assisted treatment centers, specialty outpatient behavioral healthcare programs, and recovery support services in 49 states and Washington, D.C. The association was founded in 1933.

SOURCE National Association for Behavioral Healthcare

CEO Update 209

NABH Expresses Serious Concerns About MOTAA in Letter to House and Senate Leaders

NABH this week sent a letter to House and Senate leaders that reinforced the association’s concerns that the Modernizing Opioid Treatment Access Act (MOTAA) [S. 644/ H.R. 1359] is a misguided attempt to deregulate opioid treatment programs (OTPs), the effective standard of treatment for opioid use disorders (OUDs).
 
In our letter, NABH highlighted three areas of potential, unintended consequences and harms that may result from legislation proposing such abrupt and expansive regulatory changes: the risk of diversion and increases in overdose deaths, the risk of relying on community pharmacies to fill the gap in patient access to care, and the potential for significant harm to populations that already suffer from health inequities.
 
“In addition to the noted dangers, the wholesale regulatory change that would result from this legislation would be difficult to implement,” the letter said. “Other organizations share this practical concern, including law enforcement leaders who note that the proposed changes in MOTAA would lead to more overdose deaths and diversion of methadone…”
 
NABH suggested a more cautious approach to addressing concerns about access to methadone, such as pausing to study carefully the effects of the significant recent efforts to expand access, with a specific focus on understanding the root causes behind incremental of OUD-related overdoses as well as the disproportionate harm suffered by marginalized populations; and encouraging new models of care whereby OTPs can collaborate with local pharmacies to allow stable patients and patients living in rural settings to pick up their OTP-prescribed methadone outside of OTPs.

SAMHSA Releases OTP Guidelines that Align with Regulations Released This Year

The Substance Abuse and Mental Health Services Administration (SAMHSA) on Wednesday released Federal Guidelines for Opioid Treatment Programs to provide recommendations and best practices for OTPs related to the implementation and compliance of regulatory changes in 42 CFR Part 8 that became effective in April and for which OTPs were required to comply starting on Oct. 2, 2024.
 
The revised regulations took steps to increase access to evidence-based medications for opioid use disorder, or MOUD, and promote practitioner discretion; support patient-centered care; reduce barriers to treatment; and remove stigmatizing or outdated language from the 2001 regulations.
 
The newly released guidelines replace guidelines published in 2015.

Call for Behavioral Healthcare Clinicians to Help Develop IPF Patient Assessment Instrument

The Centers for Medicare & Medicaid Services (CMS) and its contractor Abt Global are recruiting psychiatrists, psychologists, nurses and other behavioral healthcare clinicians to help develop and test a draft patient assessment tool known as the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).
 
CMS’ primary objectives for this significant policymaking process to improve both quality of care and payment accuracy. Eventually, the agency plans to require that a common PAI be used during admission and discharge of every IPF patient.

NABH has confirmed with CMS that our members will have multiple opportunities to weigh in on this project. We strongly urge your participation in the alpha stage, during which Abt will identify the PAI data elements to field-test – a critical stage that requires real-world input from our field. 

To join the alpha stage of IPF PAI development, please apply here by Dec. 30, 2024.

SAMHSA Issue Brief Offers Information on Co-Occurring Mental Health and Substance Use

SAMHSA has released an issue brief for State Mental Health Authorities (SMHA) about co-occurring mental health and substance use disorders (CODs).
 
The document highlights the commonality of CODs and negative outcomes in the absence of evidence-based integrated care. It also provides an overview of treatment barriers and potential solutions and the effectiveness of integrated care.

Call for Presenters: NABH to Kick Off AI Webinar Series in 2025

NABH is seeking presenters who have integrated AI in their business operations to share their experiences in the association’s new webinar series about AI in behavioral healthcare scheduled for Spring 2025.
 
The first webinar will focus on using AI to reduce administrative burden and create efficiencies, and the second webinar will highlight using AI for clinical-decision support.

Please contact NABH Associate Manager for Congressional Affairs Emily Wilkins at Emily@nabh.org by close of business on Monday, Dec. 16 if you want to participate.

ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

NABH recently hosted a webinar about using hospital data effectively in your negotiations with health plans.

The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. Please click here for the webinar’s recording and here for the presentation slides.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

A study published in Health Affairs this month found that in 2021, 42.8% of U.S. children ages 5-17 lived with an adult who had at least four adverse childhood experiences (ACEs). The report noted that childhood exposure to adult ACEs was correlated negatively with child mental health, particularly among children living in low-income and publicly insured families.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 208

DEA Extends Authority for Telehealth Prescribing Without an In-person Visit a Third Time

The Drug Enforcement Administration (DEA) and HHS this week again temporarily extended the existing telemedicine flexibilities for the prescribing of controlled medications through Dec. 31, 2025.

This latest extension allows prescribing practitioners to prescribe controlled medications without first conducting an in-person evaluation of the patient. This third extension of this flexibility – which was introduced in January 2020 in response to the COVID-19 pandemic – follows the first extension in May 2023 and the second in August 2023.

Among the agencies’ primary objectives for these extensions is to ensure a smooth transition for patients and practitioners who have relied on telemedicine for controlled-medication prescriptions, as well as to preserve access for those who may need this flexibility before a more permanent policy is established.

NABH and other stakeholders continue to wait for DEA and HHS to finalize two proposed rules issued in March 2023: Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have Not Had a Prior In-Person Medical Evaluation and the Expansion of Induction of Buprenorphine via Telemedicine Encounter.

NABH’s comments on these rules were among the 38,000 comments that stakeholders sent to the federal agencies.  

APA Releases Recommendations for Healthy Teen Video Viewing

The American Psychological Association (APA) this week issued its first set of recommendations to help parents, policymakers, and tech companies empower teens to manage their viewing habits.

The APA Recommendations for Healthy Teen Video Viewing summarizes scientific research on adolescents’ viewing habits to offer guidance to parents, youth, and educators, as well as recommendations to policymakers and technical industry professionals for substantial changes.

“Research consistently shows that video content, and the platforms that host it, have the potential to help or harm teens,” APA CEO Arthur C. Evans Jr., Ph.D., said in an announcement about the recommendations. “It is the shared responsibility of video platforms, content creators, parents, caregivers, educators, policymakers and the technology industry to create an environment where youth can learn and express themselves safely online.”

The report calls for tech companies to change the built-in features of their platforms that can affect adolescent well-being because the APA notes platforms that recommend content to youth and switch rapidly between short-form videos and autoplay videos to extend viewing times could magnify the effects of harmful video content and contribute to maladaptive viewing habits in youth.

In addition, the report recommends limiting exposure to content that encourages violent or risky behaviors and/or reinforces negative stereotypes, especially on platforms that allow users to share content or add comments or “likes” that may endorse harmful behaviors; guiding adolescents to choose content based on quality and accuracy, especially when evaluating health related information by creators who are not licensed health professionals; teaching adolescents about false, damaging or biased information and other risks introduced by content generated by artificial intelligence (AI); encouraging access to video content that promotes empathy, learning, emotional well-being and joy; and encouraging video skills that allow adolescents to develop healthy relationship skills.

Your Expertise is Needed to Help Develop IPF Patient Assessment Instrument

The Centers for Medicare & Medicaid Services (CMS) is recruiting participants to help the agency, its contractors RTI International and Abt Global, and other partners develop and test a draft patient assessment instrument, or the Inpatient Psychiatric Facility Patient Assessment Instrument (IPF-PAI).

NABH urges all members to assist CMS and participate in this important project that aims to advance care quality in IPFs. Your feedback will help inform CMS’ efforts in the agency’s rulemaking process.

Please click here to learn more and here to apply.

Call for Presenters: NABH to Kick Off AI Webinar Series in 2025

NABH is seeking presenters who have integrated AI in their business operations to share their experiences in the association’s new webinar series about AI in behavioral healthcare scheduled for Spring 2025.

The first webinar will focus on using AI to reduce administrative burden and create efficiencies, and the second webinar will highlight using AI for clinical-decision support.

Please contact NABH Associate Manager for Congressional Affairs Emily Wilkins at Emily@nabh.org by close of business on Monday, Dec. 16 if you are interested in participating.

ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

NABH on Nov. 14 hosted a webinar about using hospital data effectively in your negotiations with health plans.

The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. Please click here for the webinar’s recording and here for the presentation slides.

Please Visit Our New Website!

NABH’s website is live!  NABH has designed our updated site to help members, policymakers, journalists, patient advocates, and the general public learn about our association and the resources we provide in a way that is easier to navigate so you find what you’re looking for quickly and efficiently.

We have also updated our member password, which is required for member-only resources, such as our letters to congressional offices and regulatory agencies, as well as previous editions of CEO Update (all of which can be found by clicking on the “News” tab. NABH members should refer to the NABH Alert they received on Thursday, Oct. 31 for the new member password.

Please e-mail nabh@nabh.org with any questions or feedback you may have about the new site.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   

We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.

Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.

To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

The University of South Florida will track young people through 2050 to learn more about the long-term effects of smartphones, social media, and other digital media on individual wellbeing.

Happy Thanksgiving!

The NABH staff wishes its members and their families a very happy, healthy, and safe Thanksgiving! NABH will not publish CEO Update next week and will resume on Friday, Dec. 6, 2024.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 207

SAMHSA Announces Behavioral Health Workforce Career Navigator

The Substance Abuse and Mental Health Services Administration this week launched the
Behavioral Health Workforce Career Navigator to help current and aspiring behavioral health professionals identify state requirements for a range of behavioral health careers.
 
“We need a behavioral health workforce that can meet our country’s needs. That includes helping current and aspiring behavioral health workers pursue their careers and thrive in their work,” HHS Secretary Xavier Becerra said in an announcement. “The new Behavioral Health Workforce Career Navigator is an important tool towards improving the process of finding and comparing education, training, and licensure and certification requirements across the country. President Biden and Vice President Harris’ Unity Agenda continues to take on the biggest challenges facing Americans, including addressing our nation’s behavioral health needs.”
 
HHS will host a webinar about the new resource today, Friday, Nov. 15 at 3 p.m. ET. Click here to register.
 
If you haven’t yet, please be sure to check out the NABH Education and Research Foundation’s Workforce Startup Guide and share it with members of your human resources and operations teams.

Trump Chooses RFK, Jr. to Lead HHS While Senate GOP Leadership Takes Shape

President-elect Donald Trump on Thursday named environmental lawyer and activist Robert F. Kennedy, Jr., son of the late Sen. Robert F. Kennedy, as the nation’s next HHS secretary.
 
Kennedy, a widely known vaccine skeptic, will require Senate confirmation to lead the department that oversees agencies including the Centers for Disease Control and Prevention, the Centers for Medicare & Medicaid Services, the Food and Drug Administration, and the National Institutes of Health.
 
“The safety and health of all Americans is the most important role of any administration, and HHS will play a big role in helping ensure that everybody will be protected from harmful chemicals, pollutants, pesticides, pharmaceutical products, and food additives that have contributed to the overwhelming health crisis in this country,” Trump wrote Thursday in a post on the social media platform X.
 
Meanwhile, in the Senate, Sen. John Thune (R-S.D.) was elected by his peers to serve as majority leader to lead the Republican Caucus and control the Senate’s legislative agenda. Thune succeeds Sen. Mitch McConnell (R-Ky.) after McConnell decided to step down from the position while remaining in the Senate until the end of his term. Thune was elected to the Senate in 2005, ousting then-Majority Leader Tom Daschle (D-S.D.). A leader in the Senate Finance Committee, Thune has been a strong proponent for repealing the IMD exclusion.
 
Sen. Bill Cassidy, M.D. (R-La.) and Sen. Mike Crapo (R-Idaho) are positioned to chair the Senate HELP and Finance Committees, respectively, following the Republican victory on Nov. 5 that flipped Senate control to the GOP from Democrats. Cassidy is a policy-focused gastroenterologist. As ranking member of the Senate HELP Committee, Cassidy focused on pharmacy benefit manager reform and on site-neutral payment policy, among other issues. He has been a proponent of increasing access to behavioral healthcare services and voted in favor of S. 644, the Modernizing Opioid Treatment Access Act (MOTAA) in committee last December. Cassidy has heard the concerns over MOTAA from NABH and NABH member companies and allied groups and has appeared interested in working towards a mutually agreeable outcome. It is unknown currently to what extent he will prioritize the issue.
 
Both chairmen are expected to advocate for limited government and market-driven strategies to cut healthcare costs and work closely with President-elect Trump to implement his administration’s priorities, which could include allowing enhanced Affordable Care Act (ACA) subsidies to expire and promoting policies that chip away at the ACA and Medicaid. The chairmen will also have to advance a slew of Trump administration health nominees.
 
With the GOP gaining control of both chambers of Congress, lawmakers may use Reconciliation – a complex process allowing bill passage with a simple majority vote — to push through priority legislation.
 
Sen. Bernie Sanders (I-Vt.) is likely to remain as the HELP Committee’s ranking member. The incoming majority party will have two seats to fill, while the incoming minority party will have one vacancy.
 
With Crapo’s ascension, Sen. Ron Wyden (D-Ore.) will become the Senate Finance Committee’s ranking member. Democrats will have six seats to fill due to the retirement of Sens. Stabenow (D-Mich.), Carper (D-Del.), and Cardin (D-Md.) and the defeats of Sens. Brown (D-Ohio), and Casey (D-Pa.) and resignation of Menendez (D-N.J.)
 
The House of Representatives will choose its committee chairmen and ranking members in December.

Future of the Kids Online Safety Act is Uncertain as 118th Congress Wraps Up

The outlook for the Kids Online Safety Act (KOSA) is uncertain despite the Senate approving the legislation in a 91-3 vote this past July.
 
Introduced shortly after Surgeon General Vivek Murthy, M.D. released his advisory on social media and youth mental health, the bill aims to protect children from the harm social media causes to youth mental, physical, and emotional health by requiring social media companies to protect children’s privacy, prevent targeted advertising, and block manipulative algorithms to users 17 and younger.
 
The House Energy and Commerce Committee approved the bill on Sept. 18 and the measure is seen as a priority for outgoing House Energy and Commerce Chair Cathy McMorris Rodgers (R-Wash.); however, leaders including House Speaker Mike Johnson (R-La.) and Majority Leader Steve Scalise (R-La.) find the “platform duty-of-care” requirements and potential for censorship problematic. 

Amended to mitigate the concerns about the duty-of-care language and the provision that would require tech companies to remove features that encourage compulsive use, the bill advanced through the committee process and has just a few weeks to become law before the 118th Congress ends.

Some youth and parent advocacy groups are concerned that the House version lacks the strength of the Senate version. Referring to the House version of the bill, Zamaan Qureshi, co-chair of the youth-led coalition Design It For Us, said “…In essence (it) removed the ability to target some of the design features that have preyed on my generation, preyed on young people,” according to Roll Call. Some parent advocacy groups said they hope Sen. Marsha Blackburn (R-Tenn.) and other Senate leaders will encourage House counterparts to pass the legislation.

If the bill does not pass during this Congress, it will need to be introduced in the 119th Congress.

Please Visit Our New Website!

NABH’s website is live!  NABH has designed our updated site to help members, policymakers, journalists, patient advocates, and the general public learn about our association and the resources we provide in a way that is easier to navigate so you find what you’re looking for quickly and efficiently.
 
We have also updated our member password, which is required for member-only resources, such as our letters to congressional offices and regulatory agencies, as well as previous editions of CEO Update (all of which can be found by clicking on the “News” tab. NABH members should refer to the NABH Alert they received on Thursday, Oct. 31 for the new member password.

Please e-mail nabh@nabh.org with any questions or feedback you may have about the new site. 

ICYMI: NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

NABH on Thursday hosted a webinar about using hospital data effectively in your negotiations with health plans.

The webinar featured Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare.

Please click here for the webinar’s recording and here for the presentation slides.

Reminder: Manatt to Host Webinar About State Medicaid Innovations to Address America’s Behavioral Health Crisis

Research firm Manatt will host a webinar with state leaders to address topics such as 1115 demonstrations, strategies to combine Medicaid with other sources of funding, and what policies states are implementing to address the nation’s behavioral health crisis.
 
The hourlong webinar will start at 3 p.m. ET on Thursday, Nov. 21. Click here to register.

Please Submit Data to NABH’s Denial-of-Care Portal

We urge all NABH members to join those already submitting data to our Denial-of-Care Portal.   
 
We are beginning to use aggregated portal data to illustrate and compare prior authorization practices for commercial, Medicare Advantage, and Medicaid managed care denials.
 
Policymakers have expressed particular interest in our aggregate estimate on days of uncompensated charity care, as well as the length of delayed health plan responses to prior-authorization requests.
 
To support this advocacy push, we strongly encourage all NABH members to submit data to the portal. Please contact NABH Associate Manager for Congressional Affair Emily Wilkins with questions about the data metrics that we are collecting and/or the data-submission process.

Fact of the Week

Rates of hospitalizations and ED visits related to mental health exceeded expected rates in only the second year after the pandemic onset (6% and 5%, respectively), whereas those related to self-harm persistently increased above expected rates after the pandemic onset (28% and 43% in the third year, respectively), according to a recent study in JAMA Network Open.  

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

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DOL Official Timothy Hauser to Headline NABH Annual Meeting Day #2

NABH is pleased to announce Timothy D. Hauser, deputy assistant secretary for program operations at the U.S. Labor Department’s (DOL) Employee Benefits Security Administration (EBSA), will kick off our Annual Meeting’s second day on Tuesday, May 14 at 10 a.m. Hauser, who serves as EBSA’s chief operating officer, will discuss parity and be prepared to answer questions from attendees. Hauser joined DOL in 1991 as a trial attorney for the Plan Benefits Security Division (PBSD), where he represented the department in federal district court and appellate litigation. From November 2000 until November 2013, Hauser was the associate solicitor of the division. As the head of PBSD, Hauser was responsible for all of DOL’s legal work under ERISA. Before joining DOL, Hauser worked as a trial attorney for six years at Legal Aid of Western Missouri. He graduated from Harvard Law School in 1985 and earned his undergraduate degree at the University of Illinois. You can learn more about this year’s speakers and view our preliminary program on NABH’s Annual Meeting homepage. And please be sure to register for the Annual Meeting if you haven’t yet.   We look forward to seeing you in Washington!

Remember to Register for Hill Day 2024!

Please register for Hill Day 2024 on Tuesday, May 14 and urge members of your team to join you!   Hill Day is an excellent opportunity to meet one-on-one with legislators to discuss the issues that matter most to behavioral healthcare providers.   After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent you or your facility footprint. Closer to the day of the meeting, we will send you a meeting schedule, materials, and talking points to guide your conversations with Members of Congress and their staff. Please indicate in your Annual Meeting registration form that you are interested in Hill Day and be sure to include all the states where your system has a footprint. If you have an existing relationship with a legislator, please let us know!

SAMHSA’s Recent Grant Funding Opportunities Limit Financial Incentives for Contingency Management

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released funding opportunity notices for State Opioid Response and Tribal Opioid Response grants that limit financial incentives for contingency management to $75 per budget period. While the grants require implementing evidence-based practices, the funding limitation is contrary to what is known to be an evidence-based incentive amount that produces behavior change. This amount is inconsistent with what the Contingency Management Policy and Practice Group (CMPG) – known formerly as the Motivational Incentive Policy Group and of which NABH is a member – has advised the federal government. “This is a squandered opportunity to implement a highly effective treatment for stimulant use disorder, which is fueling almost half of our nation’s overdoses,” said NABH Director of Quality and Addiction Services Sarah Wattenberg, who serves as NABH’s CMPG representative. “If we can’t get a handle on stimulant use, we won’t see the overdose rate go down,” Wattenberg said before she cautioned providers against using $75 for incentives because they haven’t proven effective. The grant applications are due July 1, 2024.

Reminder: Please Complete Federal BHIT Data Standards Survey by May 12

Advocating for parity in behavioral health information technology (BHIT) is one of NABH’s top advocacy priorities. That’s why we strongly urge our members’ information technology, medical record documentation, and coding leaders to complete a federal survey by May 12 that will help create standardized behavioral health data elements. NABH alerted members about the survey from SAMHSA and the Office of the National Coordinator for Health Information Technology (ONC) in CEO Update earlier this year. Part of SAMHSA and ONC’s joint BHIT initiative, the survey presents more than 150 potential data elements for consideration, including many clinical elements, as well as provides a platform for survey respondents to submit alternative elements for evaluation. Ultimately, HHS expects to incorporate the final data metrics into the Center for Medicare and Medicaid Innovation’s eight-year project with eight states to develop alternative payment models and quality measures to advance integrated BH and physical healthcare services, including a Medicare per-member-per-month risk-adjusted payment, and a complementary Medicaid payment model and statewide IT approach. To participate in the survey, respondents must first create a user account using the log in feature in the top right of the USCDI+ Platform page. See the USCDI+ User Guides for help creating an account, navigating datasets, and submitting new data elements or comments. Learn more from this federal resource page, or e-mail USCDI.Plus@hhs.gov for further assistance.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

The American Psychological Association recently released a report that calls on social media companies to take responsibility to help protect youth mental health.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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Please Help Us Welcome Deputy National Coordinator for Health IT Steven Posnack on May 13!

NABH is pleased to welcome Deputy National Coordinator for Health Information Technology Steven Posnack, M.S., M.H.S., as our first 2024 Annual Meeting presenter on Monday, May 13 at 2:45 p.m. ET in the Salamander hotel’s Grand Ballroom. Posnack advises the national coordinator, executes the Office of the National Coordinator for Health Information Technology’s (ONC) mission, and represents ONC’s interests at a national and international level. Together with the national coordinator, Posnack also oversees ONC’s federal coordination, regulatory policy, public-private initiatives, and the overall implementation of statutory authorities and requirements, including those from the 21st Century Cures Act and HITECH Act. He will discuss behavioral health information technology at our Annual Meeting. Also, please join us for Monday’s workforce panel on Monday, May 13 at 4 p.m. This year’s panel of NABH members and workforce consultants will highlight NABH member best practices to recruit and retain talent as well as how to establish partnerships and “grow your own” programs to address your workforce needs. Please click here to learn about our panelists and other Annual Meeting speakers. And be sure to register for the meeting, reserve your hotel room, and view our preliminary program if you haven’t yet.   We look forward to seeing you in Washington!

Biden Administration Releases First National Strategy for Suicide Prevention

The Biden administration this week released the 2024 National Strategy for Suicide Prevention and accompanying federal action plan to combat America’s deadly mental health and overdose crises. The National Strategy was the result of a combined effort among the Substance Abuse and Mental Health Services Administration, the Centers for Disease Control and Prevention, the National Action Alliance for Suicide Prevention, and more than 20 agencies across 10 federal departments. The National Strategy maps out recommendations for addressing gaps and meeting the needs of at-risk populations, while the federal action plan identifies 200 discrete actions to be initiated and evaluated over the next three years. Actions include identifying ways to address substance use and suicide risk together in the clinical setting; funding a mobile crisis locator for use by 988 crisis centers; increasing support for survivors of suicide loss and others whose lives have been affected by suicide; and evaluating promising community-based suicide prevention strategies. The Biden administration said it will monitor and evaluate these strategies regularly to determine progress and success, and to further identify barriers to successful suicide prevention.

CMS Releases Final Rule on Medicare Managed Care Transparency and Accountability

NABH is pleased with the Centers for Medicare & Medicaid Services’ (CMS) final rule on transparency and accountability for Medicaid managed care plans that the agency released this week. Nearly a year after issuing its proposed rule – and facing firm opposition from healthcare insurance stakeholders – CMS released a rule with provisions that NABH strongly supports, including maximum appointment wait time standards aligned with commercial insurance, including a 10-day wait time standard for outpatient mental health and substance use disorder services. The rule also requires independent annual secret shopper surveys that assess appointment timeliness standards and provider director accuracy. And in an important move toward price transparency, health plans will be required to share their actual expenditures and revenues for state-directed payments and to report any identified or recovered overpayments to states within 30 days. Given the rule’s complex rollout schedule, CMS issued a detailed chart showing the staggered implementation plan for the rule, with effective dates ranging from immediate implementation to four years after its release. Additional information is available in the agency’s fact sheet.

NABH Comments to CMS About Agency’s Accrediting Organization Oversight Rule

NABH recently sent a comment letter to CMS about a proposed rule intended to improve and make more consistent the agency’s oversight of accrediting organizations (AO). NABH supports the rule’s overall direction, which is to improve the accountability and transparency of AO survey and accreditation activities. Of the nine AOs this rule would affect, The Joint Commission is the one of most interest to NABH members. “NABH appreciates that the proposed rule recognizes the current disparity of survey findings among The Joint Commission (and other AOs) and state survey agencies,” NABH wrote in our letter. “Such disparities raise red flags about the misaligned criteria, as well as the reliability of relevant surveyor training programs and preparedness of individual surveyors,” the letter continued. “Current inadequacies have resulted in inconsistent, and therefore at least partially inaccurate, survey findings. This entire process warrants closer examination by CMS of the overall scope and details of these inconsistencies – and the public sharing of related findings with stakeholders.”

NABH Opposes FTC’s Final Rule Banning Non-Compete Agreements

NABH staunchly opposes this week’s final rule banning noncompetes from the Federal Trade Commission (FTC) that the agency said it expects will generate new businesses, raise worker wages, and boost innovation. The FTC estimates that the final rule will lead to new business formation growing by 2.7% per year, resulting in more than 8,500 additional new businesses created each year. The FTC also expects the final will result in higher earnings for workers, with estimated earnings increasing for the average worker by an additional $524 per year; as well as lower healthcare costs by up to $194 billion over the next decade. The U.S. Chamber of Commerce and other business groups filed suit to stop the FTC from banning noncompetes, arguing the FTC doesn’t have the authority to prohibit companies from limiting their employees’ ability to work for competitors.   NABH weighed in on the proposed rule a year ago and acknowledged the FTC’s other efforts to address issues of genuine, unequal bargaining power between certain employers and certain types of workers. However, we opposed the proposed rule for several reasons. “First, the rule proposes an overly simplified, one-size-fits-all approach for all employees across all industries,” NABH said in our March 2023 comment letter. “From a behavioral healthcare perspective, the proposed rule would profoundly alter the healthcare labor market – particularly for physicians and senior hospital executives – by instantly invalidating millions of dollars of existing contracts,” the letter continued. “The rule would affect the full array of NABH members’ employees, including those who are highly trained and lower skilled; as well as both highly compensated and lower-wage employees.”

The Joint Commission Announces New Telehealth Accreditation Program

The Joint Commission this week announced its new Telehealth Accreditation Program for eligible hospitals, ambulatory, and behavioral healthcare organizations. Effective July 1, 2024, the program’s requirements contain many of the standards similar to other Joint Commission accreditation programs, such as requirements for information management, leadership, medication management, patient identification, documentation, and credentialing and privileging. Some requirements specific to the new telehealth program include:
  • Streamlined emergency management requirements to address providing care and clinical support remotely rather than in a physical building.
  • New standards for telehealth provider education and patient education about the use of telehealth platforms and devices.
  • New standards chapter focused on equipment, devices, and connectivity.
The Joint Commission’s announcement noted telehealth use increased by 154% during the COVID-19 pandemic’s early years before stabilizing and presently remaining at levels 38 times higher than they were in 2019.

NABH Telehealth Survey is Due Tuesday, April 30

NABH is eager to learn how your system uses telehealth services in its operations. Please remember to complete this brief survey by Tuesday, April 30, 2024.    Your responses will help guide our advocacy efforts. We also urge you to share this survey with IT colleagues who have insight into how your facilities use telehealth to support your patients. Please email NABH Executive Vice President for Government Relations and Public Policy Rochelle Archuleta if you have questions.

Reminder: The National Academies to Explore Mental Health Services for Anxiety & Mood Disorders in Women

The National Academies Forum on Mental Health and Substance Use Disorder will host a hybrid public workshop in Washington, D.C. and via webcast to explore mental health care services related to anxiety and mood disorders in women on April 29 and 30. Sponsored by the Health Resources and Services Administration, the workshop will examine currently available evidence to identify, define, and prepare strategies for the provision of essential healthcare services related to anxiety and mood disorders in women across the life course. Presentations will also describe health disparities, healthcare finances, and policies related to the quality and access of mental healthcare services available for women.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Researchers have created an AI model that can identify accurately women at risk of child-birth related PTSD, Science Daily reports. The study notes early intervention is critical to prevent progression of a disorder that could carry serious health consequences for as many as 8 million women a year globally.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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RTI Study Shows Pervasive Disparities in Access to In-Network Behavioral Healthcare 

A report this week from not-for-profit research institute RTI International adds to mounting research showing a lack of access to affordable mental health and substance use disorder treatment in the United States continues. NABH helped sponsor the study, Behavioral Health Parity—Pervasive Disparities in Access to In-Network Care Continue, which found that patients went out-of-network 3.5 times more often to see a behavioral health clinician than a medical/surgical clinician, 8.9 times more often to see a psychiatrist, 10.6 times more often to see a psychologist, 6.2 times more often for acute behavioral inpatient care, and 19.9 times more often for sub-acute behavioral inpatient care. “It’s upsetting, though not surprising, that RTI researchers found what we’ve seen for too long: patients who need critical behavioral healthcare services are forced to seek that care out-of-network much more than they do for medical-surgical services because of inadequate insurer networks. This comes at higher personal costs to these patients,” NABH President and CEO Shawn Coughlin said in a statement. “Worsening the problem, behavioral healthcare providers are reimbursed at much lower rates than their peers in medical/surgical facilities. The Mental Health Parity and Addiction Equity Act passed more than 15 years ago,” he continued. “It’s time lawmakers and regulators ensure this critical law is implemented fairly and fully nationwide.” The study also found that in-network office visit reimbursement, which health plans use to encourage provider in-network participation, was higher for medical/surgical clinicians than office visits with behavioral clinicians: 22% higher on average; 48% higher at the 75th percentile; and 70% higher at the 95th percentile. Notably, physician assistants were reimbursed for office visits at an average amount 19% higher than psychiatrists and 23% higher than psychologists.

In Case You Missed It: Watch Our Foundation’s Talent-Recruitment, Part II Webinar

The NABH Education and Research Foundation hosted the second in its two-part webinar series about talent recruitment and retention on Thursday, April 18. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers University Behavioral Health Care, and senior vice president of the Behavioral Health and Addictions Service Line at RWJBarnabas Health, co-led the webinar with workforce consultants Beth Kuhn of Stonegate Strategies and John Pallasch of One Workforce Solutions. The presenters discussed long-term solutions to recruiting and retaining talent through partnerships; how skills-based hiring is a more effective approach to talent management; and what funding sources are available to help NABH members in their workforce-related efforts.   If you missed it, please click here for the webinar’s recording, here for the presentation slides, and here for the poll question results. And be sure to join us for our Annual Meeting Workforce Panel on Monday, May 13 from 4 – 5 p.m. ET in the Salamander Washington DC’s Grand Ballroom. NABH Education and Research Foundation Vice President Jim Shaheen, CEO of New Season, will moderate the panel, which will include this week’s webinar presenters Kuhn and Pallasch, as well Jason Brooks, senior vice president of Human Resources at New Season, and Rhonda Ashley-Dixon, vice president of strategic partnership and engagement at Vanderbilt Behavioral Health.

Please Meet Our Exhibitors and Sponsors at the 2024 NABH Annual Meeting Next Month!

NABH appreciates the generous support of our exhibitors and sponsors, whose valuable 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 May 13-15 at the Salamander Washington, DC. Before then, you can view a list of our exhibitors and sponsors on our Annual Meeting homepage. Also, please register for the Annual Meeting, reserve your hotel room, and view our preliminary program, if you haven’t done so yet. We look forward to seeing you in Washington!

FTC Brings Case Against Monument to Enforce Health Data Privacy Protections

The Federal Trade Commission for the first time took enforcement action through the Opioid Addiction Recovery Fraud Prevention Act (OARFPA) to stop telehealth company Monument from disclosing health data to advertising platforms by bringing a case against the company, which treats patients with alcohol addiction virtually, Inside Health Policy reports The story also noted that Monument’s data-sharing practices also violated section 5 of the FTC Act, resulting in a proposed ban on data sharing with third parties and a $2.5 million civil penalty, FTC says. Enacted in 2018, OARFPA authorizes FTC to seek civil penalties for unfair or deceptive acts or practices related to substance use disorder treatment services or products.

Center for Health Strategies Examines Medicaid Options to Cover Incarcerated Youth

The Center for Health Care Strategies, together with the Annie E. Casey Foundation, has developed a policy cheat sheet outlining requirements that will expand Medicaid options to cover services for incarcerated youth starting in 2025.   Several provisions under the Consolidated Appropriations Act of 2023 will expand Medicaid services to youth who are incarcerated, of which nearly two-thirds have a diagnosable mental health or substance use disorder, according to the Medicaid Payment and CHIP Access Commission, or MACPAC. The fact sheet outlines the new requirements, opportunities for Medicaid to collaborate with the corrections sector, and next step for Medicaid agencies before the provisions take effect.

Reminder: The National Academies to Explore Mental Health Services for Anxiety & Mood Disorders in Women

The National Academies Forum on Mental Health and Substance Use Disorder will host a hybrid public workshop in Washington, D.C. and via webcast to explore mental health care services related to anxiety and mood disorders in women on April 29 and 30. Sponsored by the Health Resources and Services Administration, the workshop will examine currently available evidence to identify, define, and prepare strategies for the provision of essential healthcare services related to anxiety and mood disorders in women across the life course. Presentations will also describe health disparities, healthcare finances, and policies related to the quality and access of mental healthcare services available for women.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Among U.S. college athletes, suicide is now the second leading cause of death after accidents—and  rates have doubled to 15.3% from 7.6% in the past 20 years, according to a study published in the British Journal of Sports Medicine. CNN analyzed the report’s findings in a recent article. For questions or comments about this CEO Update, please contact Jessica Zigmond.

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NABH Remembers Unit Committee Member Anthony Santucci, M.S.

NABH remembers with grateful appreciation Anthony Santucci, M.S., 50, of BayCare Behavioral Health, who died unexpectedly on March 25. Anthony served as BayCare’s director of nursing for 13 years and was an active and energetic member of NABH’s Behavioral Health Services within General Healthcare Systems Committee – known as the Unit Committee – for many years. Born and raised in South Jersey, Anthony earned his nursing degree at Wesley College in Delaware and continued his education at Jacksonville and Walden Universities, ultimately earning a Master of Science degree in nursing in 2016. Anthony was also a 2020 graduate of the Tampa Bay Chamber’s Leadership Tampa, an intensive executive leadership program, and was a devoted member of the Tampa Bay behavioral health community for more than 25 years. Anthony is survived by Jaclyn Santucci, his wife of 20 years, and their daughter Josephine Cecilia. Anthony will be missed by all who knew him. In lieu of flowers, donations can be made in Anthony’s memory to Feeding Tampa Bay or to the Pinellas County Hunter Association, a horseback riding association, via Zelle at 123pcha@gmail.com.

Register Today for Part II of Our Foundation’s Talent-Recruitment Webinar Series on April 18

Please join us and register today for the NABH Education and Research Foundation’s second webinar about recruiting and retaining talent next Thursday, April 18 from 2 p.m. – 3 p.m. ET. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will co-lead this free, interactive webinar with workforce consultants Beth Kuhn of Stonegate Strategies and John Pallasch of One Workforce Solutions. Kuhn has more than 30 years of workforce experience and served previously as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. Pallasch has spent more than 20 years influencing organizational personnel, efficiency, and productivity in the public and private sectors and served previously as the assistant secretary for employment and training at the U.S. Labor Department. Together they will discuss establishing and developing partnerships to “grow your own” within your systems; explore funding opportunities to help support your workforce efforts; and urge you to focus more on skill sets and less on job responsibilities among your staff. Please share the registration link with your Human Resources, Operations, and Workforce Engagement teams!

The 2024 NABH Annual Meeting Hotel Cutoff Date is Now Sunday, April 28

The Salamander Washington, DC has extended its cutoff date for NABH 2024 Annual Meeting room reservations through Sunday, April 28. Please reserve your hotel room today and be sure to register for our Annual Meeting (May 13-15), if you have not done so yet. We look forward to seeing you in Washington!

House and Senate Committees Examine Behavioral Healthcare Policies in Hearings

House and Senate Committees returned from the Easter recess and reviewed several pending behavioral healthcare policies this week. In a hearing on Wednesday, April 10, the House Energy & Commerce Committee Health Subcommittee explored ways to support patients’ access to telehealth as lawmakers determine how best to extend digital health flexibilities in effect through Dec. 31. Lawmakers will need to decide whether to pursue a temporary or permanent extension of pandemic-era telehealth policies. Extending telehealth coverage beyond 2024 is expected to be costly, and if implemented in a budget neutral manner, would reduce funds available for other Medicare programs. Committee members said best practices on digital billing codes, policies that prevent overuse of telehealth services and limit fraud, and CMS’ ability to capture and report telehealth data are integral pieces for them to determine whether telehealth provisions will be extended permanently by year’s end. Lawmakers also expressed concerns that changes to virtual care policy will not hinder access to in-person care. Wednesday’s hearing announcement included a list of 15 telehealth bills that would extend or make permanent telehealth provisions. Two bills specific to behavioral healthcare include H.R. 3432, Rep. Doris Matsui’s (D-Calif.) Telemental Health Care Access Act, which eliminates certain restrictions relating to Medicare coverage of mental health services that are provided through telehealth; and H.R. 7858, the Telehealth Enhancement for Mental Health Act of 2024 from Reps. John James (R-Mich.), Don Davis (D-N.C), and David Schweikert (R-Ariz.), which would establish a Medicare “incident to” modifier for tele-mental health services. Lawmakers remain divided over whether to extend audio-only telehealth. Representatives who serve rural and underserved communities say audio-only telehealth may be the only way their constituents can experience virtual care. The ultimate collection of provisions – either temporary or permanent – will likely be included in a larger healthcare package expected to be taken up in a lame-duck session. The Senate Finance Health Subcommittee convened a roundtable to discuss opportunities to improve substance use disorder (SUD) treatments within federal health programs. Witnesses described how measures such as treatment prior authorization, low physician reimbursement rates, and inadequate funding perpetuate treatment barriers for individuals living with SUD. Both Democrats and Republican lawmakers expressed support for increasing access to care through peer support specialists, increased reimbursement rates, comprehensive care, and certified community behavioral health clinics (CCBHCs). Additional discussion items included the importance of a continuum of care and opportunities to reduce SUD stigma. One panelist highlighted increasing the availability of methadone treatment options, and several senators reiterated support for S. 644, the Modernization Opioid Treatment Access Act. Committee leaders indicated they will hold an official hearing about increasing access to SUD treatment in the future.

The National Academies to Explore Mental Health Services for Anxiety & Mood Disorders in Women

The National Academies Forum on Mental Health and Substance Use Disorder will host a hybrid public workshop in Washington, D.C. and via webcast to explore mental health care services related to anxiety and mood disorders in women on April 29 and 30. Sponsored by the Health Resources and Services Administration, the workshop will examine currently available evidence to identify, define, and prepare strategies for essential healthcare services related to anxiety and mood disorders in women across the life course. Presentations will also describe health disparities, healthcare finances, and policies related to the quality and access of mental healthcare services available for women.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

A new JAMA study shows probabilities of parents having anxiety-related visits (10.6% versus 7.0%), depression-related visits (8.4% versus 6.1%), and any mental health-related visits (18.1% versus 13.3%) were higher in families of children with cancer versus  children without cancer. The authors said the findings underline the importance of multi-level interventions – such as providing MH screening, counseling, and timely support and ensuring comprehensive insurance coverage and paid medical leave – to better meet the mental-health needs of these parents. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 180

Please Join Us for Our Annual Meeting Workforce Panel on Tuesday, May 14!

Building on last year’s success, the NABH Education and Research Foundation will host a panel discussion featuring NABH members and workforce consultants during the 2024 Annual Meeting on Monday, May 13 from 4 p.m. – 5 p.m. ET. This year’s panel will focus on NABH member best workforce practices, workforce development boards, apprenticeships, fellowships, and other “grow your own” programs. It will feature the following panelists: Jason Brooks, Senior Vice President of Human Resources, New Season Rhonda Ashley-Dixon, Vice President, Strategic Partnerships & Engagement, Vanderbilt Behavioral Health Beth Kuhn, Principal, Stonegate Strategies and former Commissioner, Kentucky Department of Workforce Investment John Pallasch, Founder and CEO, One Workforce Solutions and former U.S. Assistant Secretary for Employment and Training, U.S. Labor Department The Foundation urges NABH members to attend the session and engage with panelists during the question-and-answer period. Also, please remember to register for the Annual Meeting and reserve your hotel room if you haven’t done so yet. We look forward to seeing you in Washington!

Learn About Long-term Solutions in the Fight for Talent!

Please join us for the NABH Education and Research Foundation’s second in its two-part webinar series about recruiting and retaining talent on Thursday, April 18 from 2 p.m. – 3 p.m.   NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P., who serves as president and CEO of Rutgers University Behavioral Health Care and senior vice president of the Behavioral Health and Addictions Service Line at RWJBarnabas Health, will co-lead this interactive webinar with workforce consultants Beth Kuhn of Stonegate Strategies and John Pallasch of One Workforce Solutions. Kuhn has more than 30 years of workforce experience and served previously as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. Pallasch has spent more than 20 years influencing organizational personnel, efficiency, and productivity in the public and private sectors and served previously as the assistant secretary for employment and training at the U.S. Labor Department.   Together they will present practical approaches to attracting and keeping top talent, such as developing partnerships and offering apprenticeship programs. Participants will come away with some applicable next steps to employ in their own systems to set the foundation for long-term solutions. Please click here to register and be sure to alert your members of your Human Resources, Operations, and Workforce Engagement teams to attend!

NABH Comments to Federal Agencies About Proposed BHIT Data Standards

NABH on March 29 submitted comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Office of the National Coordinator for Health Information Technology (ONC) on their joint effort to create official data standards for behavioral health information technology (IT). In addition to the association sending a comment letter, NABH members concurrently responded to the related online survey about potential behavioral health data items. As we know, behavioral healthcare providers were not eligible recipients of the HITECH Act of 2009 funding, and, as such, most IT vendors did not develop viable BHIT systems or tools at that time or since. More than 15 years after HITECH became law, our country needs a federal investment in BHIT to help our field align with the IT capacity of the rest of the continuum of healthcare providers. Our comments emphasized that a significant portion of our membership lacks an IT system compliant with the ONC standards set in 2015. As a result, many in our field face reduced efficiency and more administrative burden. We also noted that on the policy front, the ongoing use of outdated IT reduces the field’s ability to engage in recent policy initiatives that require modern interoperability. NABH recommended that the new behavioral health language include data metrics for behavioral health populations that tend to be overlooked by behavioral health IT system modules, such as for patients experiencing suicidality or the potential of harm to self or others; substance use disorder patients; patients in intensive outpatient programs or partial hospitalization programs; and adolescent and youth populations. Our letter also recommended social determinants of health to include in the new standards. In addition, we urged the initiative to consider data terms related to the emerging use of artificial intelligence within behavioral healthcare settings. Because this is a top priority of NABH, we urged SAMHSA and ONC to work closely with providers and other stakeholders on this long-awaited investment. This collaboration is of highest importance because it is expected that the data standards that emerge from this project will be used in future standards for BH electronic medical records.

NABH Weighs in On Physical Holds for Children and Youth in Joint Commission Letter

In a letter to The Joint Commission (TJC) this week, NABH noted that The Joint Commission’s proposal to modify standards on the use of physical holds for children and youth would affect NABH-member group homes, foster care, non-hospital residential treatment programs, and perhaps others – many of which are accredited by the Council on Accreditation. The Joint Commission’s proposed change would combine the current physical holding standards for children and youth with existing standards for restraints and seclusions for all individuals served. Because the brief proposal lacks a clear rationale, NABH’s letter outlined several key elements that stakeholders need before responding to the proposal. Specifically, we asked for a comprehensive policy justification and evidence, impact estimate, and explanation of any link between this proposal and efforts to combat workplace violence. NABH also requested a meeting with The Joint Commission to learn more about the proposal.

Reminder: U.S. Labor Department Seeks Information in Parity Enforcement Survey

The U.S. Labor Department is conducting an 11-question survey to better understand stakeholder views about the department’s federal parity law oversight and enforcement efforts. In particular, the survey focuses on compliance enforcement for non-quantitative treatment limitations, which include prior authorization protocols, network adequacy standards, and timeliness requirements. Click here to complete the survey, which opened on Wednesday, March 27 and closes on Wednesday, April 10.

Reminder: Please Submit Data to NABH’s Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

A new telehealth study focused on patients with Alcohol Use Disorder showed some groups were less likely to receive any video telehealth than telephone visits, suggesting that multiple treatment modalities should remain available to ensure treatment access. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 179

CMS Proposes IPF PPS Reforms and FY 2025 Increase of 2.6%

The Centers for Medicare & Medicaid Services (CMS) on Thursday proposed a net update of 2.6 percentage points for fiscal year (FY) 2025 payment levels relative to FY 2024 levels for hospitals and units reimbursed under the inpatient psychiatric facility prospective payment system (IPF PPS). The update moderately varies by provider types, with a 2.2% increase for urban, freestanding for-profit providers, and a 2.4% increase for urban, freestanding not-for-profit hospitals, as well as for urban, for-profit and not-for-profit units. The IPF PPS rule also proposed budget-neutral adjustments to the Medicare severity diagnosis related groupd (DRG), which are payment categories that reflect a patient’s principal diagnosis, selected comorbidities, patient age, and the variable per diem adjustments. The proposed changes also include:
  • Maintaining the current 17 DRGs.
  • In response to the growing volume of these cases, CMS proposes to make these two current DRGs eligible for payment add-ons: DRGs 917 (Poisoning and toxic effects of drugs w MCC) and 918 (Poisoning and toxic effects of drugs w/out MCC). See Table 4 in the rule for more details.
  • Replacing DRGs 080 (Nontraumatic stupor & coma w MCC) and 081 (Nontraumatic stupor & coma w/o MCC) with DRGs 947 (Signs and Symptoms w MCC) and 948 (Signs and Symptoms w/out MCC), because volume in these current DRGs have decreased significantly and CMS said the proposed replacement DRGs are a more appropriate fit. See Table 3 in the rule for more details.
Regarding comorbidity payment add-ons, in an overall budget-neutral manner, CMS proposes multiple changes to these payment adjustment rates, as outlined in Table 8 in the rule. To maintain this payment system’s 2.0% outlier pool, CMS proposed to increase the fixed dollar loss threshold to $35,590 from $33,470, which will result in fewer cases qualifying for outlier payments. The rule also proposes to increase payments for electroconvulsive therapy to $660.30 in FY 2025 from the current rate of $385.58. Due to these adjustments, the base per diem was reduced to $874.93 from $895.63 (a 2.3% reduction) to ensure that overall payments remained budget neutral.  And our analysis will further explain this reduction and its overall financial impact to the industry. In addition, under the congressional mandate from the Consolidated Appropriations Act, 2023, the rule includes two requests for information (RFI) on potential future IPF PPS reforms. For the first RFI, CMS revisits and builds upon its 2022 technical report by flagging several potential future reforms to the current adjustments for rural IPFs, teaching IPFs, and “safety-net” IPFs. The second RFI in the rule proposes to develop a standardized IPF patient assessment instrument, which will be designed to implement in 2028. Please see the agency’s fact sheet for additional information about the proposed rule. Public comments are due by Tuesday, May 28. Also, please join NABH via Zoom on Tuesday, April 16 from 2 p.m. – 3 p.m. ET, when we’ll discuss the rule in greater detail, as well as priority issues that NABH will address in the association’s official comment letter.

View the NABH 2024 Annual Meeting Preliminary Program!

Earlier this week NABH shared its 2024 Annual Meeting preliminary program with members and meeting registrants. Unless noted otherwise, meeting sessions are open to all Annual Meeting attendees. Please remember to register for the Annual Meeting and reserve your hotel room today if you haven’t done so yet. We look forward to seeing you in Washington!

Deadline to Advertise in the 2024 NABH Exhibitor and Sponsor Guide is Today, March 29!

NABH will distribute the 2024 NABH Exhibitor and Sponsor Guide to all registrants at the 2024 NABH Annual Meeting from May 13-15 at the Salamander Washington, DC. Be sure your organization is included in it!   All ads are due today, Friday, March 29, 2024. Please click here for details about advertising options, requirements, payment, and more. The association also will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage.

Register for Part II of Our Foundation’s Talent-Recruitment Webinar Series!

Please join us on Thursday, April 18 at 2 p.m. ET for Part II of the NABH Education and Research Foundation’s talent-recruitment webinar series, which will explore long-term solutions. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar along with Kuhn and workforce consultant John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department. This interactive webinar will explore how to develop partnerships for apprenticeships and other “grow your own” programs.   Please click here to register.

ICYMI: Watch Part I of Our Foundation’s Talent-Recruitment Webinar Series!

On March 26, our foundation hosted Part I of its two-part, talent-recruitment webinar series, which focused on short-term solutions. If you missed it, please click here for the webinar’s recording, here for the presentation slides, and here for the poll question results.

U.S. Labor Department Seeks Information in Parity Enforcement Survey

The U.S. Labor Department is conducting an 11-question survey to better understand stakeholder views about the department’s federal parity law oversight and enforcement efforts. In particular, the survey focuses on compliance enforcement for non-quantitative treatment limitations, which include prior authorization protocols, network adequacy standards, and timeliness requirements. Click here to complete the survey, which opened on Wednesday, March 27 and closes on Wednesday, April 10.

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Perinatal mood and anxiety disorder (PMAD) diagnoses among privately insured people nationwide increased by 93.3% from 2008 to 2020, growing faster in 2015–20 than in 2008–14, according to a new study published in Health Affairs. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 178

Congress Moves to Approve Final Spending Bill Before Government Shutdown Deadline

Congressional appropriators on Thursday unveiled legislative text for the final spending package for fiscal year 2024. The House will vote first on this six-bill “minibus,” which contains the appropriations bills for Labor-HHS-Education, Defense, Financial Services and General Government, Homeland Security, State-Foreign Operations, and Legislative Branch during a Friday session. The Senate is moving quickly to review the package before the federal funding deadline expires at midnight. Absent this “time agreement,” a brief weekend shutdown could be possible while the bill works its way to the president’s desk. Negotiations between House and Senate leadership broke down on another skinny health package. This deal would have included additional funding for community health centers, PBM reforms and price transparency provisions, as well as extensions for the Pandemic and All-Hazards Preparedness and Advancing Innovation Act (PAHPA) and the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment Act (SUPPORT). Lawmakers may consider these provisions during the congressional lame duck session after the elections. In the bill, HHS is set to receive an increase of $955 million above the current funding level to more than $117 billion. Behavioral healthcare funding includes more than $4.6 billion to support substance use prevention and treatment efforts to address the rising toll of opioid overdoses; $2 billion for the Substance Use Prevention, Treatment, and Recovery Services Block Grant; $1.575 billion for State Opioid Response grants; $145 million for the Rural Communities Opioid Response Program; and $1 billion for the Mental Health Block Grant. The bill also provides $153 million for the Behavioral Health Workforce Education and Training Program to support community-based clinical training and strengthen the mental health workforce through repayment of education loans for individuals working in either a Mental Health Professional Shortage Area or where the overdose death rate exceeds the national average. The package allocates $42 million to the Health Resources and Services Administration (HRSA) for the Office of the Advancement of Telehealth (OAT) for expenses, grants, contracts and “cooperative agreements for the advancement of telehealth activities; $1 million to connect rural veterans to health care facilities; and $20.9 million for rural hospitals to adopt health information technology.   The bill also provides an $18 million increase for the 988 Suicide Prevention Lifeline, building on the nearly $400 million increase in fiscal year 2023. The proposed boost comes after GOP leaders on the House Energy and Commerce Committee requested that the Government Accountability Office audit the Substance Abuse and Mental Health Services Administration’s (SAMHSA) oversight of funds to the lifeline, saying more than half of designated funding has gone unused.

Register Today for Next Week’s NABH Education and Research Foundation Workforce Webinar

There’s still time to register for the NABH Education and Research Foundation’s workforce webinar on Tuesday, March 26 from 2 p.m. – 3 p.m. ET. Next week’s webinar is the first in a two-part series that explores talent recruitment and retention. Foundation Vice President Jim Shaheen, CEO of New Season/Colonial Management Group, LP, Foundation Secretary Mary Pawlikowski, president at Vanderbilt Psychiatric Hospital and Clinics, and workforce consultant Beth Kuhn of Stonegate Strategies will lead participants in an interactive discussion to share their talent-recruitment and retention challenges, as well as their best, short-term strategies to address those problems. These practices include re-organizing recruitment teams to align with operations, developing alumni outreach initiatives, streamlining an organization’s onboarding process, conducting stay interviews, and more. Please join us and click here to register for Part I on March 26 at 2 p.m. ET! The second webinar in this series will examine longer-term solutions to recruiting talent – such as Registered Apprenticeship Programs, education and certification opportunities, fellowships, and more – on Thursday, April 18 at 2 p.m. ET. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar along with Kuhn and workforce consultant John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department.   Please join us and click here to register for Part II on April 18!

HHS Needs Your Feedback to Help Develop a Behavioral Healthcare Data Set

Through next Friday, March 29, HHS’ Office of the National Coordinator (ONC) – the federal agency that standardizes information technology requirements for healthcare providers – is collecting information about specific data elements to include in a new behavioral healthcare data set. NABH encourages you to help with this important project. The task is a joint effort between ONC and the Substance Abuse and Mental Health Services Administration (SAMHSA) to create the draft United States Core Data for Interoperability (USCDI) + BH to address core data and interoperability for behavioral health needs beyond the scope of the USCDI. In December 2023, ONC launched a new USCDI+ platform to support the organization, linking of domains, and functionality to solicit and receive feedback for all USCDI+ domains. HHS’ goal with this activity is to confirm the data points needed to improve and advance care continuity for patients who see behavioral healthcare providers and other healthcare providers. Survey respondents will identify the specific data metrics from among 187 options – such as the patient’s address, insurance information, clinical data points, and more – that HHS should collect, as well as items that HHS should not collect. Your expertise will help develop an eventual government-endorsed data set for the behavioral healthcare field and also influence a separate HHS effort to develop a future behavioral health information technology system.   Behavioral Health Information Technology, or BHIT, is one of NABH’s top advocacy priorities, so we strongly urge you and your teams’ health IT experts to complete ONC’s survey by no later than Friday, March 29. Meanwhile, NABH is working with its committees to prepare an association comment letter to ONC. Please contact Sarah Wattenberg with any questions.

White House Announces Challenge to Save Lives from Overdose

The Biden administration has announced The White House Challenge to Save Lives from Overdose, a nationwide call to action to stakeholders from all sectors to save lives by increasing training about and access to life-saving opioid overdose reversal medications. The White House urges organizations, philanthropists, local governments, and businesses large and small to participate in a variety of ways, such as training 100% of an organization’s employees on how and when to use an opioid reversal medication; ensure an opioid overdose reversal medication is in every first aid kit in worksites and schools; and purchase and distribute opioid overdose reversal medications to a certain number of employees. Click here to learn more about the challenge.

2024 Annual Meeting Hotel Reservation Cutoff Date is Approaching!

Please reserve your hotel room today at the Salamander Washington, DC for the 2024 NABH Annual Meeting from May 13-15, 2024! The Salamander, Washington DC’s reservation cutoff date is Sunday, April 14. And please remember to register for this year’s Annual Meeting, The Future of Behavioral Healthcare, if you haven’t done so yet. The Annual Meeting’s preliminary program will be available soon. We look forward to seeing you in Washington!

Advertise in the 2024 NABH Exhibitor and Sponsor Guide!

NABH will distribute the 2024 NABH Exhibitor and Sponsor Guide to all registrants at the 2024 NABH Annual Meeting from May 13-15 at the Salamander Washington, DC. Be sure your organization is included in it!   All ads are due by next Friday, March 29, 2024. Please click here for details about advertising options, requirements, payment, and more. The association also will send the guide to all NABH members after the meeting and post it on the NABH Annual Meeting webpage.

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

In Case You Missed It: NABH’s 2024 Advocacy Priorities

NABH has released its 2024 Advocacy Priorities, which we urge you to read and share with your Government Relations teams. Topping NABH’s priorities this year are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.

Fact of the Week

A recent JAMA study reported Delta 8-THC use prevalence is appreciable among U.S. adolescents and is higher in states without marijuana legalization or existing Delta 8-THC regulations. The study noted that prioritizing surveillance, policy, and public health efforts addressing adolescent Delta 8-THC use may be warranted.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 177

HHS Needs Your Feedback to Help Develop a Behavioral Healthcare Data Set

Through March 29, HHS’ Office of the National Coordinator (ONC) – the federal agency that standardizes information technology requirements for healthcare providers – is collecting information about specific data elements to include in a new behavioral healthcare data set. NABH encourages you to help with this important project. The task is a joint effort between ONC and the Substance Abuse and Mental Health Services Administration (SAMHSA) to create the draft United States Core Data for Interoperability (USCDI) + BH to address core data and interoperability for behavioral health needs beyond the scope of the USCDI. In December 2023, ONC launched a new USCDI+ platform to support the organization, linking of domains, and functionality to solicit and receive feedback for all USCDI+ domains. HHS’ goal with this activity is to confirm the data points needed to improve and advance care continuity for patients who see behavioral healthcare providers and other healthcare providers. Survey respondents will identify the specific data metrics from among 187 options – such as the patient’s address, insurance information, clinical data points, and more – that HHS should collect, as well as items that HHS should not collect. Your expertise will help develop an eventual government-endorsed data set for the behavioral healthcare field and also influence a separate HHS effort to develop a future behavioral health information technology system.   Behavioral Health Information Technology, or BHIT, is one of NABH’s top advocacy priorities, so we strongly urge you and your teams’ health IT experts to complete ONC’s survey by no later than Friday, March 29. Meanwhile, NABH is working with its committees to prepare an association comment letter to ONC. Please contact Rochelle Archuleta with any questions.

Register Today for the NABH Education and Research Foundation’s Talent-Recruitment Webinars

The NABH Education and Research Foundation will host a two-part webinar series about talent recruitment featuring NABH members and workforce experts in March and April. Part I –Talent Recruitment: Exploring Short-Term Solutions – on Tuesday, March 26 will feature Foundation Vice President Jim Shaheen, CEO of New Season/Colonial Management Group, LP; Foundation Secretary Mary Pawlikowski, president at Vanderbilt Psychiatric Hospital and Clinics; and workforce consultant Beth Kuhn of Stonegate Strategies. In this hourlong webinar, presenters will lead participants in an interactive discussion to share and discuss their talent-recruitment and retention challenges, as well as their best, short-term strategies to address those problems. These practices include re-organizing recruitment teams to align with operations, developing alumni outreach initiatives, streamlining an organization’s onboarding process, conducting stay interviews, and more. Please join us and click here to register for Part I on March 26 at 2 p.m. ET! The second webinar in this series will examine longer-term solutions to recruiting talent – such as Registered Apprenticeship Programs, education and certification opportunities, fellowships, and more – on Thursday, April 18 at 2 p.m. ET. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar along with Kuhn and workforce consultant John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department.   Please join us and click here to register for Part II on April 18!

President Biden’s Fiscal 2025 Budget Proposal Aims to Transform Behavioral Healthcare

President Biden this week unveiled his fiscal year (FY) 2025 budget proposal, which would provide considerable funding to achieve the Biden administration’s goal of transforming behavioral healthcare in America. Each year, the president’s budget proposal is most significant for sending a message about the administration’s priorities. President Biden’s FY 2025 proposal provides $1 billion to advance BHIT adoption and interoperability among providers. It also provides a combined total of $216 million for mental health programs, including $200 million from the Bipartisan Safer Communities Act, a 900% increase in program funding since 2021. The funds will help to increase the number of school-based counselors, psychologists, social workers, and other mental health professionals in K-12 schools. NABH is also pleased to see the president’s budget proposal seeks to strengthen parity by requiring all commercial market health plans to cover mental health and substance use disorder benefits; ensuring that plans have an adequate network of behavioral health providers; and improving the U.S. Labor Department’s (DOL) ability to enforce the law. The budget includes $275 million over 10 years to increase the DOL’s capacity to ensure that large group market health plans and issuers comply with mental health and substance use disorder requirements, and to act against plans and issuers that do not comply. The budget’s other behavioral healthcare provisions include: investing in strengthening the behavioral healthcare workforce, including integration into primary care settings; increasing funding for the Children’s Mental Health Initiative by $50 million; increasing funding for the State Opioid Response grant program, investing in a new technical assistance center to strengthen health providers’ understanding and treatment of substance use and women’s mental health; expanding the 988 Suicide and Crisis Lifeline, and more.

SAMHSA to Host Webinar Next Week on Assisted Outpatient Treatment Program for Individuals with Serious Mental Illness

SAMHSA will host a virtual webinar for prospective applicants interested in applying for the fiscal year 2024 Assisted Outpatient Treatment Program for Individuals with Serious Mental Illness (AOT). The webinar will provide an overview of SAMHSA’s late-February AOT funding opportunity and application requirements. Registration is not required for the webinar on Wednesday, March 20 from 2:30 – 4 p.m. ET.

Register Today for the 2024 NABH Annual Meeting

Please remember to register for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare and reserve your hotel room at the Salamander Washington, DC from May 13-15, 2024.   This year’s meeting will examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. We look forward to seeing you in Washington!

Join Us for Hill Day 2024

Please remember to sign up for Hill Day 2024 on Tuesday, May 14, the second day of this year’s Annual Meeting. Hill Day is an excellent opportunity to meet one-on-one with legislators to discuss the issues that matter most to behavioral healthcare providers. After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent you or your facility footprint. Closer to the day of the meeting, we will send you a meeting schedule, materials, and talking points to guide your conversations with Members of Congress and their staff. Please indicate in your Annual Meeting registration form that you are interested in Hill Day, and be sure to include all the states where your system has a footprint. If you have an existing relationship with a legislator, please let us know!

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

In Case You Missed It: NABH’s 2024 Advocacy Priorities

NABH released its 2024 Advocacy Priorities, which we urge you to read and share with your Government Relations teams. Topping NABH’s priorities this year are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.

Fact of the Week

In 2021 and 2022, people ages 75 and older had the highest suicide rate among all age groups, largely driven by males, according to the Centers for Disease Control and Prevention and noted in a recent Health Affairs article. For questions or comments about this CEO Update, please contact Jessica Zigmond.

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NABH Supported Behavioral Healthcare Riders in Funding Package Passes House and Awaits Senate Passage

House and Senate Leadership agreed to a six-bill spending package with a March 9 deadline that contains a narrow list of health measures, including several important NABH priorities. The agreement set up a Wednesday vote in the House, which passed the legislation 339-85 and sent the package to the Senate. The Senate is expected to consider and pass the legislation today or early tomorrow morning to avoid a partial government shutdown. Following passage of the initial package, lawmakers will have roughly three additional weeks to fund HHS as part of the second funding package which has a March 22 deadline. The limited health care riders include NABH priority provisions to permanently require state Medicaid plans to cover medication-assisted treatment and to create a permanent state Medicaid option allowing treatment of substance use disorder at institutions. Other behavioral health provisions include establishing Certified Community Behavioral Health Clinic services as an optional Medicaid benefit, requiring HHS to issue guidance on how states can improve integrating behavioral health with primary care, and a provision to make treatments more streamlined for justice-involved Medicaid beneficiaries — states must suspend rather than terminate coverage for incarcerated enrollees. The skinny health care package also includes funding to eliminate the statutorily required payment reductions intended to offset hospitals’ uncompensated care costs through Dec. 31, 2024. Notably excluded from the healthcare package is the Modernizing Opioid Treatment Access Act (MOTAA), which NABH and coalition partners advocated extensively to stop. Other healthcare provisions excluded include an extension of now-expired pandemic provisions allowing employers to offer telehealth as a separate benefit, highly-debated items related to prescription drugs and hospitals, such as pharmacy benefit manager (PBM) reforms, hospital price transparency measures, or any site neutral payment policies for hospitals. There is the potential that some healthcare provisions could move with the March 22 funding package or in a year-end health package following the November elections. Should another healthcare package emerge, NABH will continue to advocate for remaining SUPPORT Act provision priorities and to prevent any effort to include MOTAA.

HHS Announces Steps to Assist Providers After Change Healthcare Cyberattack

HHS on Thursday announced what the Centers for Medicare & Medicaid Services (CMS) is doing to help healthcare providers continue to serve patients following the late-February cyberattack on Change Healthcare, a unit of UnitedHealth Group (UHG). The HHS announcement also said the department is in regular contact with UHG leadership, state partners, and with numerous external stakeholders to better understand the nature of the impacts and to ensure the effectiveness of UHG’s response. “HHS has made clear its expectation that UHG does everything in its power to ensure continuity of operations for all health care providers impacted and HHS appreciates UHG’s continuous efforts to do so,” said in its statement. “HHS is also leading interagency coordination of the Federal government’s related activities, including working closely with the Federal Bureau of Investigations (FBI), the Cybersecurity and Infrastructure Security Agency (CISA), the White House, and other agencies to provide credible, actionable threat intelligence to industry wherever possible.” Click here to read about the steps CMS is taking to assist providers. And please contact NABH if your system has been affected by the cyberattack and/or if you have questions for NABH.

SAMHSA Announces $36.9 Million in Behavioral Healthcare Grant Funding

The Substance Abuse and Mental Health Services (SAMHSA) recently announced $36.9 million in grant program funding to support behavioral healthcare services nationwide. The funding covers a variety of areas, including $10 million for screening, brief intervention, and referral to treatment; more than $6 million to support first responders and others with training, administering, and distributing naloxone and other Food and Drug Administration (FDA)-approved opioid overdose reversal medications or devices; and more than $5 million to help expand and ensure that students in health professional receive SUD education early in their academic careers and have a basic knowledge of strategies to identify and treat addiction and support recovery after they graduate. Click here to read about the other funding opportunities.

Register for the NABH Education and Research Foundation’s Talent Recruitment Webinars

The NABH Education and Research Foundation will host a two-part webinar series about talent recruitment featuring NABH members and workforce experts in March and April. Part I –Talent Recruitment: Exploring Short-Term Solutions – will be held Tuesday, March 26, 2024 at 2 p.m. ET. Foundation Vice President Jim Shaheen, CEO of New Season/Colonial Management Group, LP, and Foundation Secretary Mary Pawlikowski, president at Vanderbilt Psychiatric Hospital and Clinics, will join workforce consultant Beth Kuhn of Stonegate Strategies for this interactive webinar to help NABH members learn about and share their best, short-term solutions to recruiting talent. Kuhn has more than 30 years of workforce experience and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. She has also served as chief engagement officer at the Kentucky Cabinet of Health and Family Services. The second webinar in this series will examine longer-term solutions to recruiting talent – such as Registered Apprenticeship Programs, education and certification opportunities, fellowships, and more – on Thursday, April 18 at 2 p.m. ET. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar with Kuhn and workforce consultant John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department. Please join us and click here to register for Part 1 on March 26 and here to register for Part 2 on April 18!

Alcohol Deaths Jump During Pandemic

A new CDC study found that more than 178,300 people died from excessive alcohol use during 2020 and 2021 in the U.S., a 29% increase from 2016 and 2017, and that the number of people who died per year increased by more than 40,000 within six years. Female deaths had a 35% spike compared to 27% for males.  The report suggests that increases may have been caused by changes in alcohol policies during the COVID-19 pandemic in which many states permitted alcohol carryout and delivery to homes for off-premises consumption.

SAMHSA to Hold Briefing on CFR Amendments

Join a virtual stakeholder briefing on Thursday, March 14, 3-4 pm ET, unveiling recent amendments to 42 CFR part 8 of the Code of Federal Regulations (CFR) governing opioid treatment program (OTP) certification and treatment standards. Published on Feb. 2, 2024, these revisions aim to enhance care access through reduced barriers, flexible treatment, and telehealth integration. This event will include a presentation from Dr. Yngvild Olsen, director of SAMHSA’s Center for Substance Abuse Treatment (CSAT), others, and followed by a Q&A and discussion. Register for this breifing here.

Register Today for the 2024 NABH Annual Meeting!

Please remember to register for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare and reserve your hotel room at the Salamander Washington, DC from May 13-15, 2024.   This year’s meeting will examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. We look forward to seeing you in Washington!

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

In Case You Missed It: NABH’s 2024 Advocacy Priorities

Last week NABH released its 2024 Advocacy Priorities, which we urge you to read and share with your Government Relations teams. Topping NABH’s priorities this year are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.

Fact of the Week

Research from the Treatment Advocacy Center (TAC) reports that bed availability within state psychiatric hospitals reached a low of 10.8 beds per population of 100,000 in 2023. TAC’s report attributed this trend to a variety of circumstances, including the COVID-19 pandemic and the increasing, disproportionate number of beds filled by individuals from the criminal legal system.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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Now Available: NABH 2024 Advocacy Priorities!

NABH is pleased to share its 2024 Advocacy Priorities, which we urge you to read and share with your Government Relations teams. Topping NABH’s priorities this year are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion. “NABH’s 2024 advocacy priorities reflect the organization’s mission to advance responsive, accountable, and clinically effective prevention, treatment, and care for children, adolescents, adults, and older adults with mental health (MH) and substance use disorders (SUD),” the advocacy priorities document notes. “2024 is a critically important year as the country continues to face intense access challenges for both MH and SUD patients. Demand for our services across all age groups nationwide has never been higher.

NABH Education and Research Foundation to Host Webinar Series on Talent Recruitment

The NABH Education and Research Foundation will host a two-part webinar series about talent recruitment featuring NABH members and workforce experts in March and April. Part I –Talent Recruitment: Exploring Short-Term Solutions – will be held Tuesday, March 26, 2024 at 2 p.m. ET. Foundation Vice President Jim Shaheen, CEO of New Season/Colonial Management Group, LP, and Foundation Secretary Mary Pawlikowski, president at Vanderbilt Psychiatric Hospital and Clinics, will join workforce consultant Beth Kuhn of Stonegate Strategies for this interactive webinar to help NABH members learn about and share their best, short-term solutions to recruiting talent. Kuhn has more than 30 years of workforce experience and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. She has also served as chief engagement officer at the Kentucky Cabinet of Health and Family Services. The second webinar in this series will examine longer-term solutions to recruiting talent – such as Registered Apprenticeship Programs, education and certification opportunities, fellowships, and more – on Thursday, April 18 at 2 p.m. ET. NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P. president and CEO, Rutgers University Behavioral Health Care and senior vice president, Behavioral Health and Addictions Service Line, RWJBarnabas Health, will lead the April webinar with Kuhn and workforce consultant John Pallasch of One Workforce Solutions. Pallasch served previously as the assistant secretary for employment and training at the U.S. Labor Department. Please join us and click here to register for Part 1 on March 26 and here to register for Part 2 on April 18!

Lawmakers Avert Government Shutdown; Healthcare Funding Package Slated for Late March

Federal lawmakers this week averted a partial government shutdown after the Senate on Thursday approved a two-step Continuing Resolution that clears the path for policymakers to conclude appropriations work and prepare for a healthcare funding package scheduled for March 22. The House and Senate moved quickly to pass a stopgap funding bill ready for President Biden’s signature this weekend, buying more time to finalize half a dozen spending bills that congressional leaders must pass by the new March 8 deadline. The vote will set up a first tranche of full-year spending bills, which include the Agriculture, Commerce-Justice-Science, Energy-Water, Interior-Environment, Military Construction-VA and Transportation-Housing and Urban Development measures. Enacting these bills would fund those agencies through Sept. 30. Congress will consider a second batch of bills as they face a new deadline of March 22 to avoid a partial government shutdown. That package includes the Defense, Financial Services, Legislative Branch, Homeland Security, Labor-HHS-Education and State-Foreign Operations measures. A final deal on the Labor-HHS bill could include a stripped-down healthcare package with a handful of priorities, including a NABH priority: an IMD provision that would make the state plan amendment option permanent. Other healthcare priorities expected in the bill include a partial fix to Medicare physician pay cuts, extended funding for community health centers, and delayed disproportionate share hospital cuts. Other long-debated health policy measures – including pharmacy benefit manger reforms, site-neutral hospital policies, transparency reforms, and some SUPPORT Act provision reauthorizations – are likely to be set aside until the lame-duck session after November’s elections. MOTAA proponents will likely continue to advocate for including this measure – which NABH will continue to oppose – in a November funding package.

SAMHSA to Host Webinar on Models to Reduce Frequent Service Utilization for Individuals with MH and SUD

The Substance Abuse and Mental Health Services Administration’s (SAMHSA) GAINS Center will host the webinar Implementing Complex Care Models to Reduce Frequent Service Utilization Among Individuals Experiencing Mental and Substance Use Disorders later this month. As SAMHSA noted in its announcement, people with complex healthcare needs, including mental and substance use disorders, can sometimes fall through service gaps and cycle among emergency, criminal justice, and hospital systems. Their complex needs require a person-centered approach to care and linkages to support treatment retention and recovery. Learn more in this webinar on Thursday, March 21 starting at 1:30 p.m. ET. Click here to register.

Now Open: 2024 NABH Annual Meeting Registration

Registration is now open for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare. Please join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting to examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. Click here to register for the meeting and reserve your hotel room. We look forward to seeing you in Washington!

Join Us for Hill Day 2024!

Please remember to sign up for Hill Day 2024 on Tuesday, May 14, the second day of this year’s Annual Meeting. Hill Day is an excellent opportunity to meet one-on-one with legislators to discuss the issues that matter most to behavioral healthcare providers. After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent you or your facility footprint. Closer to the day of the meeting, we will send you a meeting schedule, materials, and talking points to guide your conversations with Members of Congress and their staff. Please indicate in your Annual Meeting registration form that you are interested in Hill Day, and be sure to include all the states where your system has a footprint. If you have an existing relationship with a legislator, please let us know!

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

In areas with some racial or ethnic diversity, there is a large decline in the geographic availability of buprenorphine prescribers and prescription fills, according to a new study from the University of Pittsburgh. “In areas that are less than 95% white, for example, there’s a 45 to 50% drop (in access),” said Coleman Drake in a U.S. News and World Report article. Drake is an assistant professor of health policy and management at Pitt Public Health in Pittsburgh and the study’s lead author.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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DOL Includes Mental Health in $200 Million Grant Announcement for Registered Apprenticeships

The U.S. Labor Department this week announced nearly $200 million in grants to support public-private partnerships that expand, diversify, and strengthen Registered Apprenticeships and included mental health occupations under the “care economy” sector that is eligible to apply. The funding opportunity includes $95 million of competitive grants through the second round of the Apprenticeship Building America Grant Program and $100 million in the second round of State Apprenticeship Expansion Formula Grants. The Apprenticeship Building America Grant Program aims to leverage Registered Apprenticeships as a workforce solution while assuring that people from underrepresented and underserved communities can access high-quality training and pre-apprenticeships that lead directly to enrolling in a Registered Apprenticeship program. In addition to the care economy, sectors include information technology/cybersecurity, K-12 teacher occupations, clean energy, hospitality, public sector, and supply chain sector (logistics, warehousing, transportation, manufacturing). Click here to learn about the second round of the Apprenticeship Building America Grant Program and here to learn about the State Apprenticeship Expansion Formula grants. The NABH Education and Research Foundation will host a webinar this spring to help members learn more about Registered Apprenticeships and will provide details soon.

U.S. Supreme Court Rejects UBH Request to Hear Claim Denial Case

In a win for behavioral healthcare providers, the U.S. Supreme Court this week rejected a request for appeal from United Behavioral Health (UBH) to hear a behavioral health claim denial case. The initial case centered on how health plans under the Employee Retirement Income Security Act (ERISA) handle clinician insights in the denial-appeal process and how those decisions should be communicated to members. UBH sought to challenge a prior court’s rule pertaining to whether the health plan gave the plaintiff – a patient who ultimately died by suicide – a full and fair review during the denial-appeals process. The Supreme Court’s rejection this week upholds the 10th U.S. Circuit Court of Appeals’ May 2023 ruling, which noted: “United argues its actions were not arbitrary and capricious because it met certain ERISA regulatory requirements. It points to regulations which discuss requirements for engagement with medical opinions in ERISA disability plans,” and continued: “We recognize the textual difference in the ERISA disability and ERISA medical regulations pointed out by United but disagree that the dialogue absolves United from its duty to engage in meaningful dialogue that includes a full and fair review of the insured’s claim.”

National Academies Report Urges Developing Standards to Limit Potential Social Media Harms on Adolescent Mental Health

A recent report from the National Academies of Sciences, Engineering, and Medicine (NASEM) recommends developing new industry standards to limit the potential harms of social media on adolescent mental health while bolstering its possible benefits. The report notes that during the past 15 years, an increase in young people’s smartphone usage has coincided with a decline in mental health, a damaging  association that U.S. Surgeon General Vivek Murthy, M.D., M.B.A, warned against in a May 2023 advisory. Click here to read the JAMA article about the NASEM report.

HHS & DOJ to Host Webinar on Tech-facilitated Abuse in Teen Relationships Next Week

In conjunction with February’s Teen Dating Violence Awareness Month, HHS and the U.S. Justice Department (DOJ) will host a webinar on Feb. 28 to help participants learn about the use of technology in teen dating and its related impacts on behavioral health. HHS’ Office of Family Violence Prevention and Services and Substance Abuse and Mental Health Services Administration, along with DOJ’s Office on Violence Against Women, will lead the 75-minute event, which will also examine non-consensual image-sharing and practices to address these challenges at the community level. Click here to register for the webinar, which will begin at 3 p.m. ET next Wednesday.

Now Open: 2024 NABH Annual Meeting Registration

Registration is now open for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare. Please join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting to examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. Click here to register for the meeting and reserve your hotel room. We look forward to seeing you in Washington!

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

A recent report from union group National Nurses United showed 81.6% of nurses polled said they had experienced workplace violence in at least one form. Respondents reported the three most common types of violence were being verbally threatened (67.8%), physically threatened (38.7%), and being pinched or scratched (37.3%).   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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NABH Remembers Youth Services Committee Member Mike Lyons, M.S.

NABH remembers with grateful appreciation Mike Lyons, M.S., 54, who died unexpectedly of a brain aneurysm on Sunday, Feb. 11. Mike served as vice president of specialty education for Universal Health Services’ (UHS) Behavioral Health Division, where he was responsible for implementing UHS’ Best in Class Academic Accountability System throughout the organization’s network of academic programs in acute, partial hospitalization, residential, and day-school settings. Mike also championed education legislation at the state and federal levels to make certain that children and adolescents with mental illness receive an equitable and quality educational experience. At the association, Mike was an influential and supportive member of the Youth Services Committee, where his fellow members and NABH team respected him highly for his insights, thoughtful comments, and devotion to helping kids learn. As an example, last year Mike sent his regrets for missing the 2023 Annual Meeting and Youth Services Committee meeting so he could attend the high school graduation ceremony at one of UHS’ facilities. Mike will be missed by all who knew him. There will be a celebration of Mike’s life at The Casa Bella Club House, 6005 Anello Drive, Melbourne, Florida 32940 from 2 – 5 p.m. on Saturday, Feb. 17. In lieu of flowers, donations can be made to Camp Marist, 22 Abel Boulevard, Effingham, New Hampshire, 03882. Under the leadership of the Marist Brothers for more than 70 years, Camp Marist is based in New Hampshire’s White Mountain Lakes region and is a place where children learn about character, leadership, and community.

NABH Sends MOTAA Opposition Letter to Congressional Leaders

This week NABH sent a letter to House and Senate leaders outlining the association’s strong opposition to the Modernizing Opioid Treatment Access Act (MOTAA). “The Modernizing Opioid Treatment Access Act (MOTAA) [H.R. 1359 / S. 644] would permit addiction physicians outside OTPs to prescribe methadone that would be dispensed through pharmacies,” NABH wrote in its letter. “This legislation has not been vetted appropriately with stakeholders, the House has not held a hearing to examine it, and the Senate has given it only a cursory review,” the letter continued. “The bill’s goal is to provide greater access to methadone; however, patient safety concerns with such an untested approach warrants further review and attention before further congressional consideration.” NABH cautioned that MOTAA would significantly introduce more danger of overdose given the safety profile of methadone (versus buprenorphine, for example). Instead, NABH wrote that implementing the Substance Abuse and Mental Health Services Administration’s (SAMHSA) regulations released on Feb. 2 would be a more effective approach to providing greater access. “They will allow greater access to individuals of all ages, provide greater convenience for patients, bolster the workforce, ease expansion to broader settings of care (medication units and mobile units), and more,” NABH wrote. “The regulations also recognize that methadone has a more dangerous pharmacological profile than other medications for OUD.”

CMS Clarifies Parameters on Using AI in Coverage Decisions for MA Plans

In a recent memo, the Centers for Medicare & Medicaid Services (CMS) clarified that Medicare Advantage (MA) plans cannot use artificial intelligence (AI) and algorithms to deny prior authorization requests but may use the technology to assist in coverage decisions. This clarification – published in the memo as frequently asked questions (FAQ) – is based on the agency’s April 2023 rule, which took effect on Jan. 1, 2024. In the FAQ, the agency responds to concerns about inappropriate coverage denials based on algorithms. “An algorithm or software tool can be used to assist MA plans in making coverage determinations, but it is the responsibility of the MA organization to ensure that the algorithm or artificial intelligence complies with all applicable rules for how coverage determinations by MA organizations are made,” the agency noted in its FAQ. This scrutiny aligns with recent lawsuits against UnitedHealth Group, Humana, and Cigna’s MA plans, as well as a 2022 HHS Office of the Inspector General report about the erroneous algorithm coverage decisions.

Kaiser Family Foundation to Examine Prior Authorization in Webinar Next Week

The Kaiser Family Foundation (KFF) will host a webinar on Feb. 22 featuring a panel of four experts who will explore why insurers use prior authorization, its effect on patients and providers, and how new regulations may change current practices. Larry Levitt, KFF’s executive vice president for health policy, will moderate the 45-minute discussion that will include Troyen Brennan, M.D., adjunct professor of health policy and management at the Harvard T.H. Chan School of Public Health and former CVS Care executive; Fumiko Chino, M.D., radiation oncologist at Memorial Sloan Kettering Cancer Center; Anna Schwamlein Howard, principal, policy development at the American Cancer Society Action Network; and Kaye Pestaina, KFF’s vice president and director of the Program on Patient and Consumer Protection.   Click here to register for the webinar, which is scheduled for Thursday, Feb. 22 at noon ET.

SAMHSA Releases Resource on Medicaid Coverage of Medications for Alcohol and Opioid Use Disorders

SAMHSA has released a report that provides an update on the present state of coverage, availability of, and access to medications within state Medicaid plans for treating ongoing alcohol use disorder (AUD) and opioid use disorder (OUD) and reversing an opioid overdose. The new resource also includes examples of efforts to increase access to medications for treating SUD. SAMHSA also developed an hourlong webinar and slides in conjunction with the report.

SAMHSA Announces New SUD-Related Funding Opportunities

SAMHSA this week released two separate notices of funding opportunities focused on SUD. In the first funding notice, SAMHSA will distribute up to 10 awards totaling $9.95 million to implement the screening, brief intervention, and referral to treatment public health model for children, adolescents, and/or adults in primary care and community health settings, HMOs, PPOs, health plans, federally qualified health centers, children’s hospitals, and more with a focus on screening for underage drinking, opioid use, and other substance use. The other funding notice will distribute up to 18 awards totaling $5.4 million to expand and assure that graduate-level healthcare students receive SUD education early in their academic careers and prepare them to identify and treat UD in mainstream healthcare after they graduate.

Now Open: 2024 NABH Annual Meeting Registration

Registration is now open for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare. Please join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting to examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. Click here to register for the meeting and reserve your hotel room. We look forward to seeing you in Washington!

Join Us for Hill Day 2024!

Please remember to sign up for Hill Day 2024 on Tuesday, May 14, the second day of this year’s Annual Meeting. Hill Day is an excellent opportunity to meet one-on-one with legislators to discuss the issues that matter most to behavioral healthcare providers. After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent you or your facility footprint. Closer to the day of the meeting, we will send you a meeting schedule, materials, and talking points to guide your conversations with Members of Congress and their staff. Please indicate in your Annual Meeting registration form that you are interested in Hill Day, and be sure to include all the states where your system has a footprint. If you have an existing relationship with a legislator, please let us know!

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Behavioral healthcare jobs made three of the top seven and five of the top 20 jobs in Indeed’s Best Jobs of 2024, which focused on jobs w/ a minimum salary of $75,000 and w/ at least 10% of postings that included remote or hybrid work.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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Now Open: 2024 NABH Annual Meeting Registration!

Registration is now open for the 2024 NABH Annual Meeting, The Future of Behavioral Healthcare. Please join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting to examine and discuss critical issues that behavioral healthcare providers manage today and will continue to address tomorrow, including access to care, parity, technology, workforce, the political environment, and more. Click here to register for the meeting and reserve your hotel room. We look forward to seeing you in Washington!

SAMHSA and ONC Launch Behavioral Health Information Technology Initiative

HHS’ Substance Abuse and Mental Health Services Administration (SAMHSA) and Office of the National Coordinator for Health Information Technology (ONC) this week announced they will invest more than $20 million of SAMHSA funds in the next three years to advance health information technology (IT) in behavioral healthcare and practice settings. The announcement acknowledged that behavioral healthcare providers lag behind other providers in health IT adoption in part because they are ineligible to participate in health IT incentive programs that the Centers for Medicare & Medicaid Services (CMS) provide. An ONC analysis of American Hospital Association survey data from 2019 and 2021 found that 86% of non-federal, general acute care hospitals had adopted a 2015-edition certified electronic health record (EHR), while only 67% of psychiatric hospitals had adopted the same certified EHR. Meanwhile, ONC analysis of SAMHSA survey data from 2020 show psychiatric hospitals lag even further behind in adoption of interoperability and patient engagement functions. To address these challenges, the Behavioral Health Information Technology (BHIT) Initiative will identify and pilot a set of behavioral health-specific data elements with SAMHSA’s Substance Use Prevention, Treatment, and Recovery Services Block Grant and Community Mental Health Services Block Grant grantees and Community Mental Health Services Block Grant grantees. The data elements will be coordinated via a new USCDI+ domain for behavioral health to improve the effectiveness and reduce the costs of data capture, use, and exchange for behavioral health providers. This year ONC, SAMHSA, and other federal partners will begin to identify data elements for the USCDI+ project as part of the broader BHIT Initiative. This collaborative approach will incorporate input on behavioral health priorities from a variety of individuals and entities including clinicians, grantees, states, and advocates. Then SAMHSA and ONC will coordinate with technology developers and participating providers on how to best include USCDI+ behavioral health data elements in health IT and pilot their use.

HHS Finalizes ‘42 CFR Part 2’ Rule to Better Align with HIPAA Standards

HHS on Thursday released its final Confidentiality of Substance Use Disorder (SUD) Patient Records rule to implement the Coronavirus Aid, Relief, and Economic Security Act (CARES) amendments to the federal substance use confidentiality rule – commonly known as 42 CFR part 2, or Part 2. Consistent with NABH recommendations, the new rules further align Part 2’s requirements with the Health Insurance Portability and Accountability Act’s (HIPAA) rules and the Health Information Technology for Economic and Clinical Health Act (HITECH). Although opponents to these changes argued they were unnecessary, HHS nonetheless adopted these modifications to align with HIPAA, a rule that has historically had fewer privacy protections than part 2. The new rule permits patients to provide one-time consent for the disclosure of treatment records; permits an accounting of disclosures; strengthens prohibitions against disclosure of records in civil, criminal, or legislative proceedings, and provides HHS with enforcement authority, including financial penalties. Importantly, the rule creates a new definition for SUD clinicians’ notes that is analogous to the protections HIPAA provides for psychotherapy notes. The rule will become effective 60 days after publication and compliance is not required until 2026. Meanwhile, HHS’ Office for Civil Rights plans to finalize changes to the HIPAA Notice of Privacy Practices (NPP) to address uses and disclosures of protected health information that is also protected by Part 2 along with other changes to the NPP requirements, in an upcoming final rule modifying the HIPAA privacy. In addition, HHS plans to implement in separate rulemaking the CARES Act antidiscrimination provisions that prohibit the use of patients’ Part 2 records against them.

CMS Releases Updated State Medicaid & CHIP Telehealth Toolkit

CMS this week released an updated State Medicaid & Children’s Health Insurance Program (CHIP) Telehealth Toolkit, a series of resources that include telehealth policies and information about telehealth platforms, billing best practices, strategies to deliver accessible and culturally competent care via telehealth, and more. The resources provide states with statutory and regulatory infrastructure issues to consider as they evaluate the need to expand their telehealth capabilities and coverage policies, including coverage and reimbursement policies, providers, and practitioners eligible to provider telehealth, technology requirements, considerations for specific populations, and state examples and strategies.

Prevent Suicide New Jersey to Host Safety Planning Intervention Workshop on Feb. 28

Prevent Suicide New Jersey, a partnership among state departments, professional and community organizations, schools, and families, will host a free workshop on Feb. 28 about the Stanley Brown Safety Planning Intervention (SPI), a collaborative, clinical intervention that results in a prioritized written list of warning signs, coping strategies, and resources for suicidal individuals. The virtual workshop will teach participants the six steps to create a safety plan: 1) recognizing warning signs; 2) identifying internal coping strategies; 3) identifying other people or social settings for distraction; 4) identifying individuals to ask for help; 5) identifying professionals and agencies for help; and 6) making the environment safe. The New Jersey Chapter, American Academy of Pediatrics (NJAAP), ABFT International Training Institute, LLC, and the U.S. Journal of Training are co-sponsoring the training, and the webinar is open to certified licensed community behavioral health clinicians, school-based behavioral health providers, and interested community members. Click here to register.

Reminder: Please Submit Data to NABH’ Denial-of-Care Portal

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

Researchers at the University of Texas at Austin, the University of Texas at Dallas, and the University of Miami have identified a molecule that reduces hypersensitivity in trials in mice by binding to a protein they have shown is involved in neuropathic pain, according to a study published in Science Daily. The new compound, dubbed FEM-1689, does not engage opioid receptors in the body, making it a possible alternative to existing pain medications linked to addiction.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

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NABH Alert: SAMHSA Updates OTP Regulations

The Substance Abuse and Mental Health Services Administration published Medications for the Treatment of Opioid Use Disorder late yesterday for public inspection. The final rule was published earlier today and becomes effective on April 2, 2024, with compliance by October 2, 2024. [Please note that this is a correction of the compliance date of October 2, 2026 that was published yesterday in the public notice.] NABH provided comments on the Notice of Proposed Rule Making that was issued in December 2022 calling for greater regulatory flexibility for opioid treatment programs (OTPs). The final regulations align closely to NABH recommendations and herald greater deference to clinical decision-making in the nation’s (OTPs). Among the provisions, the regulations:
  • Make permanent the Covid-era take-home schedule;
  • Permit methadone for new patients via audio-visual telemedicine with the dispensing of medication at the OTP (not audio-only).
  • Permit audio-only telemedicine when the patient is in the presence of a practitioner who is registered to prescribe SII, including dispensing.
  • Clarify (in response to NABH off-line discussion and official comments) that the prescription of methadone to community pharmacies is NOT permitted;
  • Change the requirement for a one-year history of OUD for eligibility so that now either the patient must a) meet diagnostic criteria for moderate-severe OUD, or b) be in OUD remission, or c) at high risk for overdose;
  • Remove the requirement for two treatment failures for people under 18 to be eligible for services;
  • Remove requirement for a one-year history of OUD for people recently released from a correctional facility, pregnant patients, or previously enrolled individuals;
  • Allow medication units to provide all OTP services;
  • Decouple medication and attendance at counseling services;
  • Permit interim treatment for 180 days, including at for-profit OTPs;
  • Permit mid-levels (“…those appropriate licensed by the state”) to prescribe without exemption;
  • Clarified accreditation standards to reduce potential for a burdensome increase in less-than 3-year accreditations;
  • Permit buprenorphine prescribing in an OTP via audio-only and audio-visual without an in-person evaluation; and
  • Update terminology to reflect contemporary, non-stigmatizing language.
The final rule additionally codifies the Consolidated Appropriations Act, 2023 elimination of the Drug Addiction and Treatment Act (DATA) Waiver by removing all relevant language.

CMS Proposes MA Rates for 2025

The Centers for Medicare & Medicaid Services (CMS), on Wednesday, released a calendar year (CY) 2025 advance notice which includes measures related to Medicare Advantage (MA) and other issues. The advance notice proposes an annual increase to MA payments of, on average, 3.7 percent ($16 billion), relative to 2024. This advance notice complements another CY 2025 proposed rule issued last November. It also builds upon technical updates in 2023 to the MA risk adjustment model that are designed to yield more accurate payments. CMS will accept comments on the advance notice through April 1. For additional background, see this CMS fact sheet. NABH appreciates CMS’s meaningful efforts in recent years to improve the MA program, including increasing the accountability and transparency of MA health plans as well as substantive proposals to enforce parity and improve the prior authorization program.

CMS Requests Information on MA In Push For Data Transparency

The Centers for Medicare & Medicaid Services (CMS), on Thursday, Jan. 24, requested information on Medicare Advantage (MA) data capabilities to increase data transparency. The RFI asked for recommendations for improving data capabilities to increase accuracy on coverage, enhance quality of care, and better inform healthcare professionals. This RFI builds upon CMS’ extensive regulatory activity to increase transparency and accountability of Medicare Advantage plans. CMS is aiming to have comprehensive data on the MA program made publicly available and thus allowing for further comparative analyses between other health programs. Click here to read the full press release.

SAMSHA Releases Guide for Overdose Prevention and Response

The SAMHSA Overdose Prevention Toolkit provides guidance on preventing and responding to an overdose and the role of opioid overdose reversal medications. The toolkit emphasizes that harm reduction and access to treatment are essential aspects of overdose prevention. Appendices are directed to specific audiences, such as people who use drugs (PWUD), people taking prescribed opioids, first responders, healthcare practitioners, and others. Click here to access the toolkit.

GAO Evaluates the Potential Expansion of FHA Loans to Behavioral Health Hospitals

The Government Accountability Office last week issued recommendations to Congress on the pros and cons on the possible expansion of the Federal Housing Authority (FHA) Hospital Mortgage Insurance Program. Any expansion in the future would expand access to higher-acuity behavioral health services. Today, this FHA program funds loans to general acute-care hospitals for capital improvements, not including hospitals focused on treating behavioral health patients due to their, on average, smaller size, revenue, and margins. The report, commissioned by Congress, suggests that any expansion of this program be coupled with parameters to mitigate potential risks, such as initially limiting the volume loans to newly eligible hospitals through a pilot program, and requiring regular loan performance updates from FHA to Congress

SAMHSA Offers Consumer Guide for Peer Support in Substance Use Recovery

The newly released peer support recovery guide from The Substance Abuse and Mental Health Services Administration (SAMHSA) provides an in-depth look into the role of peer specialists. SAMHSA states that readers can utilize visual aids and consumer forms to better understand the range of services provided by peer specialists and how they can be a resource to those in recovery from substance use. Click here to access the guide.

HHS’ Office of Long Covid Welcomes Ian Simon as Director

The Department of Human and Health Services (HHS) appointed Ian Simon as the director of the Office of Long Covid Research and Practice. In this position, Simon will lead HHS towards a coordinated government response to better understand the long-term impacts of COVID-19. Simon was the assistant director for health strategy and bio preparedness at the White House’s Office of Science and Technology Policy. He also brings additional experience from his time at the National Institute of Allergy and Infectious Diseases (NIAID).

Reminder: SAMHSA Releases Updated 988 Partner Toolkit

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released an updated 988 Partner Toolkit that the agency says is designed to help users better navigate the bank of materials available to promote the lifeline in communities. The toolkit has the same video PSAs, social media promotions, FAQs, and print materials, and is now available to search by target audience, population, language, and resource type. Click here to access the toolkit.

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Save the Date for the NABH 2024 Annual Meeting!

Please plan to join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting, The Future of Behavioral Healthcare. Registration will open in February.

Fact of the Week

A study from JAMA Internal Medicine found that pregnant patients treated with buprenorphine within the first trimester had an 18% lower risk of congenital malformations than those treated with methadone.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

SAMHSA Updates OTP Regulations

SAMHSA Updates OTP Regulations

Updated Feb. 2, 2024 The Substance Abuse and Mental Health Services Administration published Medications for the Treatment of Opioid Use Disorder late yesterday for public inspection. The final rule was published earlier today and becomes effective on April 2, 2024, with compliance by October 2, 2024. [Please note that this is a correction of the compliance date of October 2, 2026 that was published yesterday in the public notice.] NABH provided comments on the Notice of Proposed Rule Making that was issued in December 2022 calling for greater regulatory flexibility for opioid treatment programs (OTPs). The final regulations align closely to NABH recommendations and herald greater deference to clinical decision-making in the nation’s (OTPs). Among the provisions, the regulations:
  • Make permanent the Covid-era take-home schedule;
  • Permit methadone for new patients via audio-visual telemedicine with the dispensing of medication at the OTP (not audio-only).
  • Permit audio-only telemedicine when the patient is in the presence of a practitioner who is registered to prescribe SII, including dispensing.
  • Clarify (in response to NABH off-line discussion and official comments) that the prescription of methadone to community pharmacies is NOT permitted;
  • Change the requirement for a one-year history of OUD for eligibility so that now either the patient must a) meet diagnostic criteria for moderate-severe OUD, or b) be in OUD remission, or c) at high risk for overdose;
  • Remove the requirement for two treatment failures for people under 18 to be eligible for services;
  • Remove requirement for a one-year history of OUD for people recently released from a correctional facility, pregnant patients, or previously enrolled individuals;
  • Allow medication units to provide all OTP services;
  • Decouple medication and attendance at counseling services;
  • Permit interim treatment for 180 days, including at for-profit OTPs;
  • Permit mid-levels (“…those appropriate licensed by the state”) to prescribe without exemption;
  • Clarified accreditation standards to reduce potential for a burdensome increase in less-than 3-year accreditations;
  • Permit buprenorphine prescribing in an OTP via audio-only and audio-visual without an in-person evaluation; and
  • Update terminology to reflect contemporary, non-stigmatizing language.
The final rule additionally codifies the Consolidated Appropriations Act, 2023 elimination of the Drug Addiction and Treatment Act (DATA) Waiver by removing all relevant language.

CEO Update 170

CMS $50 Million in Grants for School-Based Health Services, Particularly for Mental Health

The Centers for Medicare & Medicaid Services (CMS) this week announced $50 million in state grant funding to connect millions more children to critical healthcare services, especially mental health, in schools. The funding comes through the Bipartisan Safer Communities Act and will provide 20 states up to $2.5 million each in funding that can help states implement, enhance, and expand school-based health services through Medicaid and the Children’s Health Insurance Program, or CHIP. “This funding will be transformational for states at any stage in developing school-based health services programs, which represent one of CMS’ most powerful tools for expanding access to care for our children,” CMS Administrator Chiquita Brooks-LaSure said in an announcement about the funding. “Medicaid and CHIP cover over 39 million children. This targeted support is one way CMS can help kids get the health care they need by meeting them where they are — in school.” CMS said it anticipates a total of 20 grant awards, with a minimum of 10 awards to states that have yet to cover school-based health services for all children covered under Medicaid or CHIP. In addition, the agency said up to 10 grants are intended for states that have taken initial steps to expand school-based health services, with the hope that these grants will enhance or refine their existing programs. Applications for grant funding are due by March 25 and funding is expected by this summer. Click here for more information.

National Academy for State Health Policy Updates State Opioid Settlement Tracker

The National Academy for State Health Policy (NASHP) this month updated its tracker to show how states are implementing administrative structures to disburse an expected $50 billion awarded to states and localities from opioid-related lawsuits, which includes $26 billion awarded to 46 states as part of the National Opioid Settlement. These structures include strategies for engaging a wide variety of stakeholders on priorities for reducing opioid-related deaths and investing in SUD prevention, treatment, and recovery infrastructure. NASHP released an issue brief about its tracker in December 2022 to show funding allocated to each state through the National Opioid Settlement, as well as laws, agreements, and processes that states have established for allocating the funds.

Now Available: NABH Education and Research Foundation Webinar Resources and Interview

Thank you to all who joined or watched our foundation’s webinar, Redesigning the Present and Future Behavioral Healthcare Workforce, on Tuesday, Jan. 23. NABH regrets that we were unable to hear from NABH Education and Research Foundation President and co-presenter Don Parker soon after the webinar began due to a power outage in Parker’s service area. Below is an exchange between Parker and co-presenter Beth Kuhn, principal at workforce consultancy Stonegate Strategies, in a post-webinar interview. BK: Don, what can you tell us about the top workforce challenges you experienced at Hackensack Meridian Health System? DP: At the start of the COVID-19 pandemic, the Hackensack Merdian Health System asked the system’s Behavioral Health Care Transformation Services to develop a post-pandemic strategy recognizing that we would have two major problems to deal with: a rapidly increasing demand for behavioral healthcare, given all of the fear, loss, isolation and uncertainty our citizens were experiencing, and an unpredictable reaction from our staff who had the same fears but just multiplied given the nature of their jobs in health care. Although we slowed our feared staff exodus, similar to every other hospital in America, it increased and has led to shortages across the professions. As we now face both supply (under staffing of all levels of professionals) and demand (unprecedented demand for behavioral health from every age cohort) our HMH team has turned its focus to improving retention and attracting new recruits to bolster our veterans. BK: Your system has been especially focused on building partnerships to support your talent supply efforts.  What can you tell us about your approach? DP: Knowing we would face a shortage of psychiatrists, HMH initiated 64 psychiatry resident slots and 16 fellowships (heavily weighted to children). Our first class graduated last year and began to fill our ranks.  For the many residents and fellows we recruited to stay at HMH, we engaged them in an “Earn While You Learn” program for their final year. They received what would be equal to a signing bonus in monthly increments for the year. It provided great recruitment and retention. Our health system created two new nursing school partnerships with all the nurses rotating through the HMH psychiatry locations. The exposure has proven to be highly beneficial to our nursing recruitment. On the Mental Health Technician front, we have initiated several programs in partnership with the Local Workforce Investment Boards and the Community Colleges. I have had more than a 30-year history of working closely with WIBs. I also served as chairman of the WIB in my county in New Jersey for several years. I have been a Board Member of the Community College in my County for 17 years and personally started my education in a Junior College. BK: One webinar participant asked for information on what “resiliency investments” look like. It seems to me that you have some answers within your overall retention strategy. DP: Our administrative staff were deeply concerned that we would experience an exodus of our staff due to the sheer everyday extreme stress they were experiencing. During the pandemic HMH engaged in multiple staff support strategies, from shortened schedules, on the spot individual and group counseling, integrative medicine delivered remotely or on the spot, as well every morale booster we could engage in. In addition, as a retention strategy, HMH has shifted to a Strength-based motivational system (our version of Strength-based therapy). We expect that the focus on creating a mindset as a Survivor as opposed to being a victim of the pandemic will have a major impact on improving retention. BK: Apprenticeship seems to hold a lot of potential, both in bringing more professionals into your system and in prompting workforce redesign.  Tell us about HMH apprenticeship efforts. DP: Our post-pandemic initiatives have featured two collaborations with Middlesex Community College in New Jersey and the WIB Board. In Fall 2023, we worked with Middlesex to develop and deliver a certification as a Mental Health Technician. While not specifically designated as an apprenticeship, it served the purpose, as the academics, designed in collaboration with the HMH staff, were delivered to the college, with the on-the-job at HMH Psychiatric Hospitals. HMH has engaged in designing a second MHT Certification with a specialization in Integrative medicine. Each of our four psychiatric inpatient hospitals at HMH provide a daily curriculum filled with options for patients to engage in relaxation exercises, music therapy, yoga, Qigong, exercise programs, and a substantial exposure to art therapy. We expect this initiative will expand our recruitment pool to all the integrative medicine providers who practice in the community and can blend their practices with a job that offers steady income and benefits.

Reminder: SAMHSA Releases Updated 988 Partner Toolkit

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released an updated 988 Partner Toolkit that the agency says is designed to help users better navigate the bank of materials available to promote the lifeline in communities. The toolkit has the same video PSAs, social media promotions, FAQs, and print materials, and is now available to search by target audience, population, language, and resource type. Click here to access the toolkit.

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Save the Date for the NABH 2024 Annual Meeting!

Please plan to join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting, The Future of Behavioral Healthcare. Registration will open in February.

Fact of the Week

Semaglutide, a highly popular medication that the U.S. Food and Drug Administration has approved to treat obesity and manage type 2 diabetes, was associated with a 49% to 73% lower risk of first-time or recurring suicidal ideations compared with other medications for controlling obesity and type 2 diabetes that work via different mechanisms, according to a recent NIH-funded study.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 169

NABH Education and Research Foundation to Kick Off Webinar Series Next Week

The NABH Education and Research Foundation is pleased to host its first webinar, Redesigning the Present and Future of Behavioral Healthcare, on Tuesday, Jan. 23, 2024 from 2 p.m. – 3 p.m. ET. Foundation President Donald Parker, who serves as president of Behavioral Health Care Transformation Services for Hackensack Meridian Health, will co-lead the webinar with workforce consultant Beth Kuhn of Stonegate Strategies. Kuhn has more than 30 years of workforce experience – with special interest and expertise in behavioral healthcare workforce development – and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as director of workforce development at the Vermont Department of Labor. Kuhn’s accomplishments include creating the Strategic Initiative for Transformation Employment, or SITE, a statewide model designed to bridge the gap between recovery and workforce participation for individuals active in their recovery from substance use issues. During this interactive webinar, participants are encouraged to ask questions of Kuhn and Parker, who will provide an overview of existing behavioral healthcare workforce challenges; explain why America’s current workforce structure doesn’t meet present or future workforce needs; suggest redesign strategies, present examples of current successes; and offer ideas about how to leverage current options to help providers develop a more robust workforce system. Please join us and click here to register for this free webinar!

Congress Clears Stop Gap Funding Extension, Delaying Potential Healthcare Package

Staving off a government shutdown, House and Senate lawmakers passed legislation this week to extend the federal government’s current funding deadlines into March. The House passed the bill in 314-108 vote hours after the Senate passed the measure 77-18. The legislation extends funding for agencies under four appropriations bills that were scheduled to expire today, Jan. 19 – Agriculture, Rural Development, Food and Drug Administration, and related agencies; Energy and Water Development; Military Construction, Veterans Affairs, and related agencies; and Transportation, Housing and Urban Development, and related agencies – until March 1. Funding covered under the remaining eight bills that were scheduled to expire Feb. 2 have been extended through March 8. Lawmakers have indicated they expect this is the final stopgap spending measure needed for fiscal year 2024. Several non-controversial healthcare provisions were included in the March 8 stopgap measure, such as providing continued funding for community health centers, teaching health centers and the National Health Service Corps; funding special diabetes programs; averting steep cuts to hospitals that have a high volume of uninsured and Medicaid patients; and providing continued funding for the Sexual Risk Avoidance Education Program, which aims to limit teen pregnancy and domestic violence. The bill did not address several expired health programs, including the SUPPORT Act reauthorization; the global HIV/AIDS program, the U.S. President’s Emergency Plan for AIDS Relief (PEPFAR); the Pandemic and All-Hazards Preparedness Act; and heath price transparency legislation. Lawmakers are expected to include those programs in a potential March deal, if Congress doesn’t have to punt again with another spending patch. NABH continues to advocate for SUPPORT Act reauthorization and to stop the Modernizing Opioid Treatment Access Act (MOTAA) as part of a broader healthcare package. Health policy leaders in the House and Senate remain in negotiations on a final package.

CMS Increases Prior Authorization Timeliness and Transparency in Final Rule

The Centers for Medicare & Medicaid Services (CMS) this week finalized a rule that takes concrete steps to shorten the prior authorization process, which physicians and providers use to request health plan coverage for medical treatments and services that a physician has prescribed for a patient. In part, this rule responds to recent government audits that found that many government-contracted health plans were denying coverage inappropriately for services that actually were covered. The rule mostly takes effect for managed contracts in 2026 and beyond for insurers who contract with Medicare, Medicaid, and the Children’s Health Insurance Program, but not private insurance. Specifically, health plans will be required to make prior authorization coverage decisions within seven days and 72 hours for urgent requests. The rule also requires health plans to provide a specific reason for denying a prior-authorization request, which will help facilitate the correction of fixable claims as well as denial appeals. These payers also will be required to report their clinical and/or policy basis publicly for prior-authorization denials. Finally, to further reduce administrative burden, payers will now be required to conduct prior authorizations using a common electronic interface for transactions and data exchange, using Health Level 7 and other applications. Overall, CMS estimates that the final rule will reduce federal healthcare expenditures by approximately $15 billion over 10 years. Click here to learn more in the agency’s fact sheet.

CMS Announces Model to Test Approaches for Advancing Integration in Behavioral Health

CMS on Thursday introduced its Innovation in Behavioral Health (IBH) model to improve the care quality and outcomes for adults with Medicare and Medicaid who have mental health conditions and/or substance use disorder (SUD) by connecting them with the physical, behavioral, and social supports they need. The CMS Innovation Center will test the new IBH model, under which community-based behavioral healthcare practices will form interprofessional care teams composed of behavioral and physical health providers, as well as community-based supports. This new model supports President Biden’s mental health strategy and implements an action item in the HHS Roadmap for Behavioral Health Integration.   “The Biden-Harris administration will continue to explore innovative ways to help people with mental health conditions and/or substance use disorder,” HHS Secretary Xavier Becerra said in an announcement. “Put simply, mental health is health—and by expanding access to the high-quality care that people need, we are changing lives.” CMS’ announcement said through the interprofessional care teams, people will experience an integration of services that will bridge the gaps between physical and behavioral health. The model enables a “no wrong door” approach, meaning that regardless of how patients enter care, they will have access to all available services. Through this practice, IBH also aims to reduce overall program expenditures. The model will launch in Fall 2024, and CMS said it expects it to operate for eight years in up to eight states. CMS will release a notice of funding opportunity for the model in Spring 2024. Click here to learn more.

SAMHSA Releases Updated 988 Partner Toolkit

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released an updated 988 Partner Toolkit that the agency says is designed to help users better navigate the bank of materials available to promote the lifeline in communities. The toolkit has the same video PSAs, social media promotions, FAQs, and print materials, and is now available to search by target audience, population, language, and resource type. Click here to access the toolkit.

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Save the Date for the NABH 2024 Annual Meeting!

Please plan to join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s Annual Meeting, The Future of Behavioral Healthcare. Registration will open in February. Fact of the Week SAMHSA’s Food and Mood Project aims to promote emotional wellness and reduce the impact of mental health and substance use conditions among the nation’s K-12 population by implementing strategies that address the intersection among behavioral health, food/nutrition security, and cultural food diversity.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 168

Congress Returns to Urgent Funding Deadlines and Full 2024 Agenda

Congress returned to Washington this week facing two deadlines to fund all federal government operations as it works to clear some policy priorities – including a healthcare package with the SUPPORT Act’s reauthorization – ahead of the 2024 campaign season. In early January, House Speaker Mike Johnson (R-La.) and Senate Majority Leader Chuck Schumer (D-N.Y.) agreed to topline funding figures, allowing congressional appropriations leaders to begin the process of negotiating each of the spending allocations for all 12 spending bills. Congress has until Jan. 19 before the first government funding deadline for the U.S. Agriculture, Energy, Housing and Urban Development, Transportation, and Veterans Affairs Departments. All other departments, including HHS, are funded through Feb. 2. There is a growing likelihood that Congress will have to pass a short-term continuing resolution (CR) to allow lawmakers to agree on funding, although conservative House members are strongly opposed to that action and threaten to derail progress. Congressional leaders have indicated a healthcare package will likely be included in the first funding bill, due to the urgency in addressing several expired health programs and funding provisions for physician payments. This package will include several healthcare bills the House and Senate have passed.   NABH continues to advocate strongly for the SUPPORT Acts reauthorization with new provisions and opposes the Modernizing Opioid Treatment Access Act (MOTAA), which only the Senate HELP Committee has passed and the House has not considered. MOTAA proponents are strongly advocating for this bill to be included in the final package, and NABH and coalition partners are working with both congressional chambers to prevent this effort. This advocacy includes working with members of the Senate HELP Committee who oppose MOTAA to continue raising concerns with their Senate leadership; contacting members who serve on the Senate Judiciary Committee; contacting other senators who share concerns with law enforcement officials about implementing this legislation; as well as contacting members of the House Energy and Commerce Committee and House Judiciary Committee. House Energy & Commerce Republicans remain strongly opposed to including MOTAA in any legislative package. NABH continues to emphasize to Members of Congress that there is no consensus on MOTAA and these policies need more vetting. Other health policies that lawmakers might fold into a larger legislative package include addressing expired telehealth regulations, Medicare’s physician pay cut, transparency measures, reporting requirements for insurers, hospitals and pharmacy benefit managers, and site-neutral payment provisions. In addition, funds for graduate medical education, community health centers, and special diabetes programs sunset on Jan. 19, and certain Medicaid disproportionate share hospital cuts are delayed until that date. NABH will continue to support provisions important to our members and fight to prevent bad policies from becoming law. Please see next week’s edition of CEO Update for the latest information.  

NABH Education and Research Foundation to Host Workforce Webinar on Jan. 23

Please join us for the NABH Research and Education Foundation’s first webinar, Redesigning the Present and Future of Behavioral Healthcare, on Tuesday, Jan. 23, 2024 from 2 p.m. – 3 p.m. ET. Foundation President Donald Parker, who serves as president of Behavioral Health Care Transformation Services for Hackensack Meridian Health, will co-lead the webinar with workforce consultant Beth Kuhn of Stonegate Strategies. Kuhn has more than 30 years of workforce experience – with special interest and expertise in behavioral healthcare workforce development – and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. Kuhn’s accomplishments include creating the Strategic Initiative for Transformation Employment, or SITE, a statewide model designed to bridge the gap between recovery and workforce participation for individuals active in their recovery from substance use issues. During this interactive webinar, participants are encouraged to ask questions of Parker and Kuhn, who will provide an overview of existing behavioral healthcare workforce challenges; explain why America’s current workforce structure doesn’t meet present or future workforce needs; suggest redesign strategies, present examples of current successes; and offer ideas about how to leverage current options to help providers develop a more robust workforce system. Please click here to register for this free webinar and share the link with members of your teams!

CMS Administrator Brooks-LaSure to Outline Agency’s 2024 Priorities in Stakeholder Call

The Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure will host a stakeholder call to discuss the agency’s 2023 accomplishments, 2024 priorities, and CMS Strategic Plan on Tuesday, Jan. 23. CMS Principal Administrator and Chief Operating Officer Jon Blum and other members of the CMS leadership team will also serve as presenters during the hourlong call, which will begin at 1 p.m. ET. Click here to register.

CMS Releases State Plan Summaries for American Rescue Plan of 2021

CMS has released state spending plan summaries for a section of the American Rescue Plan of 2021 (ARP) that provides information about the amount of money spent on activities to enhance, expand, or strengthen community-based services. NABH members might find the report useful because it includes information about state spending on efforts related to workforce, technology, education, behavioral healthcare support for youth, housing and homelessness, and more. Click here for the full report and to read your state’s summary.

Save the Date for the NABH 2024 Annual Meeting!

Registration will open soon for the NABH 2024 Annual Meeting, The Future of Behavioral Healthcare, at the Salamander Washington, DC from May 13-15, 2024. Please plan to join us!  

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Fact of the Week

About 52,000 Medicare enrollees experienced an opioid overdose in 2022; however, only 18% of Medicare patients with opioid use disorder received medication-assisted treatment, according to a report from the HHS Office of the Inspector General. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 167

NABH Welcomes Frank Ghinassi, Ph.D. as 2024 Board Chair

NABH is pleased to welcome Rutgers University Behavioral Health Care (UBHC) President and CEO Frank Ghinassi, Ph.D. as chair of the NABH Board of Trustees for 2024. A longstanding NABH member, Frank has served the association in many capacities, including as board treasurer, Quality Committee chair, and Annual Meeting program chair. As UBHC’s CEO, Frank is responsible for a statewide system of academically based mental health and addiction services across New Jersey; managing an annual operating budget of $320 million and 2,200 staff and faculty. UBHC, one of the largest providers of behavioral and addictions healthcare in the country, offers a wide range of clinical services across all diagnosis, and across the lifespan, including inpatient units, partial hospitalization programs, intensive outpatient programming, case management, traditional outpatient treatment, correctional health care, a Certified Community Behavioral Health Center, peer operated helplines for service members, veterans, mothers of children with special needs, law enforcement officers and child protection workers, a statewide suicide prevention hotline and a clinical research and training institute, as well as an array of specialty and peer support services. Frank also serves as professor at Rutgers Graduate School of Applied and Professional Psychology; an adjunct professor of psychiatry at Rutgers Robert Wood Johnson Medical School; an adjunct associate professor of psychiatry at the University of Pittsburgh School of Medicine; and a core faculty member at Rutgers Global Health Institute. The association’s Washington-based team is eager to work with Frank this year and appreciates his vision and leadership. NABH is also grateful to Sheppard Pratt President and CEO Harsh Trivedi, M.D., M.B.A. for his service as the association’s 2023 board chair and all he has done to promote NABH, its priorities, and its mission. Thank you, Harsh!

NABH Letter to CMS Cites Concerns about Medicare Advantage Plans that Block Access to Care

NABH this week sent a letter to the Centers for Medicare & Medicaid Services (CMS) expressing concerns about Medicare Advantage (MA) plans that either block or delay access to behavioral healthcare services. The association’s letter endorsed and also made recommendations related to the rule’s positive provisions, such as incentivizing MA coverage for additional behavioral healthcare practitioners and inclusion in a health plans’ provider networks; annually analyzing the health equity level of MA plans relative to underserved populations; and laying the groundwork for increased data collection on MA coverage decisions, appeals and decision rationales. NABH’s letter also urged CMS to modify its existing proposal to improve the appeals process for MA enrollees in certain settings to include behavioral healthcare settings, which the letter describes in detail.

Sen. John Fetterman Discusses His Battle with Depression on NBC’s ‘Meet the Press’

In an exclusive interview with NBC News’ “Meet the Press” on Dec. 31, Sen. John Fetterman (D-Pa.) spoke candidly about his experience with clinical depression and how he is grateful for receiving treatment. The first-term senator was discharged March 31 from Walter Reed National Medical Center, where he had received treatment for clinical depression. Fetterman checked himself in for treatment on Feb. 15 last year following a battle with depression that worsened during his recovery from a stroke he suffered in May 2022. “The line [is] ‘I’m living my best life,’ and I really am, because I just am so grateful,” Fetterman told journalist Kristen Welker. “And I’m always talking about mental health because I want everybody that can hear that is that help works, and you should get help. And please, don’t suffer any longer, because you deserve to be better. And I’m so grateful to do that, and I’m paying it forward by talking about it.” Click here to watch Fetterman’s interview.

NABH Education and Research Foundation to Host Workforce Webinar on Jan. 23

The NABH Education and Research Foundation is pleased to host its first webinar, Redesigning the Present and Future of Behavioral Healthcare, on Tuesday, Jan. 23, 2024 from 2 p.m. – 3 p.m. ET. NABH Education and Research Foundation President Donald Parker, who serves as president of Behavioral Health Care Transformation Services for Hackensack Meridian Health, will co-lead the webinar with workforce consultant Beth Kuhn of Stonegate Strategies. Kuhn has more than 30 years of workforce experience – with special interest and expertise in behavioral healthcare workforce development – and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. Kuhn’s accomplishments include creating the Strategic Initiative for Transformation Employment, or SITE, a statewide model designed to bridge the gap between recovery and workforce participation for individuals active in their recovery from substance use issues. Throughout this interactive webinar, participants are encouraged to ask questions of Parker and Kuhn, who will provide an overview of existing behavioral healthcare workforce challenges; explain why America’s current workforce structure doesn’t meet present or future workforce needs; suggest redesign strategies, present examples of current successes; and offer ideas about how to leverage current options to help providers develop a more robust workforce system. The Foundation will also ask attendees poll questions during the hourlong webinar to gauge member interest in future workforce events and resources. Please join us and click here to register for this free webinar!

National Academies to Host Webinar on Behavioral Healthcare Provider Experience with Public Insurance Programs Next Week

The National Academies’ Committee on Strategies to Improve Access to Behavioral Health Care Services through Medicare and Medicaid will host a virtual webinar that discusses behavioral healthcare provider experiences with public insurance programs on Wednesday, Jan. 10. This webinar will examine the experiences of behavioral healthcare providers who accept Medicare, Medicaid, and Marketplace insurance and discuss what can be done to increase access to behavioral healthcare services for this patient population. Click here to register for the two-hour webinar, which starts at 2 p.m. ET next Wednesday.

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Save the Date for the NABH 2024 Annual Meeting!

Please mark your calendars and plan to join us at the Salamander Washington, DC from May 13-15, 2024 for this year’s NABH Annual Meeting!

Fact of the Week

A new study in Psychiatry Research suggests ethnoracial inequities in patient assignment to buildings that differed in clinical and physical conditions. Examining data from more than 18,000 unique patients during a period of six years, researchers said the findings serve as a call to action for hospital systems to examine the ways in which structural racism impact clinical care.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CEO Update 166

NABH Education and Research Foundation to Host Workforce Webinar in January

The NABH Education and Research Foundation is pleased to host its first webinar, Redesigning the Present and Future of Behavioral Healthcare, on Tuesday, Jan. 23, 2024 from 2 p.m. – 3 p.m. ET. Foundation President Donald Parker, who serves as president of Behavioral Health Care Transformation Services for Hackensack Meridian Health, will co-lead the webinar with workforce consultant Beth Kuhn of Stonegate Strategies. Kuhn has more than 30 years of workforce experience – with special interest and expertise in behavioral healthcare workforce development – and has served in both Democratic and Republican administrations, including in her roles as commissioner of the Kentucky Department of Workforce Investment and as Vermont’s director of workforce development. Kuhn’s accomplishments include creating the Strategic Initiative for Transformation Employment, or SITE, a statewide model designed to bridge the gap between recovery and workforce participation for individuals active in their recovery from substance use issues. During this interactive webinar, participants are encouraged to ask questions of Parker and Kuhn, who will provide an overview of existing behavioral healthcare workforce challenges; explain why America’s current workforce structure doesn’t meet present or future workforce needs; suggest redesign strategies, present examples of current successes; and offer ideas about how to leverage current options to help providers develop a more robust workforce system. Please join us and click here to register for this free webinar!

NABH 2024 Board Election Ballots Due Friday, Dec. 29!

NABH has e-mailed system members NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2024 Board. If you have not done so, please vote for the open Board Chair-Elect position and four available Board seats; sign the ballot (it is not valid without a signature); and return it to NABH. You can do this by scanning your completed ballot and e-mailing it nabh@nabh.org or maria@nabh.org. NABH must receive all ballots no later than Friday, Dec. 29, 2023. New Board members and the Board Chair-elect will take office in January 2024.

SAMHSA Releases Advisory on Implementing Low-Barrier Care to Expand Access and Improve Outcomes for Individuals with SUD

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released an advisory that outlines recommendations to implement low barrier models of care to significantly expand access to lifesaving treatment for individuals with substance use disorders (SUD). Despite evidence showing the effectiveness of SUD treatment, fewer than 10% of individuals who need care receive it. Barriers such as lack of treatment availability, strict program requirements, stigma, and discrimination. The advisory emphasizes the importance of low barrier care in overcoming substantial gaps in access to SUD treatment and engaging more people in care.

Reminder: NABH’s Enhanced Denial-of-Care Portal is Now Available

NABH thanks all members who have submitted data to the association’s Denial-of-Care Portal. You have provided critical information that expands the portal and helps NABH strengthen its advocacy efforts related to erroneous prior-authorization denials. With guidance from our members, NABH has improved the portal by adding two elements:
  1. Time-based data on the number of days between a request for coverage and a plan’s denial, which improves our ability to assess and compare health plan responsiveness.
  1. The gap between days of provided care versus days of covered care to quantify and compare uncompensated days per health plan.
We strongly encourage all NABH members to submit their denial-of-care data in the portal. If you need help starting, or if you have other questions, please e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

Save the Date for the NABH 2024 Annual Meeting!

Please mark your calendars and plan to join us at the Salamander Washington, DC from May 13-15, 2024 for next year’s NABH Annual Meeting!

Fact of the Week

The Centers for Disease Control and Prevention reports that while the provisional number of suicides in 2022 (49,449) was 3% higher than in 2021 (48,183), suicide rates for people in age groups 10–14, 15–24, and 25–34 declined 18%, 9%, and 2%, respectively, from 2021 to 2022.

Happy Holidays from NABH!

NABH will not publish CEO Update next week and will resume on Friday, Jan. 5, 2024. The entire NABH team 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.