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 119^th 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 119^th 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.

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.

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.

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.

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 118^th 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 118^th 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 119^th 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

Republican Wins Bring Changes to White House and Congress; Leadership Posts Pending

Former President Donald Trump’s re-election to office on Nov. 5 also led a strong Republican wave in both chambers of Congress, with Republicans winning control of the Senate and likely retaining a small majority in the House of Representatives.
 
Either party needs 218 seats to win the majority in the House; as of this writing, Republicans can claim 211 seats, Democrats can claim 199 seats, and 25 races are too close to call.
 
In the Senate, Democrats have 45 seats, Republicans have 53 seats, and two seats are still too close to call. Senate Veterans Affairs Committee Chairman Jon Tester (D-Mont.) lost his bid for reelection. Meanwhile, Senate HELP Committee members Sherrod Brown (D-Ohio) and Bob Casey (D-Pa) lost their bids for a fourth term, while Sen. Tammy Baldwin (D-Wis.) was narrowly reelected to her third term.
 
Congress will return Nov. 12 to develop a funding package for FY 2025, while the deadline to fund the federal government is Dec. 20. With the change in both the administration and Congress, it is likely that Congress will pass a short-term Continuing Resolution (CR) until the Spring when the 119^th Congress will establish funding priorities.
 
House Republican leadership elections are scheduled for next Wed., Nov 13. Speaker Mike Johnson (R-La.) and members of the House Republican leadership are seeking reelection to their respective posts. Meanwhile, Senate Republican leadership elections will also likely be held Nov. 13, with Sens. John Thune (S.D.), John Cornyn (Texas) and Rick Scott (Fla.) vying to replace Sen. Mitch McConnell (Ky.) as Majority Leader. Sen. John Barrasso (Wy.) is running unopposed for Majority Whip.
 
House Democratic leadership elections will likely be the week of Nov. 18, with all Members seeking to maintain their leadership posts, led by House Minority Leader Hakeem Jeffries (NY). Senate Democratic Leadership elections will likely be in early December, based on past practice. The only open job is retiring Sen. Debbie Stabenow’s (MI) position as chair of the Policy and Communications Committee.
 
NABH government relations staff will introduce NABH and our priority issues to incoming freshman Members of the House and Senate as the 119^th prepares to convene.

2025 Physician Payment Rule Finalizes Slight Increase to Psychiatrist Payments; Provides Some Telehealth Support

In its recently released physician fee schedule 2025 final rule, the Centers for Medicare & Medicaid Services (CMS) increased payments to psychiatrists by 1.0%, contrary to an overall negative update of 2.93% for physician payments relative to 2024 rates. Congressional discussions are expected to determine how to offset this overall drop, perhaps by year’s end or in early 2025.

Telehealth
With regard to telehealth measures in the rule, CMS phased out current flexibilities implemented during the COVID-19 pandemic, as required by federal law. However, NABH is pleased CMS made permanent certain telehealth flexibilities, including allowing some practitioners to provide two-way, real-time, audio-only communications when the patient is not capable of or does not consent to using video technology. In addition, the rule implements three digital therapeutics codes for the first time (G0552, G0553 and G0554) that fall under existing FDA authority, which pertain to initial telehealth care plan education for patients, the first 20-minute of treatment, and subsequent 20-minute treatments. The agency also finalized additions to the Medicare Telehealth Services List, including caregiver training services, patient counseling, and safety planning
 
Telehealth provisions that only apply to 2025 include continuing to permit distant-site practitioners to use their enrolled practice locations rather than a home address when providing telehealth services from their home. Also, treatment frequency limits will remain suspended in 2025.
 
Because Congress has not finalized an extension of pandemic-originating telehealth services, the rule rolls back major Medicare telehealth services to pre-pandemic levels. NABH notes there is broad bipartisan support for extending these services, with separate bills passing both House and Senate earlier this year, which could potentially lead to enactment by year’s end, although an extension remains uncertain. Given the broad support of this extension, if Congress passes telehealth legislation before year’s end, the agency could issue an interim final rule to restore this coverage, which could take effect immediately. The longer Congress takes to act, the less time CMS has to prepare and issue such a rule.
 
Crisis Care and Opioid Use Disorder (OUD) Provisions
The rule introduces new billing codes and telehealth services to improve the quality and access of opioid use disorder treatment. The rule also finalized new coding and payment rules for safety-planning interventions for patients in crisis. 

Physician Supervision
The final rule allows supervising physicians to provide guidance virtually through real-time audio and visual telehealth. This new definition of physician supervision for “incident to” services will be submitted by the physician using CPT code 99211. The code also pertains to telehealth supervision for outpatient evaluation and management of established patients who may not require another health care professional in the appointment.
 
CMS will continue to permit telehealth supervision of all other services furnished that require the direct supervision of the physician or other supervising practitioner through telehealth through 2025, when both the treatment and supervision are furnished virtually through, for example, a three-way telehealth visit.

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

Register Today for NABH’s Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar on Thursday, Nov. 14, 2024 to learn about using hospital data effectively in your negotiations with health plans.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare, who will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Register here for this hourlong webinar that will begin at 1 p.m. on Nov. 14. 

National Study Highlights MA Plans with High Numbers of Veteran Enrollment and Utilization

A new study published in Health Affairs found that veterans increasingly enrolled in Medicare Advantage (MA) plans between 2016 and 2022, including a growing number of MA plans in which 20% or more of the enrollees were veterans. 
 
According to the findings, about one in five Veterans Health Administration (VHA) enrollees in these high-veteran MA plans did not incur any Medicare services paid by MA within a given year—a rate 2.5 times that of VHA enrollees in other MA plans and 5.7 times that of the general MA population. Meanwhile, VHA enrollees in high-veteran MA plans were significantly more likely to receive VHA-funded care.
 
The study reported that in 2020, CMS paid more than $1.32 billion to MA plans for VHA enrollees who did not use any Medicare services, with 19.1% going to high-veteran MA plans.

Manatt to Host Webinar About State Medicaid Innovations to Addressing 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

In Appalachia, the seat of one of the earliest and deadliest waves of the opioid crisis, physicians at West Virginia University’s Rockefeller Neuroscience Institute are using focused ultrasound waves to reset the brain’s reward center, the nucleus accumbens. They hope the procedure can treat addictions ranging from drugs like opioids and methamphetamine to gambling and eating.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Deadline Extended: Please Submit Updated Member Information by Friday, Sept. 27!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

Last month NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use that link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

We have extended the deadline for members to submit changes to Friday, Sept. 27. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Mental Health Parity Final Rule Promises Meaningful Implementation of Groundbreaking Law

NABH is very pleased that the U.S. Health and Human Services (HHS), Labor (DOL) and Treasury Departments’ parity final rule released this week takes major steps toward meaningful implementation of true parity between behavioral and physical healthcare coverage.

Additional sub-regulatory guidance on how to execute the complex rule is pending, and the rule’s provisions will be implemented in a staged manner. Consequently, it will take some time before we can achieve actual parity nationwide and among countless health plans. Given this complexity, NABH, our members, and other partners will remain engaged with federal and state policymakers until the final rule provides meaningful parity protection.

The long-awaited rule lays the groundwork for more stringent compliance protocols and related definitions (noted below) to finally bring the Mental Health Parity and Addiction Equity Act to life 16 years after it was signed into law in October 2008. Responding to the 9,500 comments from stakeholders about the proposed parity rule released in July 2023, HHS, DOL and Treasury made some positive changes from their initial proposal in the final rule, which also reflects the concerns of health plans regarding the feasibility of some of the proposed rule’s recommendations.

In addition, many of the changes allow for closer alignment with existing federal statute, seemingly to acknowledge the risk of legal challenges to the final rule to align with the recent U.S. Supreme Court decision in Loper Bright Enterprises v. Raimondo, in which the High Court overturned the 40-year-old Chevron deference doctrine.

The rule affects group health plans and group or individual health insurance coverage that cover both behavioral and physical healthcare services. In general, the main focus of the rule is to require health plans to prepare comparative analyses that assess parity compliance of their non-quantitative treatment limitations (NQTLs), including specifying the mandatory components of these analyses, and a process for publicly sharing these reports. Examples of important NQTLs include:

• “Medical management standards (such as prior authorization) limiting or excluding benefits based on medical necessity or medical appropriateness, or based on whether the treatment is experimental or investigative,
• Formulary design for prescription drugs,
• For plans with multiple network tiers (such as preferred providers and participating providers), network tier design,
• Standards related to network composition, including but not limited to, standards for provider and facility admission to participate in a network or for continued network participation, including methods for determining reimbursement rates, credentialing standards, and procedures for ensuring the network includes an adequate number of each category of provider and facility to provide services under the plan or coverage, and
• Plan or issuer methods for determining out-of-network rates, such as allowed amounts; usual, customary, and reasonable charges; or application of other external benchmarks for out-of-network rates.”

A Data-driven Approach for Demonstrating NQTL Parity Compliance
The rule requires health plans to implement a data analysis plan to assess how each NQTL impacts access to mental health (MH)/substance use disorder (SUD) care, including whether each NQTL causes “material differences” in access. In the final rule, health plans will be allowed to consider “the terms of the NQTL at issue, the quality or limitations of the data, causal explanations and analyses, evidence as to the recurring or non-recurring nature of the results, and the magnitude of any disparities.” Using such analyses, NQTLs that are found to be parity non-compliant will not be implemented until they are compliant. The final rule also notes that NQTL oversight will be a collaborative process that includes working with health plans to find ways to address potential issues with compliance, rather than taking a strictly punitive approach.

Increased Compliance Transparency
Plans and issuers are required to provide all comparative analysis upon request to the three federal departments, states, and consumers experiencing treatment limitations. For self-insured employers, all beneficiaries are entitled to request the comparative analyses. These analyses must include:

• “a description of the NQTL,
• the identification and definition of the factors used to design or apply the NQTL,
• a description of how factors are used in the design or application of the NQTL,
• a demonstration of comparability and stringency, as written,
• a demonstration of comparability and stringency, in operation, and
• findings and conclusions.”

More Stringent NQTL Compliance Measures
NQTLs include prior authorization requirements and other medical management techniques, standards related to network composition, and methodologies to determine out-of-network reimbursement rates. The rule addresses these NQTL issues by:

• Reinforcing that health plans and issuers cannot use NQTLs that are more restrictive than those predominantly applied to physical health benefits in the same classification.
• Disallowing implementation of new NQTLs that do not meet parity standards.
• Specifying how insurers are to measure and report on their network composition, out-of-network reimbursement rates, and medical management and prior authorization NQTLs.
• Concerning the design of NQTLs, prohibiting discriminatory information, evidence, sources, or standards that systematically disfavor access to behavioral healthcare benefits as compared with physical health benefits.

Mitigating the Impact of Bias in NQTL Design
The final rule prohibits the use of “discriminatory factors and evidentiary standards” in designing a NQTL. Specifically, factors are considered discriminatory if, “based on all the relevant facts and circumstances, they systematically disfavor access or are specifically designed to disfavor access to mental health or substance use disorder benefits as compared to medical/surgical benefits.” For example, a seemingly neutral NQTL, but which is based on historical claims data not compliant with parity, would violate this provision of the final rule.

Generally Accepted Standards of Care (GASC)
Another important gain is the rule’s requirement that health plans explain any medical necessity standards that diverge from GASC. While the parity law does not require that medical necessity guidelines align with GASC, this new requirement will bring meaningful transparency and accountability to the process of creating these extremely effective guidelines.

Standardized “Substantially All,” “Treatment Limitations,” and Other Elements
When determining the treatment limits of a MH or SUD benefit, the parity test to compare the coverage with relevant physical health benefits should be applied to substantially all medical/surgical benefits in that classification. HHS, DOL, and Treasury included this approach in the final rule, rather than the proposed mathematical test for “substantially all” to implement a less cumbersome option.

The rule further defines “treatment limitations” as well as “processes, strategies, evidentiary standards, and other factors.” This provides greater clarity for compliance and eliminates potential loopholes. The rule also offers more specific examples of each, including specifying that the list of example non-quantitative treatment limitations (NQTLs) is meant to not be exhaustive. The final rule defines “treatment limitations” as: “Limits on benefits based on the frequency of treatment, number of visits, days of coverage, days in a waiting period, or other similar limits on the scope or duration of treatment. Treatment limitations include both quantitative treatment limitations, which are expressed numerically (such as 50 outpatient visits per year), and nonquantitative treatment limitations (such as standards related to network composition), which otherwise limit the scope or duration of benefits for treatment under a plan or coverage.”

Mandates Use of Standard Clinical Identifiers
In defining MH and SUD, the rule uses the International Classification of Diseases (ICD) and the Diagnostic and Statistical Manual of Mental Disorders (DSM), removing any non-clinical considerations from the definition. Importantly, this makes it clear that eating disorders and autism spectrum disorders fall within the definition of MH/SUD for parity compliance.

“Meaningful Benefits” Definition
To meet the mandatory “meaningful benefits” test, MH and SUD benefits will be compared with all benefits provided for physical health coverage in the same classification. This provision accommodates NABH’s request for a final definition that can mitigate future coverage disagreements among stakeholders, including plans, providers, auditors, and the courts. A meaningful benefit includes “a core treatment,” i.e., “a standard treatment or course of treatment, therapy, service, or intervention indicated by generally recognized independent standards of current medical practice.” This provides additional clarity about what is expected for coverage at every level of benefit under parity.

No “Network Adequacy” Guidance
The final rule does not include a special calculation for network adequacy, which the proposed rule suggested. In the discussion of the final rule, HHS, DOL and Treasury noted they responded to comments citing operational and legal concerns. The final rule also does not require a particular approach for analyzing data around network adequacy, such as reimbursement data.

Self-insured Employers
The final rule contains a number of considerations for self-insured employers in working with third-party administrators (TPAs) to help them achieve parity compliance with minimal additional burden. This includes considerations about how to engage TPAs in getting required data, as well as sharing compliance reporting obligations and liability for non-compliance. The federal departments also signaled interest in continuing to work with employers to ease the burden of compliance and improve coordination with TPAs.

Opt-out Option Removed
The rule amends the sunset provision to prevent opting out of compliance with MHPAEA, as required by law, after Dec. 29, 2022, with a June 27, 2023 deadline for certain plans that are subject to collective bargaining.

Effective Dates
The deadline to implement “the meaningful benefits standard, the prohibition on discriminatory factors and evidentiary standards, the relevant data evaluation requirements, and the related requirements in the provisions for comparative analyses” is Jan. 1, 2026.

For more details, please see the federal departments’ joint fact sheet and news release.

Senate Passes CBO Data Sharing Act

On Tuesday the Senate passed by unanimous consent bipartisan legislation that would allow the Congressional Budget Office (CBO) director to gain stronger authority to access sensitive healthcare data from federal agencies with fewer delays.

House Budget Committee Chairman Jodey Arrington (R-Texas) and ranking Democrat Brendan Boyle (Pa.) introduced the CBO Data Sharing Act (H.R.7032) in January. The legislation would give the CBO director the authority to request and receive information, including sensitive data, from federal agencies without lengthy negotiations or formal agreements, provided confidentiality is upheld. The bill also ensures that future laws cannot unintentionally restrict the CBO’s access to such data unless stated explicitly. The bill aims to prevent data-sharing roadblocks and ensure that Congress has more reliable information when considering changes to Medicare, Medicaid, and other public health policies.

The bill does not directly address the CBO’s interactions with federal health agencies; however, it is expected to have healthcare policy implications by helping the CBO overcome bureaucratic hurdles to secure essential health data and deliver faster, more accurate analyses of healthcare proposals.

As an example, the CBO released a 2023 report on proposals to modify or eliminate the Institutions for Mental Diseases (IMD) exclusion that limits Medicaid funding for inpatient care in psychiatric hospitals or other mental health facilities. To fully assess the potential impact of these proposals, the CBO requested detailed data from CMS on facilities meeting the IMD criteria. CMS denied the request, citing legal restrictions under the Public Health Service Act of 2000. Consequently, the CBO had to rely on less detailed public information, which limited the accuracy of its analysis. Had this bill been in place, the CBO could have bypassed that bureaucratic hurdle and provided Congress with more reliable data, according to the House Budget Committee’s bipartisan fact sheet about the legislation.

The House passed H.R. 7032 in April. The legislation now heads to the White House, where it is expected that President Biden will sign the bill into law.

ICYMI: Watch NABH’s World Suicide Prevention Day Webinar

NABH thanks all who joined us on Sept. 10 for our webinar that highlighted the 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH welcomed Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and
Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

If you missed it, please click here for the webinar’s recording; here for the presentation slides; and on the links below for some useful resources:

• The National Strategy for Suicide Prevention
• Recommended Standard Care for People with Suicide Risk
• Zero Suicide Toolkit
• Zero Suicide Institute
• 988 Lifeline

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

Mental health jobs are expected to grow three times the rate of all U.S. jobs in the next decade, according to a recent analysis of data from the U.S. Labor Department’s Bureau of Labor Statistics.

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

Reminder: Please Submit Updated Member Information by Next Friday, Sept. 13!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

Last month NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is next Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Former CDC Directors Caution that Paring Down Agency Could Cost Lives and Damage Economy

Eight former Centers for Disease Control and Prevention (CDC) directors penned an op-ed this week in STAT that warns cutting funding to the Atlanta-based public health agency could endanger lives and the U.S. economy.

“One misguided narrative is that the CDC should focus only on a ‘core mission’ of combatting infectious diseases,” wrote former directors William Foege, William Roper, Jeffrey Koplan, Julie Gerberding, Tom Frieden, Brenda Fitzgerald, Robert Redfield, and Rochelle Walensky, all of whom are physicians. “In fact, the core mission of the CDC is to save lives and protect Americans from all health threats — not only infectious diseases but also cancer, environmental risks, injuries, and the conditions that are the leading causes of death among Americans.”

They added that the CDC has helped save millions of lives through reduced tobacco and alcohol use, diabetes prevention and control, injury prevention including reducing traumatic brain injury, healthier pregnancies with lower maternal mortality, and other health-protection programs.

“Limiting our health defense to just some threats would be like allowing our military to protect us from only some types of attack, telling the National Weather Service to warn people about tornadoes but not hurricanes, or allowing doctors to treat only some diseases,” they continued.

The piece is a response to a Republican bill that would cut funding to the CDC by 22% and also to an op-ed earlier this year from Scott Gottlieb, M.D., former director of the U.S. Food and Drug Administration who now serves on the board of Pfizer.

September Issue of JAMA Pediatrics Includes Several Mental Health-Related Articles

NABH calls members’ attention the September edition of JAMA Pediatrics, which includes a number of articles focused on mental health.

Topics include healthcare needs and costs for children exposed to prenatal substance use, hospital admissions for eating disorders, mental health of transgender youth following gender identity milestones, and more.

September is National Recovery Month and Suicide Prevention Month

September is National Recovery Month, and the Substance Abuse and Mental Health Services Administration (SAMHSA) will commemorate the annual observance with a campaign focused on the four dimensions of recovery: health, home, purpose, and community.

Week One will emphasize health and will highlight choices that support well-being – such as eating a nutritious diet, exercising regularly, developing healthy sleeping habits, and managing other health issues –that can help support people with mental health and substance use conditions in their journey to recovery. Click here to access SAMHSA’s Recovery Month social media toolkit.

September is also Suicide Prevention Month, and SAMHSA has created a separate toolkit with hashtags and posts for the month and also World Suicide Prevention Day on Sept. 10 to remember the lives of those lost to suicide.

Reminder: Join NABH for World Suicide Prevention Day Webinar on Sept. 10

Please join NABH this coming Tuesday, Sept. 10, World Suicide Prevention Day, for a webinar that will feature two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH will welcome Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please click here to register for this hourlong webinar on Tuesday at 2 p.m. ET.

Join NABH for October Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar to learn about using hospital data to improve negotiations with health plans on Wednesday, Oct. 16, 2024.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. A member of NABH’s Managed Care Committee, Fox will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Fox has more than 25 years of senior leadership experience in the behavioral health sector. Prior to her current role, she served as the business development director at Peachford Hospital, a Universal Health Services facility. Fox earned her undergraduate degree from Michigan State University, where she received a dual degree in Communications and Spanish. She later earned a master’s degree in healthcare administration from Loyola University Chicago.

Please register here for this hourlong webinar on Wednesday, Oct. 16 starting at 2 p.m. ET. We hope you join us!

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

An analysis of provisional data from the National Institute on Drug Abuse found that between 2015 and 2023, there was a nearly five-fold increase in overdose deaths among non-Hispanic Black men 55 and older.

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

Reminder: Please Update Your Member Information for the 2024 NABH Membership Directory!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

NABH has e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

Legislative Preview: What to Expect from Congress This Fall 

Following their annual August recess and respective party conventions, federal lawmakers will return to Capitol Hill on Monday, Sept 9 to determine next steps for funding the federal government and provide stop-gap funding for veterans’ benefits.

The House and Senate will continue to attempt to pass appropriations bills funding various federal agencies before the Sept. 30 deadline. Both chambers have passed respective appropriations bills for Labor and HHS with vastly different funding levels, which likely won’t be reconciled before the deadline.

Numerous other agency funding bills are still pending. Congressional leaders are already having conversations about passing a Continuing Resolution (CR) to fund the government, which Congress will need to approve by Sept. 30 to stave off a government shutdown. The length of the CR will likely extend past the election or potentially after the 119 Congress takes office in January.

In addition, Congress will likely consider a $3 billion emergency aid bill that would cover veterans benefits and services as the Veterans Affairs Department (VA) warns of a nearly $14.9 billion shortfall through fiscal year 2025. A bipartisan group of appropriators and other senators intend to introduce legislation that would provide almost $2.3 billion in additional fiscal 2024 funding for the VA to cover compensation and pensions in the near term, along with almost $597 million for readjustment benefits. Without action from Congress by Sept. 20, the VA has warned it won’t be able to pay out roughly $3 billion in disability compensation, pension, and education benefits as early as Oct. 1. Because this is considered “must pass” legislation, Congress could attempt to add additional bills to this action.

Congress is expected to adjourn Sept. 27 after completing these tasks and return after the Nov. 5 elections. At that time, Congress will return to address unfinished business before the end of the year, commonly known as the “lame duck session.” Typically, most work during this session depends on which political party won majorities in the House and Senate during the November elections and whether there is a pending change in majority in either legislative chamber.

The outcome of the U.S. presidential race can also play a role in the level of activity during a lame duck session. Some congressional members might continue to push for an end-of-year health package, which could include reauthorizing the SUPPORT Act and a telehealth extension, among other priorities.

September is National Recovery Month and Suicide Prevention Month 

Next month marks National Recovery Month, and the Substance Abuse and Mental Health Services Administration (SAMHSA) will commemorate the annual observance with a campaign focused on the four dimensions of recovery: health, home, purpose, and community.

Week One will emphasize health and will highlight choices that support well-being – such as eating a nutritious diet, exercising regularly, developing healthy sleeping habits, and managing other health issues –that can help support people with mental health and substance use conditions in their journey to recovery. Click here to access SAMHSA’s Recovery Month social media toolkit.

September is also Suicide Prevention Month, and SAMHSA has created a separate toolkit with hashtags and posts for the month and also World Suicide Prevention Day on Sept. 10 to remember the lives of those lost to suicide.

Reminder: Join NABH for World Suicide Prevention Day Webinar on Sept. 10

Please join NABH on World Suicide Prevention Day, for a webinar that will feature two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

NABH will welcome Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please click here to register for this hourlong webinar on Tuesday, Sept. 10 at 2 p.m. ET.

HHS and DOJ to Host Webinar on Incarcerated Youth and Medicaid Next Week

HHS and the U.S. Justice Department (DOJ) will host a webinar next Tuesday, Aug. 27 that will highlight policy approaches designed to connect justice-involved youth with Medicaid and CHIP services.

In late July, the Centers for Medicare & Medicaid Services (CMS) sent a letter to state health officials that addressed the statutory requirements in the Consolidated Appropriations Act, 2023 regarding the availability of certain state plan services for incarcerated youth in Medicaid and the Children’s Health Insurance Program (CHIP) and modification of CHIP eligibility requirements for children who become incarcerated in juvenile or adult corrections systems.

During this webinar, HHS and DOJ leadership and subject matter experts will discuss how this opportunity will help advance health equity and build healthier and safer communities.
Click here to register for the webinar that will start at 2 p.m. ET.

SAMHSA Offers On-Demand Module on Motivational Interviewing Strategies for AUD

SAMHSA is offering an on-demand module to help physicians, physician associates, nurses, social workers, and other healthcare professionals learn how to use Motivational Interviewing strategies as a guided approach to clinical interactions and fostering behavior change in patients with alcohol use disorder.

SAMHSA’s PCSS-MAUD Motivational Interviewing for Alcohol Use Disorder Treatment is a self-paced training program that addresses the Accreditation Council for Graduate Medical Education competencies of patient care, medical-based knowledge, and practice-based learning.

National Academies Examines Strategies to Improve Behavioral Healthcare Access in Medicare and Medicaid

The National Academies has released Expanding Behavioral Healthcare Workforce Participation Through Medicare, Medicaid, and Marketplace Plans, a new resource it developed after SAMHSA and CMS asked the not-for-profit institutions t convene a committee that would examine current challenges in ensuring broad access to evidence-based behavioral healthcare services through Medicare, Medicaid, and Marketplace programs—and propose strategies to address those challenges.

“Barriers to obtaining behavioral health treatment are most evident in populations receiving Medicare, Medicaid, and Marketplace plans,” the National Academies wrote in its description of the new resource. “Behavioral healthcare providers serving individuals enrolled in these plans are more likely to experience challenges around reimbursement and training, which disincentivizes participation.”

Join NABH for October Webinar on Using Publicly Available Data in Health Plan Negotiations

Please join NABH for a webinar to learn about using hospital data effectively in your negotiations with health plans on Wednesday, Oct. 16, 2024.

The webinar will feature Erica K. Fox, M.B.A., vice president of business development and managed care contracting at Perimeter Healthcare. A member of NABH’s Managed Care Committee, Fox will review the use of publicly available data from hospitals, such as payer-specific negotiated rates and standard charges for all payers and plans, to negotiate contracts with health plans.

Fox has more than 25 years of senior leadership experience in the behavioral health sector. Prior to her current role, she served as the business development director at Peachford Hospital, a Universal Health Services facility. Fox earned her undergraduate degree from Michigan State University, where she received a dual degree in Communications and Spanish. She later earned a master’s degree in healthcare administration from Loyola University Chicago.

Please register here for this hourlong webinar on Wednesday, Oct. 16 starting at 2 p.m. ET. We hope you join us!

Reminder: 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

The National Institutes of Health announced it has launched a program to advance research that will support Native American communities to lead research to address overdose, substance use, and pain, including factors such as mental health and wellness.

NABH will not publish CEO Update next Friday, Aug. 30. The NABH staff wishes you, your teams, and your families a safe and happy Labor Day weekend next week! CEO Update will resume on Friday, Sept. 6.

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

Please Update Your Member Information for the 2024 NABH Membership Directory!

NABH is developing its online-only 2024 Membership Directory, an essential member benefit that helps the association in its advocacy efforts.

This week NABH e-mailed system members a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information.

The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our membership.

The deadline to submit your changes to NABH is Friday, Sept. 13. If you need assistance, please contact Maria Merlie maria@nabh.org or 202-393-6700, ext. 104.

As always, thank you for your time and for all you do to advance NABH’s Mission and Vision!

HRSA Social Worker Licensure Compact Seeks to Increase Behavioral Healthcare Access and Enhance Telehealth Services

The Health Resources and Services Administration (HRSA) announced recently its first Licensure Portability Grant Program investment in a multi-state social worker licensure compact.

According to HRSA, state licensure compacts allow states to agree on a common approach to licensing health care providers, allowing providers to practice across state lines without having to apply for a license in each state. Streamlining licensure while maintaining quality standards improves access to services both by better facilitating hiring and by easing pathways to utilizing telehealth. HRSA made the announcement at its National Telehealth Conference last month.

“Social workers are essential to expanding access to behavioral health care services, a top priority of the Biden-Harris administration,” HHS Deputy Secretary Andrea Palm said in a statement. “HRSA is leading the way in growing the behavioral health workforce both by training more providers and by breaking down barriers to allow the workforce to make mental health and substance use disorder services more accessible across the country,” she added.

Click here to see the grant program awardees.

Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

 Reminder: 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

According to a Pew Charitable Trusts fact sheet released this week, more than 10.2 million people ages 12 and older misused stimulants – which includes cocaine, prescription stimulants for ADHD and methamphetamine – in 2022. This reflects a nearly 9% increase from 2021.

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

Contingency Management Battles Ongoing Headwinds

Earlier this week, a STAT news article reviewed the executive branch’s response to advocacy efforts to expand financing for the only evidence-based treatment for stimulant use disorder, contingency management (CM.)  CM provides financial rewards for abstinence from stimulants and has decades of research demonstrating that intervention changes the reward centers of the brain, resulting in behavior change. There are no medications for stimulant use disorders.

Currently, the Substance Abuse and Mental Health Services Administration limits CM rewards to $75, which is too low for effective treatment. In addition, members of Congress have confused CM treatment with harm reduction and made the treatment a highly charged political issue. Speaking on behalf of NABH, Sarah Wattenberg, director of quality and addiction services, stated, “I understand their political concerns, but sometimes you just have to bite the bullet.” She continued, “Too many people are dying, and we need to act now.”

Reminder: Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar this month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: 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

A recent JAMA study found that between Jan. 2010 and Dec. 2021, 60% of youth who lost their lives to suicide lacked mental health diagnoses. This study’s findings highlight the importance of “…equitable access to MH screening, diagnosis, and treatment for all youths. “

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

CMS Finalizes 2.5% IPF Payment Increase and Payment System Reforms

The Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2025 final rule on the inpatient psychiatric facility prospective payment system (IPF PPS) implements a net increase of 2.5 percentage points. The overall update of $65 million, compared with FY 2024 payment levels, represents a slight decrease from the proposed 2.6 percentage point increase.

This update includes a market basket increase of 3.3 percentage points that is offset by a 0.5 percentage point for productivity. In addition, to maintain the mandated outlier pool of 2.0% of total payments, CMS finalized an outlier payment reduction of 0.3 percentage point to stay within this target, which reduces the number of cases that will qualify for an outlier payment.

CMS also finalized several adjustments to ensure that the PPS design and other changes discussed below are implemented in a budget-neutral manner. Due to these adjustments, the base per diem rate will be reduced to $876.53 from $895.63.

All-Inclusive Reporting
NABH is extremely disappointed that CMS finalized a significant narrowing of its all-inclusive reporting policy, which will take effect for upcoming cost reporting periods. Current policy allows IPFs to use an alternative methodology for reporting ancillary charges on cost reports. The final rule restricts this reporting option for ancillary charges only to Indian Health Service (IHS) hospitals, tribally owned and government-owned psychiatric, and acute care hospitals. CMS overlooked NABH’s strong caution that for many “all-inclusive IPFs,” significant administrative, timing and cost considerations will make impossible a timely transition to this change.

Under the finalized timing framework, CMS contractors will begin assessing compliance with the change through a look-back process that begins following the completion of a provider’s upcoming cost-reporting period that begins on or after Oct. 1, 2024. Specifically, all IPFs will be required to have a charge structure that allows the reporting of ancillary costs and charges on their cost reports for all ancillary services and correlating charges, such as labs and drugs.

With this change, IPFs that are currently in the all-inclusive category now will have their cost reports included in the annual IPF PPS update that CMS calculates. Because CMS calculates the annual update using the sum of routine and ancillary costs, in prior years the agency has removed from the calculation the all-inclusive IPFs, as their cost reports lack data on ancillary services. The final rule notes that in 2018, because of this exclusion, 82,491 (out of 364,080 total stays) were removed from the update calculation. CMS acknowledges that this exclusion has been producing skewed updates that do not represent the costs of the entire IPF field, with approximately 55 percent of stays from freestanding all-inclusive facilities removed in 2018, and 0.3 percent of stays from all-inclusive psychiatric units.

In response to feedback that all-inclusive IPFs are providing full and clinically-appropriate services and that the absence of ancillary charges on cost reports is due to gained cost efficiencies, CMS said it “believe[s that] IPFs are providing these necessary services to patients.” The agency added:  “…maintaining an accurate charge structure would be part of a business’s accounting for reordering and restocking pharmaceuticals at a minimum, as well as more accurate payment for the purposes of outlier payments.”

Payment Increase for Electroconvulsive Therapy
For FY 2025, to achieve some alignment with outpatient rates, CMS finalized the proposed 71 percent increase for ECT payment per treatment from the current rate of $385.58 to $661.52.

IPF PPS Modifications
As mandated by Congress, CMS reviewed key IPF PPS elements with a focus on facility and patient-level adjustments, and in this rule finalizes multiple, relatively modest changes. While the agency is maintaining the rural and teaching facility adjustments, as is, the rule finalizes multiple budget-neutral changes to the structure of the PPS. As shown in Tables 4 and 5 in the rule, CMS finalized these changes:

• Added DRGs 917 (Poisoning and toxic effects of drugs w MCC) and 918 (Poisoning and toxic effects of drugs w/out MCC).
• Replaced 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.
• Removed 2 DRGs: DRG 887 (Other mental disorder diagnoses) and DRG 896 (Alcohol, Drug Abuse or Dependence w/out rehab therapy w MCC).
• Multiple changes to comorbidity payment add-ons were finalized as shown in Table 10.

IPF Quality Reporting Program
As proposed, the final rule implements one new measure: the 30-Day Risk-Standardized All-Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge. In response to concerns raised through public comments that its implementation may not be feasible, CMS did not finalize the proposed requirement for IPFs to submit patient-level quality data every quarter (versus the current annual basis).

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

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Senate Passes Kids Online Safety and Privacy Act

The Senate on July 30 voted 91-3 to pass the Kids Online Safety and Privacy Act (KOPSA), a combination of the Kids Online Safety Act and the Children and Teens’ Online Privacy Protection Act. The bill would for the first time make social companies such as Facebook and TikTok responsible for the ill effects of design features that recommend content and encourage engagement.

KOPSA prescribes that technology companies must limit the amount of data they collect on children under 17; not target minors with advertising; give children the highest privacy settings by default; offer the ability to opt out of various design features like content recommendations and engagement nudges; and have an independent third party audit their platforms for potential harm to children; among other provisions.

Recent developments have increased pressure on Congress to pass a bill protecting online safety and privacy. Several states have passed social media and privacy laws aimed at mitigating youth harms. And in June, U.S. Surgeon General Vivek Murthy called for social media platforms to come with warning labels.

Technology companies and free speech advocates staunchly oppose the bill, which is expected to face certain legal challenges if it becomes law. Grassroots organizations alarmed by child suicide have pushed for the federal legislation, and have helped to enact laws in California, Colorado, Connecticut, Maryland, and New York meant to regulate social media for minors.

House companion bills are awaiting committee action, with House Energy and Commerce Chair Cathy McMorris Rodgers (R-Wash.) planning a vote this Fall. House Leadership has also signaled interest in the measures and there is bipartisan support for them.

Passing this legislation would be the first major regulation in years to alter how large technology companies interact with children on their platforms.

SAMHSA Releases 2023 National Survey on Drug Use and Health

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released key findings from the 2023 National Survey on Drug Use and Health (NSDUH).

Conducted by the federal government since 1971, the NSDUH is a primary source of statistical information on self-reported substance use and mental health of the U.S. civilian, noninstitutionalized population 12 or older. Estimates are presented by age group and by race/ethnicity for selected measures.

ASAM Past President Stuart Gitlow Pens Op-Ed on Cannabis Re-Scheduling

Stuart Gitlow, M.D., M.P.H., M.B.A., DFAPA, DFASAM, past president of the American Society of Addiction Medicine, penned an Op-Ed in ASAM Weekly in response to a proposal by the U.S. Justice Department to reschedule marijuana from Schedule I to Schedule III.

Currently, marijuana is illegal at the federal level, while many states have implemented decriminalization and legalization initiatives. This creates a difficult position for physicians (among others, such as dispensaries) who might recommend or fill out state-required forms for medical marijuana.

In his opinion piece, Gitlow argued that this would not change under rescheduling. Additionally, rescheduling would not decriminalize or legalize marijuana use. He also wrote there has not been sufficient research confirming any “true medical utility” of marijuana, whereas there is an understanding that the plant has addictive potential and impacts public health negatively.

Join NABH Sept. 10 for Webinar on the 2024 National Strategy for Suicide Prevention

Please help NABH recognize World Suicide Prevention Day on Tuesday, Sept. 10, 2024 by joining us for a webinar featuring two experts who will highlight HHS’ 2024 National Strategy for Suicide Prevention, a 10-year, comprehensive, societal approach to suicide prevention that provides concrete recommendations for addressing gaps in the suicide-prevention field.

The webinar will feature Julie Goldstein Grumet, Ph.D., vice president of suicide prevention strategy at the Education Development Center (EDC) and director of the EDC’s Zero Suicide Institute; and Colleen Carr, M.P.H., director of the National Action Alliance for Suicide Prevention.

Grumet and Carr will discuss the core strategic directions of the National Strategy; provide context on how these goals fit into current efforts by health systems, providers, and their partners in the field; highlight opportunities to support National Strategy implementation efforts; and what to expect – as well as how to engage – as the new strategy rolls out.

The discussion will also include an overview of key NABH priorities reflected in the new strategy, including workplace violence prevention and current efforts to protect and advance workforce wellbeing, including suicide prevention.

Please register here for this hourlong webinar on Tuesday, Sept. 10 webinar that starts at 2 p.m. ET. I hope you join us!

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

ICYMI: CMS Shares Discusses EMTALA and Behavioral Health in ACEP Podcast

CMS participated in the American College of Emergency Physicians’ ACEP Frontline podcast to discuss the Emergency Medical Treatment & Labor Act (EMTALA) and behavioral health.

The podcast describes how behavioral health conditions and physical health conditions are considered similarly from the standpoint of EMTALA.

Reminder: 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

NBC News reported recently that athletes prioritized their mental health ahead of the Summer 2024 Olympic Games that opened in Paris a week ago.

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

House Passes Bill to Reauthorize Child Welfare Programs Included RTF Provision

The House Ways and Means Committee on Thursday passed unanimously H.R. 9076, the Bipartisan Protecting America’s Children by Strengthening Families Act, to reauthorize and reform the nation’s child welfare programs under Title IV-B of the Social Security Act. Authorization for these programs expired in fiscal year 2021, and there have been no serious reforms since 2008.

Introduced by Reps. Darin LaHood (R-Ill.) and Danny Davis (D-Ill.), H.R. 9076 focuses mainly on America’s child foster care system and also includes a provision titled Improving Data Collection and Reporting for Youth in Residential Treatment Programs.

The language directs HHS and other agencies to update guidance to state agencies in administering state plans approved under parts B and E of title IV of the Social Security Act on a) best practices for federal and state agencies to collect data and share information related to the well-being of youth residing in residential treatment facilities, including those facilities operating in multiple states or serving out-of-state youth; b) best practices on improving state collection and sharing of data related to incidences of maltreatment of youth residing in residential treatment facilities, including with respect to meeting the requirement of section 471(a)(9)(A) of such Act for such youth in foster care; and c) best practices on improving oversight of youth residential programs receiving federal funding and research-based strategies for risk assessment related to the health, safety, and well-being of youth in the facilities.

The House Ways and Means Committee’s passage of this legislation follows the influential panel’s hearing last month about child welfare programs, which included testimony from Paris Hilton, who supported H.R. 2955, The Stop Institutional Child Abuse Act, aspects of which were incorporated into the data collection and reporting Section of H.R. 9076.

The next step would be for H.R. 9076 to move to the House floor for a vote; however, it’s unclear whether the House will consider the legislation. It’ also unknown if the Senate will consider the bill or consider similar legislation.

NABH will continue to monitor any congressional action related to H.R. 9076

HHS Streamlines Technology, Cybersecurity, and AI Functions Under ONC

HHS on Thursday announced a reorganization to streamline and strengthen its technology, cybersecurity, data, and AI strategy and policy functions.

Under the restructured format, the Office of the National Coordinator for Health Information Technology, or ONC, will be renamed the Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology, or ASTP/ONC. All oversight of technology, data, and AI policy and strategy will move from its current structure under the Assistant Secretary for Administration to ASTP/ONC, including the HHS-wide roles of chief technology officer, chief data officer, and chief AI officer.

In addition, the public-private effort between the health sector and the federal government on cybersecurity (“405(d) Program”) will move from ASA to the Assistant Secretary for Strategic Preparedness and Response, or ASPR, joining the other health sector cybersecurity activities already located in ASPR’s Office of Critical Infrastructure Protection.

Biden Administration Awards $45.1 Million to Expand Mental Health and Substance Use Services

The Biden administration this week announced grant awards totaling $45.1 million – including $15.3 million specifically for children and youth– to expand mental health and substance use services.

The youth funding will go toward supporting their mental health in school settings; serving children and families who have experienced traumatic events and grief; and providing services specific to young people of transitional ages who are at risk for or have serious mental health conditions.

“Be it fostering wellness in young people, caring for the unhoused, facilitating treatment and more, this funding directly supports the needs of our neighbors,” HHS Secretary Xavier Becerra said in an announcement about the funding. “These investments will empower communities to implement effective solutions that promote long-term healing and resilience.”

Click here to read about the various grant awards and access links to apply.

NABH Seeks Member Feedback on CMS’ 2025 PFS and OPPS Proposed Rules

NABH seeks member feedback on the Centers for Medicare & Medicaid Services’ (CMS) proposed 2025 Physician Fee Schedule rule and 2024 Outpatient Prospective Payment System  rule.

To weigh in, please begin by reviewing the regulations and NABH’s recent 2025 Physician Fee Schedule and 2025 Outpatient Prospective Payment System alerts to help NABH staff identify the priorities we should address with CMS, such as payment, impact on patients and quality, or operational challenges.

Please email your comments to Rochelle Archuleta by Friday, Aug. 9. Comments for both rules are due to CMS by Monday, Sept. 9.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: 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

A new poll from the National Alliance on Mental Illness found 82% of Americans are still not familiar with 988, the lifeline that helps people in mental health, substance use, and suicide crises get connected to support services.

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

FDA & FTC Issue Warnings to Crack Down on Illegal Sales of Food Products with Delta-8 THC

The Food and Drug Administration (FDA) and the Federal Trade Commission this week issued warnings to five companies to crack down on illegal sales of food products containing delta-8 THC.

The products’ packaging resemble familiar snacks and candies, potentially leading to accidental ingestion or overconsumption. The agencies are especially concerned about the appeal to children and potential impurities or unpredictable effects from processes used to synthesize delta-8 THC, the psychoactive cannabinoid from the Cannabis sativa plant.

The companies have 15 working days to submit written responses detailing how they will address these violations and prevent future ones. If the violations are not addressed promptly, the agency may take legal action.

From Jan. 1, 2021, to Dec. 31, 2023, the FDA received more than 300 adverse event reports involving children and adults who consumed delta-8 THC products. In response, the agency issued a warning to customers in June 2022. Meanwhile, between Jan. 1, 2021, and May 31, 2022, national poison control centers handled 10,448 single substance exposure cases involving edible products containing THC, 77% of them for people 19 or younger. 

Adverse effects can include hallucinations, vomiting, tremor, anxiety, dizziness, confusion and loss of consciousness, the agency said.

Joint Commission’s Revised Guidelines for Restraint and Seclusion to Begin Next Year

The Joint Commission has announced new and revised requirements will apply to behavioral healthcare and human services organizations that use restraint and/or seclusion starting on Jan 1, 2025.

The changes include revising the definition of restraint; reducing redundancies; streamlining processes; and removing requirements for physical holding of a child or youth and incorporating this concept into the requirements for restraint and seclusion because physical holding that restricts freedom of movement is a type of restraint.

Click here to learn more.

DEA Rule on Telehealth Slated for September

The Drug Enforcement Administration is expected to issue its highly anticipated telehealth prescribing rule in September, according to an article in Inside Telehealth, an Inside Health Policy publication.

“A last-minute title change of the proposed rule may indicate that the registration could allow for prescribing controlled substances across state lines, sources say,” the article noted.

The article also said the rule’s title was updated to “Special Registrations for Telemedicine and Limited State Telemedicine Registration,” according to DEA’s spring regulatory agenda published July 5.

NIH Study: Doctors Reluctant to Treat Addiction Report Lack of Support as Barrier

A new National Institutes of Health study found “instiutional environment” as the most frequently reported reason why physicians are reluctant to intervene in addiction treatment.

“Institutional environment” refers to factors such as lack of support from a physician’s institution or employer; insufficient resources, such as staff and training; challenges in organizational culture; and competing demands. This reason for reluctance was cited in 81% of the studies reviewed, followed by insufficient skill (74%), lack of cognitive capacity to manage a certain level of care (74%), and inadequate knowledge (72%).

Meanwhile, about 66% of studies cited negative social influences – or beliefs about public and community acceptance of addiction care – while 56% of studies cited fear of harming the patient-physician relationship as deterrents for physicians to intervene in addiction.

The study’s findings highlighted the need for institution-wide changes to improve the adoption of evidence-based substance use disorder treatment practices among physicians, such as increasing organizational support, leadership and staff buy-in, and education and training.

Kaiser Family Foundation to Host ‘Beyond Chevron: How the SCOTUS Decision will Affect Healthcare Policy Decisionmaking’ Webinar Next Week

The Kaiser Family Foundation (KFF) will host a webinar next week to discuss the potential challenges stemming from the U.S. Supreme Court’s decision on June 28 to overturn the Chevron precedent that required federal courts to defer to reasonable agency decisions when federal law is unclear.

Moderated by  KFF Executive Vice President for Health Policy Larry Levitt, the discussion will address questions such as: How will the decision change how regulators approach drafting new regulations? What type of health policy regulations are likely to be most vulnerable to future court challenges? How will it alter the legislative process and the ability to pass new laws? And to what extent will Congress be able to provide greater specificity in delegating authority to federal agencies in future legislation?

The 45-minute webinar will be held on Thursday, July 25 at Noon ET. Click here to register.

Behavioral Health Business to Examine ‘How AI is Making Healthcare More Human’ in August Webinar

The publication Behavioral Health Business will host a webinar next month to explore how AI could potentially enhance humanity in behavioral health.

The discussion will examine how AI could extend to underserved communities, improve patient outcomes, and increase both clinician and patient satisfaction.

It also promises to highlight new research involving 130,000 patients that shows people are significantly more likely to begin therapy when their experience starts with Limbic, an AI-powered clinical assessment, with the most positive effects observed among minority groups.

The webinar will be held Thursday, Aug. 22 at Noon ET. Click here to register.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: 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

Early population estimates from the Centers for Disease Control and Prevention (CDC) show that around 7% of the entire U.S. adult population reported having Long COVID in 2022. “Some of the most common mental health conditions associated with Long COVID include fatigue, sleep disturbances, depression, anxiety, psychosis, cognitive impairment, obsessive-compulsive disorder, and posttraumatic stress disorder,” the Substance Abuse and Mental Health Services Administration (SAMHSA) reported recently. “Both COVID-19 and Long COVID can result in new onset of behavioral health conditions in those who have not previously reported these conditions, and aggravate complications for those with pre-existing mental health conditions and substance use disorders.”

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

FDA Releases Guidance on Constructing Effective Clinical Trials for Devices

The FDA on Thursday issued guidance about constructing effective clinical trials to develop medical devices that treat patients who misuse opioids.

The new guidance is intended to improve both the design and development of clinical studies to provide a reasonable assurance of safety and effectiveness for a device intended to treat OUD. Challenges in developing OUD device studies include inaccurate patients report of drug use, high rates of missing data, and confounding effects of concomitant drug treatments.

The guidance is not legally enforceable.

CMS Updates IOP and PHP Payment Rates for 2025

The Centers for Medicare & Medicaid Services (CMS) this week issued its calendar year (CY) 2025 Medicare hospital outpatient prospective payment system (OPPS) proposed rule, which proposes a net increase of 2.3 percentage points, relative to current year rates. The net update reflects a market basket increase of 3.0 percentage points and the statutorily required 0.4 percentage point cut, along with several budget neutrality adjustments and a minor increase in outlier payments.

The proposed update would apply to services paid under the OPPS, intensive outpatient programs (IOP), partial hospitalization programs (PHP), community mental health centers (CMHCs), opioid use disorder (OUD) treatments in an IOP, and other settings.

In addition to other items, the proposed rule addresses the behavioral healthcare provisions summarized below and lists in Table 68 the eight proposed ambulatory payment classification (APC) per diems for IOPs and PHPs that are set according to the number of services provided per day.

IOPs
For the IOP benefit established last year, the current dual-rate, per-diem structure would be maintained: one rate for days with three services and another rate for days with four or more services. In general, the structure of the IOP mirrors the design of the PHP, including provisions on coding, billing, and payment policies.

The rule defines IOPs as distinct and organized outpatient programs of psychiatric services provided for individuals who have an acute mental illness or substance use disorder, consisting of a specified group of behavioral health services paid on a per-diem basis for a minimum of nine hours of IOP services per week, or other payment system.

Opioid Treatment Program (OTP) Payment Add-On
For the new OPPS coverage of OUD treatments that OTPs provide, CMS would maintain the payment add-on of three times the payment rate for APC 5861 (intensive outpatient of three services per day) for hospital-based IOPs.

FQHCs and RHCs
The annual payment update for IOP services provided by federally qualified health centers and rural health clinics will be addressed in the pending physician fee schedule proposed rule for CY 2025.

PHPs
For PHPs, services provided in hospital outpatient departments and CMHCs, CMS proposes to maintain the current payment structure, which sets reimbursements based on whether a patient receives three services versus four or more services per day. PHPs are intensive, structured outpatient programs that are alternatives to psychiatric hospitalization, consisting of a specified group of mental health services paid on a per-diem basis for a minimum of 20 hours of PHP services per week, based on per diem costs.

Access to Non-Opioid Treatments for Pain Relief
As mandated by Congress, CMS is proposing temporary add-on payments for certain non-opioid treatments for pain relief. This complex provision would take effect from Jan. 1, 2025 through Dec. 31, 2027, and would require certain clinical evidence for medical devices and FDA-approved indications for pain management. The payment add-on would be capped at the estimated average of 18% of the full OPPS payment, calculated using the top five procedures by volume for each drug or device. Table 84 in the rule lists the proposed seven injections and other items that would qualify for a payment add-on under this provision.

CMS will accept comments on this rule through Sept 9. See the agency’s related fact sheet for more information.

CMS’ Proposed 2025 PFS Rule Would Cut Overall Payments by 2.8%

In its proposed rule  for the calendar year (CY) 2025 physician fee schedule, the Centers for Medicare & Medicaid Services on Wednesday recommended reducing the conversion factor by 2.8% to $32.36 in CY 2025, compared with $33.29 in CY 2024. This change reflects the expired 2.93% statutory payment increase for CY 2024; a 0.00% conversion factor update under the Medicare Access and Children’s Health Insurance Program Reauthorization Act; and a .05% budget-neutrality adjustment.

Proposed New Behavioral Healthcare Services
The lengthy rule includes these proposals to improve payment for and access to behavioral healthcare services:

• For people determined to have elevated suicide or overdose risk, a new payment for safety planning interventions and post-discharge follow-up contacts;
• New digital tools payment for:
  • Post-discharge telephonic follow-up;
  • Software devices that treat a mental health condition in conjunction with ongoing treatment; and
• Extending evaluation and management services payment to allow clinical psychologists, clinical social workers, marriage and family therapists, and mental health counselors to conduct interprofessional consultations among themselves, as well with psychiatrists and other physicians.

Proposed Payment Updates by Specialty
Table 128 in the proposed rule lists these and other proposed updates by specialty:

• +3.0% for clinical psychologists;
• +1.0% for psychiatrists;
• +4.0% for clinical social workers;
• +1.0% for family practice physicians;
• +1.0% for internal medicine physicians; and
• No change for nurse practitioners.

Opioid Treatment Programs (OTPs)

Telehealth Extended for Methadone Treatment
Regarding methadone treatments, CMS proposes extending current telehealth flexibilities permanently for periodic assessments and initiation of treatment. For beneficiaries lacking permanent access to two-way audio-video communications technology, CMS would allow periodic assessments to be furnished via audio-only communications when applicable requirements are met. To support this proposal, CMS cites evidence that audio-only visits produce many of the same benefits as video-based visits. The rule also notes that this provision would advance the agency’s health equity goals.

For initiation of treatment with methadone for any new patient, audio-visual telehealth may be used if an OTP can conduct an adequate evaluation of the patient. Audio-only telehealth is not permitted. Such telehealth evaluations would use OTP intake add-on code (HCPCS code G2076) and must comply with the Drug Enforcement Administration, the Substance Abuse and Mental Health Services Administration (SAMHSA), and other requirements. These OTP provisions also are intended to align with SAMHSA’s goals for reducing barriers to access.

Payment for Patient Intakes
The rule proposes payment updates for intake activities (HCPCS code G2076) by OTPs, which align with recent SAMHSA reforms to advance patient-centered and evidence-based paradigms of care for Opioid Use Disorder (OUD) treatments such as harm-reduction interventions and recovery support services. Specifically, the rule would implement payment for social determinants of health risk assessments (HCPCS code G0136) to identify unmet health-related social needs or the need for OUD-related harm-reduction interventions and recovery support services. In addition, CMS seeks feedback on how OTPs currently coordinate care and make referrals to community-based organizations that address unmet Health Related Social Needs (HRSNs), provide harm-reduction services, and/or offer recovery support services.

Opioid Agonist and Antagonist Medications
CMS proposes to establish payment for new opioid agonist and antagonist medications that the U.S. Food and Drug Administration approved recently. Specifically, the rule would create a new add-on code to the bundled payment to reflect take-home supplies for nalmefene hydrochloride (nalmefene) nasal spray (Opvee®). The agency also proposes paying for a new extended-release injectable buprenorphine product (Brixadi®), indicated to treat moderate to severe OUD using a new weekly bundled payment code to reflect the weekly formulation of Brixadi®. In addition, the rule would update payment for the existing bundled payment for monthly injectable buprenorphine (HCPCS G2069) in order to reflect payment for the monthly formulation of Brixadi®. CMS’ goals for these changes are to help prevent additional opioid overdose deaths, reduce illicit opioid use, and retain more individuals with an OUD in treatment.

Billing Clarification
The rule also clarifies that for billing, an OUD diagnosis code is required on claims submitted under the Medicare OTP benefit, which helps ensure that payments for Part B OTP services are for the treatment of OUD.

Additional Telehealth Proposals
Permanent Expansion of Audio-only Telehealth
CMS proposes to permanently expand the allowable forms of telehealth “interactive telecommunications systems” to include audio-only communication technology if the patient is not capable of, or does not consent to, the use of video technology.

Temporary Telehealth Expansions
In addition, CMS is proposing temporary changes for the use of audio-visual (not audio-only) telehealth for the purpose of physician/practitioner supervision. Specifically, the rule would expand through CY 2025 the allowance for supervising practitioners to be “immediately available” through audio-visual telehealth. In addition, for CY 2025 only, teaching physicians could continue to supervise audio-visual telehealth services furnished by residents in all teaching settings, such as through a 3-way telehealth visit. Also for CY 2025, the agency will continue to permit physicians to use their currently enrolled practice location instead of their home address when providing telehealth services from home.

The rule also extends through CY 2025 the pandemic-originating coverage of telehealth services provided by federally qualified health centers and rural health clinics. This extension also includes the waiver allowing for reporting of enrolled practice addresses, rather than home addresses, when providers perform services from their home, and the waiver for virtual supervision for residents in all teaching settings when the services are provided virtually.

NABH is displeased that beginning Jan. 1, 2025 – in compliance with federal law – the rule repeals crucial telehealth flexibilities that would subject most digital care to pre-pandemic regulations.

Permanent Audio-visual Telehealth for Low-Risk Services
For services furnished after December 2025, CMS proposes that physician/practitioner oversight via audio-visual telehealth shall be limited to services that are “low risk by their nature, do not often demand in-person supervision, and are typically furnished entirely by the supervised personnel.” CMS’ stated goal for approving remote supervision for these particular low-risk services is that they already are known to balance patient safety concerns with the need to expand access and optimize workforce capacity:

• Services with the underlying HCPCS code that has been assigned a PC/TC indicator of ‘5’; and
• Services described by CPT code 99211 (Office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional).

In addition to CMS’ proposed telehealth expansions, Congress is also considering extending telehealth flexibilities beyond this year, most likely through a two-year extension. NABH strongly endorses these flexibilities.

Quality
For reporting in 2025, CMS proposes six new, optional metrics for the quality payment program.
Please see the agency’s news release to read a high-level summary of the rule.

CMS will accept comments on the proposed rule through Sept. 9.

Reminder: SAMHSA Accepting Nominations for First SAMHSA Trailblazers in Advancing Recovery Awards

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week it has started accepting nominations for the inaugural SAMHSA Trailblazers in Advancing Recovery (STAR) awards, which honor leaders with lived experience of mental health and/or substance use condition, including family members whose lives have been affected.

The new STAR awards will also recognize organizations that have demonstrated a commitment to promoting equitable and inclusive access to wellness and recovery supports for individuals with mental health and/or substance use conditions.

Last year SAMHSA published Recovery from Substance Use and Mental Health Problems Among Adults in the United States, which reports that more than 70% of people, or about 50 million people, identified as ever having a mental health and/or substance use problem were in recovery.

Nominations opened June 26 and will remain open through July 18. SAMHSA is planning an awards ceremony that it will livestream in September as part of National Recovery Month. Click here to learn about the award categories, eligibility requirements, and nominating process.

Reminder: SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through today, July 12, 2024.

Reminder: 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

Results from a recent national survey showed 61% of Americans are unaware that primary care physicians can prescribe medication for opioid use disorder and 13% incorrectly believed that they could not, according to study published in JAMA.
                                  
For questions or comments about this CEO Update, please contact Jessica Zigmond.

House Ways and Means Committee Hearing Examines U.S. Child Welfare System 
and RTFs

The House Ways and Means Committee on Wednesday held a hearing about strengthening America’s child welfare system and protecting America’s children through reauthorizing Title IV-B, a child and youth foster-care program.

Although committee members focused primarily on improving the nation’s child foster care system, they also asked several questions of witness Paris Hilton, who testified about Residential Treatment Facilities (RTFs) and offered support for S.1351/H.R.2955, The Stop Institutional Child Abuse Act. Members and witnesses acknowledged the need for RTFs and also called for greater state and federal oversight, an expanded workforce, additional mental healthcare for children in the youth foster-care system outside RTFs, and more community-based care.

The hearing was one of several this Congress held to explore reauthorizing the Social Security Act’s Title IV-B program, which provides flexible funding for states to support family preservation, reunification, adoption, and permanency for children in foster care. Congress has not reauthorized the program since 2008.

In addition to potentially reauthorizing Title IV-B, several committee members discussed legislation they have drafted related to RTFs, which the committee could examine in a future mark-up session. These bills include:

H.R. 8817, the Promoting Accountability, Reporting, Information Sharing, and Health Act, by Reps. Steube (R-Fla.) and Jimmy Panetta (D-Calif.), which directs the U.S. Health and Human Services Department, the U.S. Education Department, the Administration for Children and Families, the Center for Medicare & Medicaid Services, and the U.S. Justice Department, to develop guidance on best practices for federal agencies and states. The guidance would focus on collecting data collection and sharing information related to youth well-being in RTFs, improving data on maltreatment, and enhancing oversight of youth residential programs receiving federal funding.

H.R. 8643, the Foster Youth Mental Health Support Act, by Rep. Michelle Steel (R-Calif.), which amends subpart 1 of Title IV part B of the Social Security Act to strengthen state plan requirements to include comprehensive mental health and well-being for children and youth in foster care.

Both bills were recently introduced, and NABH will share the bill language with members as soon as it is available. NABH sent the Ways and Means Committee comments about RTFs and our new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs.

NABH Congratulates Board Chair Frank Ghinassi for AHRQ Technical Expert Panel Position

NABH is pleased to announce NABH Board Chair Frank Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers University Behavioral Health Care and vice president of the behavioral health and addictions service line at RWJBarnabas Health, is serving on a behavioral health technical expert panel (TEP) that the Office of the Assistant Secretary, or ASPE, convened in partnership with the Agency for Healthcare Research and Quality (AHRQ).

ASPE and AHRQ engaged research firm Mathematica to identify and recommend behavioral health integration measure concepts for further development. In Phase 1 – completed in March 2024 – the team conducted an environmental scan and gathered feedback from key stakeholders about priorities for measures related to the integration of behavioral and physical healthcare.

In Phase 2, the current phase, the team will develop draft measure specifications based on further review of the literature and interviews with key stakeholders. The TEP will provide feedback on the draft measure specifications as well as the face validity of the measures, according to a memo from Mathematica, which said it will use the TEP feedback to refine the measure specifications.

ICYMI: Surgeon General’s Op-Ed on Why Social Media Platforms Should Carry Warning Labels

U.S. Surgeon General Vivek Murthy, M.D., M.B.A., last week penned an op-ed in The New York Times urging social media platforms to carry warning labels.

“The mental health crisis among young people is an emergency— and social media has emerged as an important contributor,” Murthy wrote. “Adolescents who spend more than three hours a day on social media face double the risk of anxiety and depression symptoms, and the average daily use in this age group, as of the summer of 2023, was 4.8 hours. Additionally, nearly half of adolescents say social media makes them feel worse about their bodies,” he continued. “It is time to require a surgeon general’s warning label on social media platforms, stating that social media is associated with significant mental health harms for adolescents.

Murthy added that a surgeon general’s warning label – which requires congressional action – would regularly remind parents and adolescents that social media has not been proved safe. He recognized that a warning label alone will not keep kids safe and added that the advisory he issued last year includes specific recommendations for policymakers, platforms, and the public to make social media safer for kids.

SAMHSA Accepting Nominations for First ‘SAMHSA Trailblazers in Advancing Recovery’ Awards

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week it has started accepting nominations for the inaugural SAMHSA Trailblazers in Advancing Recovery (STAR) awards, which honor leaders with lived experience of mental health and/or substance use condition, including family members whose lives have been affected.

The new STAR awards will also recognize organizations that have demonstrated a commitment to promoting equitable and inclusive access to wellness and recovery supports for individuals with mental health and/or substance use conditions.

Last year SAMHSA published Recovery from Substance Use and Mental Health Problems Among Adults in the United States, which reports that more than 70% of people, or about 50 million people, identified as ever having a mental health and/or substance use problem were in recovery.

Nominations opened June 26 and will remain open through July 18. SAMHSA is planning an awards ceremony that it will livestream in September as part of National Recovery Month.

Click here to learn about the award categories, eligibility requirements, and nominating process.

SAMHSA Announces Funding Opportunity to Enhance Capacity of Women’s Behavioral Health Providers

SAMHSA is accepting applications for its Women’s Behavioral Health Technical Assistance Center to enhance capacity of women’s behavioral health providers, general healthcare providers, and others involved in the holistic care of women with or at risk for mental health and substance use conditions—including women who were greatly affected by the COVID-19 pandemic.

The agency said it has a total of $12.5 million for five years and anticipates granting one award. Applications are due by Tuesday, Aug. 20, 2024. Click here to learn more.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: 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

A study published in JAMA last week found that, despite their known association with reduced risk of a fatal drug overdose, only a small percentage of Medicare beneficiaries (4.1%) received medications for opioid use disorder (MOUD) or filled a naloxone prescription (6.2%) in the 12 months after a nonfatal drug overdose. “Efforts to improve access to behavioral health services; MOUD; and overdose-prevention strategies, such as prescribing naloxone and linking individuals to community-based health care settings for ongoing care, are needed,” the study noted.

Happy Independence Day from NABH!

NABH will not publish CEO Update on Friday, July 5 and will resume on Friday, July 12. The NABH team wishes you, your families, and your teams a happy and safe Independence Day weekend!

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

House Ways & Means Committee to Host Hearing Next Week on Strengthening 
Child Welfare

The House Ways and Means Committee is scheduled to conduct a hearing next Wednesday, June 26 focused on strengthening child welfare by reauthorizing Title IV-B, a program serving children and youth in foster care. Policymakers are expected to review youth Residential Treatment Facilities (RTFs) during the hearing.

Among witnesses invited to testify is Paris Hilton, who has spoken about her turbulent experience at a youth treatment center and is an advocate for S.1351/H.R.2955, The Stop Institutional Child Abuse Act. The bill establishes an interagency Federal Work Group on Youth Residential Programs to support and implement best practices regarding the health and safety, care, treatment, and appropriate placement of youth in youth residential programs.

The hearing is part of the Committee’s ongoing focus to reauthorize the Social Security Act’s Title IV-B programs. The Committee has previously held several hearings to examine various programs included in Title IV-B. The Title IV-B program provides flexible funding for states to support family preservation, reunification, adoption, and permanency for children in foster care; however, many consider the program outdated, and Congress has not reauthorized it since 2008.

NABH will submit comments to the Ways & Means Committee and will also share our new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs.

The hearing comes on the heels of last week’s Senate Finance Committee hearing about RTFs, “Youth Residential Treatment Facilities: Examining Failures and Evaluating Solutions” and a partisan report, Warehouse of Neglect: How Taxpayers Are Funding Systemic Abuse in Youth Residential Treatment Facilities, which cites limitations and problems at youth RTFs and fails to recognize the critical care, treatment, and educational support these programs provide to America’s youth. NABH sent this letter to the Senate Finance Committee last week in conjunction with the hearing.

CMS Announces Funding Opportunity Application Period for the Innovation in Behavioral Health Model

The Centers for Medicare & Medicaid Services (CMS) this week released its notice of funding opportunity application for the Innovation in Behavioral Health (IBH) model that focuses on improving the behavioral and physical health outcomes and quality of care for Medicare and Medicaid enrollees who experience moderate to severe behavioral health conditions.

The IBH Model is a state-based model that state Medicaid agencies (SMAs) lead with a goal of aligning payment between Medicaid and Medicare for integrated care.

CMS will select up to eight SMAs to participate in the IBH Model, and these agencies will use cooperative agreement funding to develop necessary infrastructure and capacity to implement the IBH Model. The SMAs will recruit “Practice Participants” to deliver care, and they will receive funding to support necessary upgrades to health information technology, electronic health records, practice transformation activities, and staffing to implement the model.

CMS will issue award notices to selected SMAs in mid-December. Learn more from this CMS IBH model overview fact sheet. For additional questions, you can reach the IBH Model team at IBHModel@cms.hhs.gov.

SAMHSA Announces New Way to Order 988 Print Materials

The Substance Abuse and Mental Health Services Administration has announced a new website to order 988 awareness printed materials.

“Over the past two years, we’ve heard your requests to simplify and improve the ordering process for 988 Suicide & Crisis Lifeline print materials,” SAMHSA said in an announcement. “We know that print materials are a critical need for all who are working to raise awareness about 988 across the country, and we have been working behind the scenes to improve this process.”

Providers and other partners will still be able to use the “order print materials” link from SAMHSA’s 988 Partner Toolkit.

CDC Reports 26% Drop in Uninsured Americans Since 2019

New data from the Centers for Disease Control and Prevention’s National Health Interview Survey (NHIS) show 7.6% of Americans did not have health insurance in 2023, compared with 10.3% of Americans without health insurance in 2019, reflecting a 26% decrease in the number of uninsured Americans.

Meanwhile, the NHIS reported that among adults ages 18–64 living in Medicaid expansion states, the percentage with public coverage increased to 25.2% in 2023 from 23.4% in 2019. A similar increase in public coverage was observed among adults living in non-Medicaid expansion states 18.1% in 2023 from 15.1% in 2019.

In a story this week, Behavioral Health Business highlighted how more Americans with health insurance could affect the behavioral healthcare segment.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

Reminder: 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

Hospitals that report using AI to detect patterns of drug diversion – when drugs are stolen from hospitals – nearly doubled to 56% in 2023 from 29% in 2019, according to a Wolters Kluwer survey.

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

Senate Finance Committee Holds Hearing and Releases Report on Youth RTFs

In conjunction with a hearing Wednesday, the Senate Finance Committee released Warehouse of Neglect: How Taxpayers Are Funding Systemic Abuse in Youth Residential Treatment Facilities, a partisan report that cites limitations and problems at youth RTFs and fails to recognize the critical care, treatment, and educational support these programs provide to America’s youth.

Only members of the Committee’s minority staff developed the report, a two-year effort that focused on four operators of youth residential treatment facilities (RTFs), including three NABH system members.

“NABH is eager to work with federal leaders to develop policies that advance access to quality care in the appropriate settings for U.S. youth who struggle with mental health and substance use disorders,” NABH President and CEO Shawn Coughlin said in a statement Wednesday. “We also want to remind congressional leaders that if public discourse about youth RTFs is to benefit the common good, we need to ensure that policymakers, members of the media, worried parents, concerned teachers, and the general public share the same, clear understanding of the role that regulated, licensed RTFs play in the behavioral healthcare continuum.”

The report recommended three main points: 1) children placed in RTFs must be afforded safety, dignity, and homelike conditions and provided with the treatment and support that they need, 2) government funding should prioritize community-based services and placements to address children’s behavioral health needs, and 3) effective oversight mechanisms of RTFs require substantial investment at all levels of government.

At the hearing, several Democratic members joined Senate Finance Committee Chairman Ron Wyden (D-Ore.) and Ranking Member Mike Crapo (R-Idaho). Several witnesses, including a disabilities-rights advocate and a Government Accountability Office representative, painted an incomplete picture of the care and treatment that RTFs provide. While most acknowledged youth RTFs play a role in the behavioral healthcare continuum, senators and witnesses called for more home and community-based services and better state and federal oversight, among other recommendations.

Meanwhile, there were no statements that reflected the successful treatment in RTF programs and the increasing need for them in the United States today. Since 2010, the number of youth residential treatment programs has declined by 60.9%; the number of youth served has declined by 77%; and the number of beds has declined by 66.2%; according to a May 2024 study from the Manhattan Institute.

Also Wednesday, NABH sent a letter to the Senate Finance Committee and released a new youth RTF fact sheet, which highlights 10 essential facts about youth RTFs. Please share the fact sheet with your teams and engage with NABH’s X and LinkedIn posts to spread the message about these facilities and the critical – and often life-saving – care that NABH members provide in RTFs every day.

Legal Action Center to Host Webinar Next Week on How SUD Providers Can Leverage Medicaid Reentry for People Leaving Prisons and Jails

Medicaid reentry is a new federal policy meant to strengthen access to health coverage and transitional services for people preparing to come home from prison or jail, with a primary goal to prevent overdose among reentering individuals.

The Legal Action Center, an Opioid Response Network training partner, will host Medicaid Reentry: How Substance Use Disorder Service Providers/Stakeholders Can Leverage This New Opportunity to Strengthen Equitable Health Outcomes for People Leaving Prison/Jail, a 75-minute webinar next Thursday, June 20 starting at noon ET.

Click here to add the event to your calendar.

National Academies Releases Publication on Adult ADHD

The National Academies has released Adult Attention-Deficit/Hyperactivity Disorder: Drug Development, Diagnosis, and Treatment, which is based on proceedings from a December 2023 workshop about the topic.

According to the National Academies, evidence suggests adults with ADHD may be more likely to develop an SUD, and there are concerns that non-medical use of prescription stimulants could lead to misuse, overdose, or toxicity.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

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.
2. 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 number of individual pills containing fentanyl that law enforcement officer seized was 2,300 times greater in 2023 compared with 2017, with 115,562,603 pills seized in 2023 versus 49,657 in 2017, according to a recent announcementfrom the National Institute on Drug Abuse.

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

Senate Democrats Pressure Biden Administration to Complete Final Parity Rule

A group of Senate Democrats is pressuring the Biden administration to complete and release its final rule on the Mental Health Parity and Addiction Equity Act’s requirements.

In a letter to the leaders of HHS, the Internal Revenue Service, and the U.S. Labor Department’s Employee Benefits and Security Administration, Sens. Chris Murphy (Conn.), Peter Welch (Vt.), Alex Padilla (Calif.), Ed Markey (Mass.), Amy Klobuchar (Minn.), and Ben Ray Luján (N.M.) urged the Biden administration to stay the course on completing its work to finalize the 2023 proposed rule.

The letter noted: “…these rules will close existing loopholes in the law, expand narrow networks, and prohibit restrictive practices that prevent families from accessing care.”

Particularly important are the rules that combat the nonquantitative treatment limitations that are being used to deny mental health services to patients. These common-sense parity rules will help Americans suffering from mental health conditions or substance use disorder, reduce costs for taxpayers, and save lives.

NABH and leaders of mental health advocacy groups are also strongly urging these agency leaders to oppose efforts from insurance and employer groups to weaken the proposed rule’s strong protections.

Meanwhile, these communications come as a powerful group of employer organizations – the ERISA Industry Committee, the Partnership for Employer-Sponsored Coverage, and the U.S. Chamber of Commerce – have pushed back on the administration and the proposed rule, arguing that the regulations would be “unworkable” and undermine access to care.

Insurers have also slammed the proposed rule, saying it wouldn’t address underlying workforce shortages, which they say limit access to care. The Treasury Department has targeted June to finalize the rules, although it remains uncertain if that will happen.

HRSA Accepting STAR Loan Repayment Program Applications Through June 27

The Health Resources and Services Administration (HRSA) will accept applications from eligible
SUD treatment clinicians and community health workers for its Substance Use Disorder Treatment and Recovery (STAR) Loan Repayment Program through Thursday, June 27.

Click here for guidance about the STAR Loan Repayment program and here for information about the application process.

HRSA Adds Occupations to Guide for Licensure Portability

HRSA has announced that counseling and school psychologists have been added as new disciplines to the Multi-Discipline Licensure Resource Project that HRSA supports with the Association of State and Provincial Psychology Boards.

Previously the site provided guidance for psychology, social work, physical therapy, and occupational therapy. The new disciplines include counseling, dentistry, dieticians, emergency medical services, physician assistants, nursing, advanced practice nursing, and school psychologists.

SAMHSA Releases Issue Brief on Peer Support in Mental Health

The Substance Use and Mental Health Services Administration has released an issue brief for state mental health authorities about the benefits of peer support and inclusion of the peer workforce throughout the behavioral healthcare continuum.

The new resource highlights current standards and best practices for including peer support workers as an essential component of services delivery for mental and co-occurring disorders such as SUD.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) last month announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity; ONC will accept applications through July 12, 2024.

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.
2. 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

Starting people with opioid use disorder on extended-release, injectable naltrexone (XR-naltrexone) within five to seven days of seeking treatment is more effective than the standard treatment method of starting within 10-15 days, but requires closer medical supervision, according to results from a National Institute on Drug Abuse-supported clinical trial.

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

NABH Comments on Fiscal Year 2025 IPF PPS Final Rule

This week NABH sent its public comment letter to the Centers for Medicare & Medicaid Services (CMS) about the agency’s fiscal year 2025 inpatient psychiatric facility prospective payment system (IPF PPS) rule.

In the letter, NABH emphasized that the proposed net update for FY 2025 – an increase of 2.6% percent relative to FY 2024 rates – does not adequately account for the nationwide cost pressures that IPFs continue to face.

“The update does not reflect the remaining healthcare cost inflation that was sparked by the COVID-19 pandemic and still persists in the form of workforce pressures and shortages and other elevated costs,” NABH wrote. “These include continued head-to-head wage competitions with other employers within and outside of local healthcare marketplaces, which are exacerbated by burnout among clinical and non-clinical personnel, and other factors that continually pressure IPFs to raise compensation levels.”

NABH offered its perspective and suggestions on a range of other topics, including the need for modern behavioral health information technology, a request to delay the requirement for ancillary-services reporting by two years, and proposed quality reporting changes.

“NABH urges CMS to delay implementing its proposed policy restriction on all-inclusive reporting. Given the complexity of transitioning from all-inclusive to traditional reporting of ancillary charges, the proposed effective date of Oct. 1, 2024 is impossible and should be changed to Oct. 1, 2026.”

The association thanks all its members who gave their time and recommendations in the last few months to help NABH prepare the letter to CMS.

FDA Launches ‘Prescribe with Confidence’ Campaign to Help Providers Treat OUD

The U.S. Food and Drug Administration (FDA) has launched Prescribe with Confidence, a campaign to help healthcare providers recognize and treat opioid use disorder (OUD), which the agency says affects 6 million people over the age of 12 in the United States.

“Research shows that OUD treatment is most effective when medications are used,” FDA Commissioner Robert Carliff, M.D. said in a brief video about the campaign.

In its announcement, the FDA noted that many primary care providers have found prescribing medications to treat OUD is easier than they thought it would be. The agency has provided firsthand testimonials, free training, and other resources to help providers. Click here to learn more.

ICYMI: 2024 NABH Annual Meeting Highlights

NABH thanks all who traveled to Washington earlier this month for the association’s 2024 Annual Meeting!

Photos from the meeting are now available. If you choose to use any of these pictures, please credit photographer Chris Ferenzi.

NABH has shared the Annual Meeting slide presentations and learned some attendees had trouble downloading them. We have re-posted the presentations as PDF documents on our 2024 Annual Meeting Speakers & Presentations page. David Wasserman’s presentation will be available until today, Friday, May 31.

We’ve received positive feedback about the NABH Education and Research Foundation’s workforce panel, and we urge you to share NABH’s Workforce Startup Guide with your teams. You can download the guide on NABH’s website homepage.

Reminder: ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) on May 13 announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity.

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.
2. 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 analysis in JAMA highlights how a hospital cyberattack can affect neighboring facilities and an entire community’s care: researchers examined emergency department (ED) discharge data from the California Department of Health Care Access and Information between 2014-2020 and found a temporary decrease in ED visits and inpatient admissions at hospitals targeted by ransomware attacks and a temporary increase in ED visits at nearby, unaffected hospitals.

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

2024 NABH Annual Meeting & Hill Day Highlights

NABH thanks all who traveled to Washington last week for the 2024 Annual Meeting!

Photos from the meeting are now available. If you choose to use any of these pictures, please credit photographer Chris Ferenzi.

Last week NABH shared the Annual Meeting slide presentations and learned some attendees had trouble downloading them. We have re-posted the presentations as PDF documents on our 2024 Annual Meeting Speakers & Presentations page. David Wasserman’s presentation will be available until May 31.

We’ve received positive feedback about the NABH Education and Research Foundation’s workforce panel, and we urge you to share NABH’s Workforce Startup Guide with your teams. You can download the guide on NABH’s website homepage.

NABH also thanks all members who participated in Hill Day in conjunction with #NABH2024! Our members met with policymakers and their staff and highlighted the crucial need to secure the promise of parity between behavioral and physical healthcare, increase the behavioral healthcare workforce, and invest in behavioral health information technology to adopt electronic health records.

NABH members conducted more than 60 congressional meetings and prioritized key offices for policymakers who serve on committees of jurisdiction overseeing behavioral healthcare policy, including the Senate Finance Committee, Senate Health, Education, Labor and Pension Committee, House Energy and Commerce Committee, and House Ways and Means Committee.

Please save the date for next year’s Annual Meeting: May 12-14, 2025 at the Salamander Washington, DC!

House Committees Advance Telehealth Extension Bills

The House Energy & Commerce Health Subcommittee on May 16 unanimously advanced telehealth legislation to the full House Energy & Commerce Committee that would extend for two years key COVID-19 pandemic telehealth waivers scheduled to expire at the end of this year.

The bill that the Subcommittee advanced – similar to the bill the House Ways & Means Committee passed in the previous week – would delay the in-person requirement and originating site restrictions for mental health services and extend the provision for audio-only telehealth services for the next two years. Both bills also include a five-year extension of waivers for the Acute Hospital Care at Home program, allowing patients to receive hospital-level care in their homes until 2029.

The House Energy & Commerce’s bill includes payment parity for federally qualified health centers and rural health clinics, so they can bill the same amount for telehealth and in-person outpatient services. Under the House Ways & Means Committee’s bill, the centers would be reimbursed at lower rates for most virtual services.

Meanwhile, the Energy & Commerce panel also advanced a second telehealth bill that would establish a Medicare incident to modifier for mental health services furnished through telehealth. Both committees’ bills include offsets that impose new transparency requirements on pharmacy benefit managers and delay the upcoming changes to Medicare payment rates for clinical lab tests by one year.

The Senate has yet to take up a telehealth extension bill, although Senate Finance Committee Chair Ron Wyden (D-Ore.) is pushing to extend permanently some of the COVID-19-era telehealth flexibilities set to expire at the end of this calendar year. If Congress passes a short-term telehealth extension, lawmakers will have to restart the process after it expires.

Final Medicaid Rule Reduces Allowed Wait Times for Behavioral Healthcare Outpatient Appointments

The Centers for Medicare & Medicaid Services (CMS) recently published a Medicaid final rule that includes positive changes on several NABH priority issues.

NABH is pleased that beginning in June 2027, wait times for adult and pediatric outpatient mental health and substance use disorder (SUD) services will be subject to a 10-day maximum. Also, starting in 2028, states will be required to conduct annual “secret shopper” surveys to investigate whether managed care plans are meeting wait time requirements and the validity of provider directories.

In July 2027, states must survey Medicaid enrollees to assess their managed care experience. Finally, to help CMS understand and improve payment adequacy, beginning in July 2026, states must annually submit payment data that compare state Medicaid managed care plan rates with Medicare or Medicaid state plan rates, including specific data for mental health and SUD services.

This CMS fact sheet provides additional details about the final rule.

ONC Funding Opportunity Seeks to Accelerate BHIT

HHS’ Office of the National Coordinator for Health Information Technology (ONC) on May 13 announced a funding opportunity totaling $2 million for fiscal year 2024 under the Leading Edge Acceleration Projects (LEAP) in Health Information Technology (Health IT).

ONC is seeking applications that address two areas of interest. The first area seeks to develop innovative ways to evaluate and improve the quality of healthcare data used in artificial intelligence (AI) tools in healthcare to improve electronic health record technologies.

The second area is focused on designing, developing, and piloting lightweight health IT solutions that can enhance health IT capabilities in behavioral healthcare settings and improve care coordination between behavioral healthcare and clinical healthcare settings.

“These two areas of interest are a natural extension of ONC’s work,” Steve Posnack, deputy national coordinator for health information technology and an NABH 2024 Annual Meeting speaker, said in a statement. “We look forward to receiving innovative applications and seeing the impacts generated by selected awardees.”

Click here to learn more about the grant opportunity.

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.
2. 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 study of more than 1.2 million people has identified 95 regions of the genome linked to PTSD, and 80 of those have not been identified previously. Researchers also identified 43 genes that seem to play a role in causing PTSD.

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

2024 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2024 Annual Meeting that starts Monday, May 13 in Washington, D.C.

This year’s Annual Meeting focuses on The Future of Behavioral Healthcare, and our presenters will explore this theme as it relates to behavioral health information technology, parity, workforce issues, and more.

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

Be Sure to Access the 2024 NABH Annual Meeting Mobile App!

Again this year, attendees will have access to all Annual Meeting programming and materials through NABH’s web-based app.

Early Monday, NABH will send all attendees an Annual Meeting alert with this link to the app that displays details about sessions, speakers, meeting room locations, NABH’s advocacy priorities, and more. Attendees can also access the link through a QR code near the Registration Desk at the Annual Meeting.

Deputy National Coordinator for Health IT Steven Posnack to Open Monday Sessions

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 t 2:45 p.m. ET in the Salamander hotel’s Grand Ballroom.

Posnack advises the national coordinator, leads the execution of 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.

NABH Education and Research Foundation to Workforce Panel on Monday at 4 p.m. ET

Building on last year’s success, the NABH Education and Research Foundation will host a panel discussion featuring NABH members and workforce consultants on Monday from 4 p.m. – 5 p.m. ET.

This year’s panel will focus on NABH member best workforce practices, internships, apprenticeships, and other “grow your own” programs.

NABH Education and Research Foundation Vice President Jim Shaheen of New Season, who also serves on the NABH Board of Trustees, will moderate the panel that will feature Jason Brooks, Ph.D., senior vice president of Human Resources at New Season; Rhonda Ashley-Dixon, vice president of Strategic Partnerships & Engagement at Vanderbilt Behavioral Health; Beth Kuhn, principal at Stonegate Strategies and former commissioner, Kentucky Department of Workforce Investment; and John Pallasch, founder and CEO of One Workforce Solutions and former U.S. assistant secretary for employment and training at the U.S. Labor Department (DOL).

This year’s panel discussion will include poll questions for the audience, and we urge NABH members to attend and engage with panelists during the question-and-answer period!

DOL Official Timothy Hauser to Discuss Parity on Tuesday, May 14 at 10 a.m.

Timothy D. Hauser, deputy assistant secretary for program operations of DOL’s Employee Benefits Security Administration (EBSA) will discuss parity when he kicks off Day 2 of the NABH 2024 Annual Meeting on Tuesday, May 14 at 10 a.m.

Hauser, who serves as EBSA’s chief operating officer, 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, Mr. Hauser was the associate solicitor of the division. As the head of PBSD, he was responsible for all of DOL’s legal work under ERISA.

Before joining DOL, Mr. Hauser worked as a trial attorney for six years at Legal Aid of Western Missouri. Hauser graduated from Harvard Law School in 1985 and earned his undergraduate degree at the University of Illinois.

Election Analyst David Wasserman to Examine 2024 Elections at 11 a.m.

Following Hauser’s presentation Tuesday morning, election analyst David Wasserman will provide Annual Meeting attendees with an in-depth look at this year’s upcoming presidential and congressional elections.

Wasserman is the senior editor for the non-partisan newsletter The Cook Political Report with Amy Walter, which has analyzed U.S. presidential, Senate, House, and gubernatorial races since 1984. Referred to as “pretty much the only person you need to follow on Election Night” according to Meet the Press host Chuck Todd, Wasserman is also a contributor to NBC News.

Prior to joining the The Cook Political Report with Amy Walter in 2007, Wasserman served for three years as House editor of Sabato’s Crystal Ball, a widely respected political analysis newsletter and website founded by renowned University of Virginia professor Larry Sabato (a former NABH Annual Meeting presenter).  Wasserman graduated from the University of Virginia.

NABH President and CEO Shawn Coughlin to Address Attendees at Annual Meeting Luncheon

Please join us for this year’s Annual Meeting Luncheon on Tuesday at Noon to hear brief remarks from NABH President and CEO Shawn Coughlin.

Coughlin will provide updates on NABH’s work and help prepare attendees who will head to Capitol Hill for congressional visits following the luncheon.

Help Us Advocate Your Issue Priorities at Hill Day 2024!

NABH is eager to welcome its members and guests to Hill Day 2024 on Tuesday, May 14 from 1:30 – 5 p.m. ET!

As always, Hill Day is an excellent opportunity for NABH members to meet personally with Members of Congress and their staff to share our association’s advocacy priorities. It’s not too late to register if you’re interested!

If you registered for the Annual Meeting, are interested in Hill Day, and have not yet signed up, please contact e-mail NABH Associate Manager for Congressional Affairs Emily Wilkins.

How it Works:

After you register for the NABH Annual Meeting, the NABH Congressional Affairs team will match you with legislators who represent your facility’s footprint.

On Hill Day, NABH will have our Advocacy Room open from 12:30 p.m. – 1:50 p.m. in the Renwick Room of the Salamander. Here NABH will help prepare you with materials and talking points to guide your conversations with Members of Congress and their staff. The Advocacy Room will reopen from 4:15 p.m. – 5:00 p.m. for you to debrief your meetings.

What We Need From You:

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! This is very helpful when scheduling meetings.

Also, Hill Day participants—and all Annual Meeting attendees—can review the association’s 2024 Advocacy Priorities and Hill Day fact sheets before or during the Annual Meeting through our web-based meeting app.

Wednesday Policy Breakfast to Feature Remarks from Rep. Doris Matsui & NABH Consultant Meiram Bendat, J.D., Ph.D.

Join us for the Annual Meeting Policy Breakfast on Wednesday at 8 a.m. to watch a brief video from NABH Champion Rep. Doris Matsui (D-Calif.) and to learn about the ongoing Wit v. United Behavioral Health case from NABH consultant Meiram Bendat, J.D., Ph.D.

Matsui will highlight her legislation, the Behavioral Health Information Technology Coordination Act, and discuss why adopting BHIT is critical.

An attorney with a background in mental health, Bendat represented children and families in the Los Angeles child welfare system and treated patients before he founded Psych-Appeal, the country’s first private mental health insurance law firm, in 2011.

Since then, Bendat has helped patients and providers successfully challenge denials of mental health treatment through administrative appeals and impact litigation, recovering millions of dollars in wrongly withheld benefits.

The NABH team wishes everyone a safe trip to Washington, and we look forward to seeing you soon!

Please note: NABH will not publish CEO Update next week and will publish the next issue on May 24. For questions or comments about this CEO Update, please contact Jessica Zigmond

CMS Releases FY 2024 IPF PPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) on Thursday released its Fiscal Year (FY) 2024 Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) final rule.   NABH’s Position While the final rule includes many NABH priorities, we remain concerned that it does not go far enough to account for the cost pressures IPFs face. The NABH team will meet with CMS to discuss the field’s health information technology and other obstacles that will greatly hinder compliance with the quality measures (QMs) to be added to the inpatient psychiatric facility quality reporting program (IPFQRP).   Final Payment Update The rule finalizes a net increase in Medicare FY 2024 payments to IPFs of 2.3%, or $70 million, relative to FY 2023. While the agency’s final FY 2023 payment update is larger than the proposed rule’s 1.9% increase, NABH will continue to push policymakers to recognize fully the high costs that our members face. The FY 2024 update includes increases in the federal per-diem base rate to $895.63 from $865.63, and in the outlier threshold to $33,470 from $24,630, which will reduce the number of cases that qualify for an outlier payment. Updated IPF Marketbasket: The rule also finalizes CMS’ proposal to rebase and revise the IPF marketbasket using more recent cost report data from 2021 in place of 2016 data. Streamlined Process for Opening New IPF Units: The rule will allow new IPF units to open and begin billing Medicare at any time during its cost reporting year, following a 30-day advance notice. Final Updates to IPFQRP               The final rule implements four new QMs and a data validation pilot, among other changes. The new QMs include these three QMs related to health equity and social drivers of health:

• A Facility Commitment to Health Equity measure, which providers will begin reporting in FY 2026 and will affect payments;
• A Screening for Social Drivers of Health (SDOH) measure, for which voluntary reporting will begin in FY 2025 and later will affect payments; and
• A Screen Positive Rate for SDOH measure beginning with voluntary reporting of CY 2024 data with impact on payment to begin in FY 2027.

The new data validation pilot program will begin data collection in FY 2025. While NABH supported the general concept of this pilot, we urged CMS to postpone it because the field is currently focused on its first year of submitting patient-level quality data. Because the agency is moving forward, we will continue to emphasize that the pilot is too much, too fast. More information on these IPFQRP updates can be found in the NABH comment letter on this rule, as well as the final rule text using the link above.

HHS, DOL and Treasury Release Proposed Rules to Strengthen MHPAEA

The U.S. Health and Human Services (HHS), Labor (DOL), and Treasury Departments on Tuesday released proposed rules to bolster the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 and remove obstacles to behavioral healthcare access.   The rules propose several amendments to the 2013 MHPAEA final regulations, as well as provisions that would establish the content requirements of the Non-Qualitative Treatment Limitations, or NQTL, comparative analyses required under amendments to MHPAEA included in the Consolidated Appropriations Act, 2021 (CAA, 2021). “In evaluating their compliance with these proposed rules, plans and issuers would be required to consider whether an NQTL is inhibiting access to treatment for mental health conditions and substance use disorders by examining whether the NQTL that applies to mental health or substance use disorder benefits is more restrictive than the predominant NQTL that applies to substantially all medical/surgical benefits within a classification of benefits set forth under the regulations,” the guidance noted. Meanwhile, the guidance said a plan or issuer would also be required to consider whether the processes, strategies, evidentiary standards, or other factors that it uses to design or apply an NQTL to mental health or substance use disorder benefits in a classification are comparable to, and applied no more stringently than, those used in designing and applying the NQTL to medical/surgical benefits in the same classification.   The three departments also released a Technical Release on NQTLs that outlines principles and seeks public comment to inform future technical guidance about the application of proposed data collection and evaluation requirements to NQTLs related to network composition that the rule proposes. Along with the proposed rules, the departments released the 2023 MHPAEA Comparative Analysis Report to Congress that the CAA, 2021 requires. The report includes information about the agencies’ enforcement efforts and identifies plans and issuers that received final determinations of non-compliance with MHPAEA. The White House released a fact sheet about the rule and DOL’s Employee Benefits Security Administration posted all the related documents here. NABH is a member of the CEO Alliance on Mental Health, which released a statement about the guidance this week. “The Biden Administration, along with bipartisan leadership in Congress, has made great progress in increasing access to comprehensive mental health and substance use care, including expanding the Certified Community Behavioral Health Clinic (CCBHC) model, improving crisis services and suicide prevention, and addressing youth mental health,” the Alliance statement said. “However, more work is needed to ensure everyone can access high quality care as early as possible, so we thank President Biden for this focus on improving parity.” CMS will accept comments until 60 days after the rules are published in the Federal Register. NABH will seek feedback from members and submit comments about the proposed rules and Technical Release.

CMS Releases Ligature Risk Guidance

CMS has released guidance to state survey directors about ligature risk and assessment in hospitals. The agency’s guidance centers around three main elements CMS said hospitals should consider when ensuring patient safety related to ligature risk: patient assessment, staffing/monitoring, and environmental risk. “Based on their clinical evaluation, some patients may require both a more restrictive environment and an increased level of monitoring than other patients,” the guidance noted. “Therefore, it is not expected that hospitals have the same ligature risk configuration throughout their facility, but rather focus on the specific needs and risks of individual patients, based on their clinical or psychiatric assessment,” it continued. “Similarly, corrective actions implemented in response to deficiencies or adverse events should focus on appropriately addressing the findings or failures, rather than universal remedies.” The changes are effective 30 days from when CMS released the memorandum on July 17. Please send any questions to QSOG_Hospital@cms.hhs.gov.

Reminder: DEA Registration Training Requirement for Buprenorphine Prescribing

Early this year SAMSHA announced that clinicians no longer need a federal waiver to prescribe buprenorphine to treat opioid use disorder; however, clinicians must still register with the U.S. Drug Enforcement Agency (DEA) to prescribe controlled medications. In late June, the DEA announced that both new and renewing applicants must complete a new, one-time, eight-hour training course. Exceptions for the training requirement are practitioners who are board-certified in addiction medicine or addiction psychiatry, and those who graduated from a medical, dental, physician assistant, or advanced practice nursing school in the United States within five years of June 27, 2023. Click here to learn more about the training.

2023 NABH Annual Meeting Photos Now Available

NABH is pleased to share photos from last month’s 2023 Annual Meeting: Security the Promise of Parity. If you choose to download and use a photo, please credit photographer Chris Ferenzi. Thank you.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

CEO Update During the Congressional August Recess

NABH will publish CEO Update only on Friday, Aug. 11 and Friday, Aug. 28 during the congressional August recess.

Fact of the Week:

A new study published in Psychiatric Services reports disruptions in opioid use disorder outpatient and medications for opioid use disorder were marginal during the pandemic, possibly because of increased telehealth services. For questions or comments about this CEO Update, please contact Jessica Zigmond.

House Energy and Commerce Committee Passes SUPPORT Act Reauthorization Bill

The House Energy and Commerce Committee this week voted unanimously to pass the SUPPORT for Patients and Communities Reauthorization Act (SUPPORT), which would renew programs from the 2018 law that would otherwise expire at the end of September.   “Today’s SUPPORT Act reauthorization includes a number of key bipartisan wins, including agreements on lifting the IMD exclusion, helping people in our criminal justice system, and caring for foster youth in need,” House Energy and Commerce Committee Chair Cathy McMorris Rodgers said in a statement after the committee passed the bill on Wednesday. Rep. Michael Burgess, M.D. (R-Texas) sponsored a bill included in the reauthorization act to remove the decades-old Institutions for Mental Diseases (IMD) exclusion. “It is no longer the 1960s and there is no longer the same stigma against the treatment of mental health,” Burgess told the news outlet Politico. Burgess also pushed for boosting the healthcare workforce and supporting providers “to ensure that mental health and substance use patients have access to personalized care, personalized medicine.” The legislation also includes a provision that would allow federal funding to pay for test strips that can detect drugs such as fentanyl and the animal tranquilizer xylazine that drug dealers often mix with it. House lawmakers could vote on the measure before they leave Washington for Congress’ August recess. NABH will keep members apprised of developments.

Becerra to Host 988 Stakeholder Webinar Today at 1 p.m. ET

U.S. Health and Human Services Department (HHS) Secretary Xavier Becerra and Substance Abuse and Mental Health Services Administration (SAMHSA) Assistant Secretary Miriam Delphin-Rittmon will host a 988 Lifeline anniversary stakeholder webinar today, Friday, July 21 at 1 p.m. ET. Other Biden administration officials will join the event, which commemorates one year since the 988 Suicide and Crisis Lifeline launched. The webinar will last 30 minutes. Click here to register.

NABH Supports Bowman Family Foundation Report on Equitable Access

NABH supports the Bowman Family Foundation’s new report, Equitable Access to Mental Health and Substance Use Care: An Urgent Need, which examines strategies for bridging the gap in access to mental health and substance use care. The 33-page report found that 57% of patients sought mental health or substance use care but did not receive any care in at least one case, compared with 32% of patients seeking physical healthcare. For children and teens under 18 (defined here as “adolescents”), the “care not received” figure was 69% for mental health or substance use compared with 17% for physical health (see Figure 2 on p. 11 of the report). Meanwhile, 80% of patients in employer-sponsored health plans who received outpatient care from at least one out-of-network mental health or substance use provider said they went to out-of-network providers “all of the time,” compared with 6% of patients who said the same for physical healthcare. NABH strongly supports the report’s recommendation for the Departments of Labor, Health and Human Services, and the Treasury to issue additional guidance on detailed templates for MHPAEA compliance data reporting to employer group plans, third party administrators, and insurance issuers that indicates what data they should be prepared to submit upon request.

SAMHSA Seeking Comments on Harm Reduction Framework Draft

SAMHSA is seeking public comment on a draft of the agency’s Harm Reduction Framework, which is intended to inform SAMHSA’s harm-reduction activities as well as all related policies, programs, and practices. Comments are due by Monday, Aug. 14 at 5 p.m. ET.

SAMHSA Releases Advisory on Digital Therapeutics in Behavioral Health

SAMHSA this week released Digital Therapeutics for Management and Treatment in Behavioral Health, which describes the research, regulatory, and reimbursement implications for digital therapeutics, including those by various federal agencies. The advisory also maps out selection and implementation considerations for payers and providers and addresses issues related to equitable access to behavioral healthcare.

Kaiser Family Foundation Examines Federal Policy for SUD Treatment

A new Kaiser Family Foundation analysis found that 24% more buprenorphine was dispensed in 2022 than in 2019, the year before the COVID-19 global pandemic. Health policy researchers examined five essential federal policies governing SUD treatment, the changes they have undergone during the pandemic, and the implications for access and treatment to opioid use disorder. Click here to read the brief analysis.

Reminder: DEA Registration Training Requirement for Buprenorphine Prescribing

Early this year SAMSHA announced that clinicians no longer need a federal waiver to prescribe buprenorphine to treat opioid use disorder; however, clinicians must still register with the U.S. Drug Enforcement Agency (DEA) to prescribe controlled medications. In late June, the DEA announced that both new and renewing applicants must complete a new, one-time, eight-hour training course. Exceptions for the training requirement are practitioners who are board-certified in addiction medicine or addiction psychiatry, and those who graduated from a medical, dental, physician assistant, or advanced practice nursing school in the United States within five years of June 27, 2023. Click here to learn more about the training.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Denials 

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week:

A new report from the HHS Office of the Inspector General found three factors that raise concerns that some people enrolled in Medicaid managed care may not be receiving all medically necessary healthcare services intended to be covered: (1) the high number and rates of denied prior authorization requests by some managed care organizations, (2) the limited oversight of prior authorization denials in most states, and 3) the limited access to external medical reviews. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Proposes to Expand Behavioral Healthcare Access in 2024 OPPS Rule

The Centers for Medicare & Medicaid Services (CMS) on Friday proposed expanding access to behavioral healthcare services through coverage of intensive outpatient services.   Currently, Medicare covers and pays for various behavioral healthcare services, including inpatient psychiatric hospitalizations, partial hospitalizations services, and outpatient therapeutic services; however, there is a gap in coverage when Medicare beneficiaries require levels of services more frequent than individual outpatient therapy visits, but less intensive than a partial hospitalization program. The agency’s 2024 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule includes proposals to implement provisions of the Consolidated Appropriations Act, 2023 (CAA, 2023) that created a new benefit category for Intensive Outpatient Program (IOP) services. CMS proposed to establish payment and program requirements for the benefit across various settings, including hospital outpatient departments, Community Mental Health Centers (CMHCs), Federally Qualified Health Centers (FQHCs), and Rural Health Clinics (RHCs) effective Jan. 1, 2024. CMS also proposed to establish payment for IOP services provided by Opioid Treatment Programs (OTPs) effective Jan. 1, 2024, and is clarifying that these intensive behavioral healthcare services are available for individuals with mental health conditions and for individuals with substance use disorders. “This proposed rule reflects CMS’ commitment to ensure Medicare is comprehensive in its ability to address patient needs, filling gaps in the health care system including behavioral health,” Meena Seshamani, M.D., deputy administrator and director for CMS’ Center for Medicare, said in a news release. “Through these proposals, we will ensure people get timely access to quality care in their communities, leading to improved outcomes and better health.” CMS provided the following details about the scope of benefits for IOP and its proposals for each setting: Scope of Benefits for IOP: CMS proposed a scope of benefits for IOP services that the CAA, 2023 mandates. The agency noted an IOP is a distinct and organized outpatient program of psychiatric services provided for individuals who have an acute mental illness or substance use disorder, consisting of a specified group of behavioral healthcare services paid on a per-diem basis under the OPPS or other applicable payment system when furnished in hospital outpatient departments, CMHCs, FQHCs and RHCs. CMS proposed to base the per-diem costs of items and services included in IOP that have been, and are, paid for by Medicare either as part of the PHP benefit or under the OPPS more generally. Physician Certification and Plan of Treatment Requirements for IOP: The CAA, 2023 requires that a physician determine that each patient needs a minimum of nine hours of IOP services per week, and this determination must occur no less frequently than every other month. CMS proposes to codify this requirement in regulation for IOP provided in all settings and is soliciting comments on the recertification period. IOP Payment Rates and Policy in Hospital Outpatient Departments and CMHCs: CMS proposed to establish two IOP ambulatory payment classifications for each provider type: one for days with three services per day and one for days with four or more services per day. For CY 2024, CMS proposed to calculate hospital-based and CMHC IOP payment rates for three services per day and four or more services per day based on cost per day using a broader set of OPPS data that includes PHP days and non-PHP days. CMS noted that while no Medicare IOP benefit currently exists, the agency believes using the broader OPPS data set would allow us to capture data from hospital claims that are not identified as IOP, but that include the service codes and intensity required for an IOP day. Opioid Treatment Program (OTP) Settings: CMS proposed to extend IOP coverage to include OTPs. The agency also proposed to establish a weekly payment adjustment via an add-on code for IOP services furnished by OTPs for the treatment of opioid use disorder (OUD) and to revise the definition of OUD treatment services to include IOP services. The payment adjustment would also be updated based on the Medicare Economic Index and receive the Geographic Adjustment Factor if finalized. CMS proposed that Medicare would pay for IOP services that OTPs provide as long as each service is medically reasonable and necessary, and not duplicative of any service paid for under any bundled payments billed for an episode of care in a given week. For an OTP to receive the additional payment adjustment for IOP services, a physician must certify that the beneficiary requires a higher level of care intensity compared to existing OTP services, and the certification, plan of care, and all other applicable requirements are met. CMS said it believes that payment for IOP services that OTPs provide would improve continuity of care between different treatment settings and levels of care, expand access to treatment for Medicare beneficiaries with an OUD and further promote health equity for racial/ethnic populations and older beneficiaries. RHCs and FQHCs: For CY 2024, CMS proposed to make conforming regulatory text changes to applicable RHC and FQHC regulations related to the scope of IOP benefits and services, certification and plan of care requirements, and special payment rules for IOP services as the CAA, 2023 mandates. The scope of IOP benefits and certification and plan of care requirements will be the same for RHCs and FQHCs as described above for hospitals. CMS proposed to pay for three IOP services/day, and according to the statute, payment is based on the hospital rate. This means RHCs would be paid the three-services per day payment amount for hospital outpatient departments. For FQHCs, payment would be the lesser of a FQHC’s actual charges or the three-services per day payment amount for hospital outpatient departments. For grandfathered tribal FQHCs, payment would be the Medicare outpatient per visit rate as the Indian Health Service has established when furnishing IOP services, and payment is based on the lesser of a grandfathered tribal FQHC’s actual charges or the Medicare outpatient per-visit rate. Regarding OPPS payment rates, CMS proposed updating OPPS payment rates for hospitals by 2.8%. This update is based on the projected hospital market basket percentage increase of 3.0%, reduced by a 0.2 percentage point for the productivity adjustment.

CMS Includes Behavioral Healthcare Provisions in Proposed 2024 Physician Fee Schedule

CMS on Thursday included a provision to extend OTP periodic assessment flexibilities via audio-only telehealth through the end of 2024 in the agency’s proposed 2024 Physician Fee Schedule rule. CMS noted it will continue to consider the value of extending this flexibility permanently. For mental healthcare, the agency’s proposed rule included implementing the CAA, 2023’s requirements that marriage and family therapists (MFTs) and mental health counselors (MHCs) can bill through the Medicare program. The agency also proposed HCPCS codes for crisis psychotherapy services, and proposed permitting Behavior Assessments and Intervention to be performed and billed by clinical social workers, MFTs and MHCs. Increases for timed PFS behavioral health services will be implemented over four years, according to CMS.

988 Suicide & Crisis Line Adds New Services as One-Year Anniversary Approaches

This week the Biden administration announced it has added Spanish text and chat services as well as specialized services for LGBTQI+ youth and young adults to the nation’s 988 Suicide & Crisis Lifeline following a successful pilot test. This Sunday marks the one-year anniversary of 988’s launch, and the Biden administration reports the Lifeline has answered nearly 5 million contacts in the past year—2 million more than were received in the previous 12 months—following a $1 billion investment from the administration. Meanwhile, in June the National Alliance on Mental Illness (NAMI) released its 988 Suicide & Crisis Lifeline Tracker that found familiarity with 988 remains low despite increasing overall awareness since it launched last July. NAMI found that 63% of Americans report at least hearing something about 988, up 19% percentage points since September 2022 and up 41 percentage points since May 2022. Still, only 17% of Americans say they are very or somewhat familiar with it, while only 4% say they are very familiar with it. The study also found Americans 49 and under are more likely than older Americans to report having heard of 988, and LGBTQ+ Americans are twice as likely to say they are familiar with it than non-LGBTQ+ Americans.

White House Releases National Response Plan to Address Emerging Threat of Fentanyl Combined with Xylazine

The White House Office of National Drug Control Policy this week released a national response plan to combat the dangerous and deadly combination of xylazine mixed with fentanyl. Earlier this year, the Biden administration used its executive designation authority for the first time when it declared xylazine mixed with fentanyl as an emerging threat in the United States. “Since we announced the emerging drug threat earlier this year, we’ve been working tirelessly to create the best plan of attack to address this dangerous and deadly substance head-on,” Rahul Gupta, M.D., director of the White House Office of National Drug Control Policy (ONDCP), said in an announcement. “Now, with this National Response Plan, we are launching coordinated efforts across all of government to ensure we are using every lever we have to protect public health and public safety and save lives.” The plan outlines action steps and key responsibilities for departments and agencies across the federal government and directs them to develop and submit an Implementation Report to the White House in 60 days. As required by statute in the SUPPORT Act and the Criteria for Designating Evolving and Emerging Drug Threats (Dir. No. 2022-002), the national response plan’s goal is to terminate fentanyl combined with xylazine as an emerging threat. This will require a 15% reduction (compared with 2022 as the baseline year) of xylazine positive drug poisoning deaths in at least three of four U.S. census regions by 2025.

NABH Members Highlight Behavioral Health EMR Gap in Health Affairs Commentary

A recent Health Affairs commentary explores the 2009 HITECH Act’s failure to include behavioral healthcare providers in its $19 billion of meaningful use incentives and the resulting lag in electronic medical record (EMR) adoption in the behavioral healthcare segment. “There was no clear rationale for this exclusion beyond implicit prioritization of physical health over mental health in the competition for funding dollars. And this disparity continues to this day,” wrote the article’s authors William Shrank, M.D., Christopher Hunter, M.B.A., and Andrew Lynch, Ph.D., adding that EMR use has exceeded 95% since 2014 but only 6% of outpatient behavioral healthcare facilities and 29% of substance use disorder treatment centers use EMRs. Shrank is a venture partner at Andreeseen Horowitz; Hunter is CEO at NABH member Acadia Healthcare, and Lynch serves as Acadia’s chief strategy officer. The article reviews earlier legislative attempts to bridge the EMR gap, including the bill Rep. Doris Matsui (D-Calif.) introduced last year.

Reminder: Provider Relief Fund Reporting Portal Now Open for Period 5

The Health Resources and Services Administration has announced that the Provider Relief Fund (PRF) Reporting Portal is now open for Reporting Period 5.   Recipients who received one or more General Distribution, Targeted Distribution, or ARP Rural Distribution payments exceeding $10,000, in the aggregate, from Jan. 1, 2022 to June 30, 2022 are required to report on the use of their payments during Reporting Period 5. This latest reporting period will close at 11:59 p.m. ET on Sept. 30, 2023. Click here to learn more.

In Case You Missed It: NABH Education & Research Foundation Workforce Resources

If you missed the 2023 Annual Meeting, be sure to access the workforce resources that the NABH Education and Research Foundation featured at the meeting and are available on the Foundation’s Resources page. First, watch speaker John Pallasch’s presentation and listen to the question-and-answer period from NABH members. Pallasch, founder and CEO of workforce consultancy One Workforce Solutions, served previously as the Senate-confirmed assistant secretary for employment and training at the U.S. Labor Department. Pallasch’s presentation challenged attendees to think beyond recruitment and retention and instead focus on re-designing the U.S. workforce system. He offered practical ideas for how NABH members can get involved in this process. Also be sure to use the workforce resource guide that the Foundation co-branded with One Workforce Solutions. The guide includes links to state workforce agencies, workforce development boards, and more.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week:

The Centers for Disease Control and Prevention estimates that 109,940 people died of an overdose between February 2022 and February 2023, compared with 110,063 people in the same period the previous year. ONDCP cited the seizure of illicit drugs at the nation’s borders and access to naloxone as reasons for the continued flattening in the overdose rate. For questions or comments about this CEO Update, please contact Jessica Zigmond

Provider Relief Fund Reporting Portal Now Open for Period 5

The Health Resources and Services Administration has announced that the Provider Relief Fund (PRF) Reporting Portal is now open for Reporting Period 5.   Recipients who received one or more General Distribution, Targeted Distribution, or ARP Rural Distribution payments exceeding $10,000, in the aggregate, from Jan. 1, 2022 to June 30, 2022 are required to report on the use of their payments during Reporting Period 5. This latest reporting period will close at 11:59 p.m. ET on Sept. 30, 2023. Click here to learn more.

NIH Research Shows Lack of Buprenorphine for Adolescents in RTFs

Only one in four residential treatment facilities that treat adolescents in the United States for opioid use disorder offer buprenorphine, the sole U.S. Food and Drug Administration-approved medication for 16- to 18-year-olds, the National Institutes of Health (NIH) reports. An NIH-funded research team identified 354 facilities nationwide that offered treatment for substance use in a residential treatment setting for people aged 17 and younger. Researchers called each facility to inquire about the treatments offered, and, in each case, a researcher posed as the relative of a 16-year-old with a recent, non-fatal fentanyl overdose. They found that 160 of these facilities, or 45%, provided residential treatment to patients younger than 18 years old. Of the facilities that treated adolescents, only 39, or less than 25%, offered buprenorphine to 16- to 18-year-old patients. In contrast, almost two-thirds of adult residential facilities offer buprenorphine. The likelihood of offering buprenorphine varied by region, from 40% in the Northeast to 18% in the West, the NIH reports. Meanwhile, the situations in which facilities offered buprenorphine also varied. Only 20 facilities—or one in eight—offered buprenorphine for ongoing treatment, and 12 offered it to patients younger than 16. “These residential treatment centers see some of the most vulnerable adolescents in our communities,” lead researcher Caroline King, M.P.H., and an M.D./Ph.D. student in the Oregon Health & Science University School of Medicine, said in an NIH announcement about the findings. “But they don’t offer the standard of care for these kids. With rising fentanyl-related overdoses among adolescents, we really need these centers to provide the best care.”

In Case You Missed It: NABH Education & Research Foundation Workforce Resources

If you missed the 2023 Annual Meeting, be sure to access the workforce resources that the NABH Education and Research Foundation featured at the meeting and are available on the Foundation’s Resources page. First, watch speaker John Pallasch’s presentation and listen to the question-and-answer period from NABH members. Pallasch, founder and CEO of workforce consultancy One Workforce Solutions, served previously as the Senate-confirmed assistant secretary for employment and training at the U.S. Labor Department. Pallasch’s presentation challenged attendees to think beyond recruitment and retention and instead focus on re-designing the U.S. workforce system. He offered practical ideas for how NABH members can get involved in this process. Also be sure to use the workforce resource guide that the Foundation co-branded with One Workforce Solutions. The guide includes links to state workforce agencies, workforce development boards, and more.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week:

New antitransgender legislation passed in several U.S. states is raising concern among psychologists about the effect on the mental health of trans individuals—in particular children and teens—as well as members of the LGBTQ+ community, the American Psychological Association reports. For questions or comments about this CEO Update, please contact Jessica Zigmond.

MedPAC Report to Congress Analyzes Behavioral Health Services and Patients

In its annual report to Congress last week, the Medicare Payment Advisory Commission (MedPAC) examined behavioral health services covered under Medicare’s inpatient and outpatient prospective payments systems and physician fee schedule. The 76-page report’s behavioral health chapter addresses Medicare beneficiaries’ service utilization patterns, Medicare spending trends to providers and clinicians, and payment adequacy and margins. Regarding access, the report notes a drop in inpatient psychiatric facility (IPF) patient volume from 2019 through 2021 (the most recent data evaluated) due to the COVID-19 pandemic. Meanwhile, during the same period, the occupancy rates grew in government IPFs—an indicator of service shortages for patients with severe mental illness. Concerning the 2021 acuity level of IPF patients relative to beneficiaries in other settings, IPF patients were 3.5 times more likely to be disabled and 2.4 times more likely to have low-income status (eligible for Part D low-income subsidy or dually-qualified for Medicare and Medicaid), metrics used as proxy indicators of acuity, according to the report. For telehealth, among other findings, MedPAC cited the widely recognized increased use in telehealth services for behavioral health patients, which grew to 28% in 2021 from 1% of Part B behavioral health services in 2019. MedPAC recommends gathering more information to assess the alignment between payments and the cost of care for ancillary and other behavioral health services, as well as additional data about patient-level outcomes. These additional data would be used to better understand variation in Medicare margins across IPF facility types, including differences due to scale and the mix of patients in different IPFs. The report also provides data on service utilization for patients affected by the Medicare’s 190-day-limit policy.

DOJ Releases Guidelines for Managing Substance Withdrawal in Jails

The U.S. Justice Department’s (DOJ) Bureau of Justice Assistance and the National Institute of Corrections this week released Guidelines for Managing Substance Withdrawal in Jails: A Tool for Local Government Officials, Jail Administrators, Correctional Officers, and Health Care Professionals.   In an announcement, DOJ said the document supports the department’s commitment to increasing access to evidence-based treatment for individuals with SUDs and those at risk for overdose, including individuals who are incarcerated or reentering their communities.   “These guidelines are a critical and much-needed resource to support local government officials, jail administrators, correctional officers and healthcare professionals faced with the difficult task of managing substance withdrawal in jail settings,” Associate Attorney General Vanita Gupta said in a statement. “Providing this new, evidence-based tool and treatment guidance, developed by a committee of clinical and correctional experts, will better safeguard the health and well-being of individuals at risk for or experiencing substance withdrawal in jails.”

DEA Now Requires One-Time Training for Buprenorphine Prescribing

Starting this week, the Drug Enforcement Agency (DEA) requires clinicians who register to prescribe controlled medications to complete a new, one-time, eight-hour training. In January, the Substance Abuse and Mental Health Services Administration (SAMHSA) announced clinicians no longer need a federal waiver to prescribe buprenorphine to treat opioid use disorder. Instead, the DEA now requires all clinicians prescribing any controlled substance to complete a one-time training. Exceptions for the training requirement include practitioners who are board-certified in addiction medicine or addiction psychiatry, and those who graduated from a medical, dental, physician assistant, or advanced practice nursing school in the United States within five years of June 23, 2023. In addition, Rural Health Clinics (RHCs) will have the opportunity to apply for a $3,000 payment on behalf of each provider who received buprenorphine waiver training between Jan. 1, 2019 and Jan. 25, 2023 (when Congress eliminated the waiver requirement). According to the Health Resources and Services Administration, about $900,000 in program funding remains available for RHCs and will be paid on a first-come, first-served basis.

The International Certification and Reciprocity Adopts SAMHSA’s National Model Standards for Peers

The International Certification and Reciprocity Consortium (IC&RC) has announced it has adopted SAMHSA’s National Model Standards for Peer Support Certification in the form of a new credential. In an announcement, the IC&RC said this national entry-level peer credential is intended to be the first rung of a career ladder that will lead to stronger substance use disorder (SUD) workforce development that is needed greatly nationwide. The IC&RC is the first—and currently only—nationally recognized, peer-certification organization to adopt the standards.

FDA Publishes First Draft Guidance on Psychedelic Drug Trials

The U.S. Food and Drug Administration (FDA) has published its first draft guidance on clinical trials for psychedelic drugs as research on using psychedelic drugs to treat conditions such as depression and post-traumatic stress disorder increases. In an announcement, FDA noted that developing psychedelic drugs poses several challenges, including minimizing the risk of the drugs being misused and addressing the role that psychotherapy plays in psychedelic drug administration. “By publishing this draft guidance, the FDA hopes to outline the challenges inherent in designing psychedelic drug development programs and provide information on how to address these challenges,” Tiffany Farchione, director of the division of psychiatry in FDA’s drug center, said in a news release. “The goal is to help researchers design studies that will yield interpretable results that will be capable of supporting future drug applications.”

GAO Examines Behavioral Healthcare Services in Critical Access Hospitals

A new Government Accountability Office (GAO) study of 10 critical access hospitals (CAHs) found that these providers offered behavioral healthcare services in a variety of ways in various settings, including emergency departments, inpatient services, and outpatient services. Unlike other hospitals, under Medicare fee-for-service, CAHs are paid based on the cost of providing services in most, but not all, care settings. GAO researchers received mixed views on how Medicare fee-for-service payment policies affect CAHs’ ability to provide behavioral healthcare services in various settings that are not paid solely based on cost. GAO said officials from multiple CAHs and stakeholders said factors outside Medicare were “substantial challenges” to their ability to provide behavioral healthcare services and patients’ access to these services. “Hiring and recruitment of behavioral health professionals, such as psychiatrists and licensed clinical social workers, was cited as one of their biggest challenges due to nationwide workforce shortages,” the study said. “In addition, they said shortages of inpatient psychiatric beds made it difficult to find inpatient treatment for their patients,” the study continued, adding that patients were sometimes stuck in an emergency department for several days waiting to be transferred to an open psychiatric bed elsewhere in their community or state.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week:

The two most common mental disorders among adults aged 18 to 65 were major depressive disorder (15.5%, or about 31.4 million adults) and generalized anxiety disorder (10%, or about 20.2 million adults), according to the SAMHSA-funded Mental and Substance Use Disorders Prevalence Study from RTI International. The NABH team wishes all its members, their teams, and their families a safe and happy Independence Weekend! For questions or comments about this CEO Update, please contact Jessica Zigmond.

2023 NABH Annual Meeting Presentations Now Available

Earlier this week NABH posted all 2023 Annual Meeting presentations for which the association has received permission to share publicly. Please remember to save the date for next year’s Annual Meeting: May 13-15, 2024 at the Salamander Washington, DC. We look forward to seeing you then!

We Want Your Opinion: Please Submit Your 2023 Annual Meeting Evaluation!

NABH welcomes your feedback on the 2023 Annual Meeting held in Washington, D.C. last week. If you attended this year’s Annual Meeting, please take a moment to complete NABH’s 10-question evaluation form if you have not done so already. Your comments help to inform future NABH Annual Meetings. Thank you for your time!

SAMHSA Releases Resource on Findings from Drug-Related ED Visits in 2022

Alcohol was reported in the highest percentage of drug-related emergency department (ED) visits (45.0%) in 2022, followed by opioids (12.7%) and cannabis (11.9%), according to data from the Drug Abuse Warning Network (DAWN): Findings from Drug-Related Emergency Department Visits, 2022 that the Substance Abuse and Mental Health Services Administration (SAMHSA) released this week. DAWN is a nationwide public health surveillance system that captures data on ED visits related to recent substance use directly from the electronic health records of participating hospitals. In 2022, DAWN identified 143,596 (unweighted) drug-related ED visits from 53 participating hospitals. These data were analyzed to generate 1) nationally representative weighted estimates for all drug-related ED visits, 2) the top drugs involved in drug-related ED visits, 3) for different opioid types involved in ED visits, 4) to describe polysubstance in ED visits, and 5) to identify newly mentioned drugs in 2022. The analysis for 2022 also showed heroin (5.6%) and prescription or other opioid (5.0%) were reported more often than fentanyl (2.7%) in drug-related ED visits.

CDC: Nearly One in Five U.S. Adults Report Having Ever Been Diagnosed with Depression

Data from the Centers for Disease Control and Prevention (CDC) show nearly one in five U.S. adults reported having ever been diagnosed with depression, although the rate – averaging at 18.4% in 2020 –varies significantly by state and county. State-level, age-standardized estimates ranged from 12.7% in Hawaii to 27.5% in West Virginia. Meanwhile, model-based, age-standardized, county-level prevalence estimates ranged from 10.7% to 31.9%, and there was considerable state-level and county-level variability. The CDC notes decisionmakers can use these estimates to guide resource allocation to areas where the need is greatest, possibly by implementing recommendations from The Guide to Community Preventive Services Task Force and SAMHSA.

NIH Study Deepens Understanding of Possible Mechanism Through Which Xylazine Affects Overdose Risk

A new study in rats suggests that xylazine, the active ingredient in a non-opioid veterinary tranquilizer not approved for human use, can worsen the life-threatening effects of opioids. Published in Psychopharmacology, the study’s findings imply that when used in combination with opioid drugs such as fentanyl and heroin, xylazine may damage the ability of the brain to get enough oxygen, one of the most dangerous effects of opioid drugs that can lead to death. Research has shown xylazine is often added to illicit opioids, including fentanyl, and that xylazine has been increasingly detected in the illicit opioid supply. “Drug mixtures containing both xylazine and opioids such as fentanyl demonstrate how rapidly the drug supply can change, and how dangerous products can proliferate despite rampant overdose deaths,” Nora Volkow, M.D, director of the National Institute on Drug Abuse – which led the study – said in a statement about the study. “Understanding the mechanisms behind how xylazine contributes to drug overdoses is essential to enable us to develop interventions that can reverse overdoses and save lives,” she continued. “In the meantime, naloxone, an opioid overdose reversal medication, should always be administered in the event of an overdose because xylazine is most often combined with opioids such as fentanyl.”

Fact of the Week:

Men had a two-to-three times greater rate of overdose mortality from opioids – such as fentanyl and heroin – and psychostimulants –such as methamphetamine and cocaine – than women, according to a new study published in Neuropsychopharmacology. For questions about CEO Update, please contact Jessica Zigmond.      

2023 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2023 Annual Meeting that starts on Monday, June 12 in Washington, D.C. This year’s Annual Meeting celebrates two important milestones for NABH: the association’s 90^th anniversary and the 15^th anniversary of the Mental Health Parity and Addiction Equity Act (MHPAEA). We’re eager to remind our members of the many ways the behavioral healthcare community has helped change the U.S. healthcare system, and, in turn, helped improve and save lives in the last nine decades. Mostly, though, we’re looking ahead. This year’s Annual Meeting theme – Securing the Promise of Parity – is a call to action for the work that remains to ensure MHPAEA is implemented fully and fairly. NABH is pleased to welcome HHS Secretary Xavier Becerra, J.D. on Monday, and you also won’t want to miss our parity panel with NABH President and CEO Shawn Coughlin, U.S. Labor Department Assistant Secretary for Employee Benefits Security Lisa Gomez, and former U.S. Rep. Patrick Kennedy (D-R.I.), founder of The Kennedy Forum, on Tuesday. We’ll conclude our meeting on Wednesday with Sen. Chris Murphy (D-Conn.), who will address attendees at this year’s policy breakfast. Details about these and other sessions and events follow below. To prepare for the meeting, view our preliminary program, learn more about this year’s speakers, and see our list of exhibitors and sponsors.

Be Sure to Access the 2023 NABH Annual Meeting Mobile App

Again this year, attendees will have access to all Annual Meeting programming and materials through NABH’s online mobile app. On Monday, June 12, NABH will send all attendees an Annual Meeting alert with a link to the app that will display important details about sessions, events, exhibitors and sponsors, our 2023 advocacy priorities, restaurant recommendations in the Washington area, and more. Attendees can also access the link through a QR code near the Registration Desk at the meeting.

HHS Secretary Becerra to Kick Off Annual Meeting

HHS Secretary Xavier Becerra, the 25^th secretary of the U.S. Health and Human Services Department and the first Latino to hold that office, will open this year’s Annual Meeting on Monday, June 12 at 2:15 p.m. in the Salamander hotel’s Grand Ballroom. Secretary Becerra will offer brief remarks and then engage in a question-and-answer session with 2023 NABH Board Chair Harsh Trivedi, M.D., M.B.A., president and CEO of Sheppard Pratt. Previously Secretary Becerra was California’s attorney general and before that served for 12 terms in the U.S. House of Representatives, where he was the first Latino to serve as a member of the powerful House Ways and Means Committee. He also served as chairman of his party’s caucus and as the ranking member of both the Ways and Means Subcommittee on Health and Ways and Means Subcommittee on Social Security. Please join us in welcoming him and be sure to stay for additional remarks from NABH Board Chair Trivedi, who will introduce a brief video commemorating our 90 years as an advocacy association.

Monday’s General Sessions to Examine Workforce Challenges and Potential Solutions

Following Monday’s opening session, NABH will present back-to-back sessions that will examine current behavioral healthcare workforce challenges and how to address them. At 3 p.m., NABH will welcome John Pallasch, former Senate-confirmed assistant secretary for employment and training at the U.S. Labor Department (DOL) and the founder and CEO of One Workforce Solutions, a workforce consultancy in Aiken, S.C. He served previously as executive director of Kentucky’s Office of Employment and Training, and—in his first stint at DOL—as deputy assistant secretary in the department’s Mine Safety and Health Administration. Pallasch has spent more than 20 years influencing organizational personnel, efficiency, and productivity in the public and private sectors. He will draw from those experiences to help NABH members think more critically about their workforce challenges and more creatively about how to solve them. Following Pallasch’s presentation, the NABH Education and Research Foundation will lead a panel discussion about workforce challenges and potential solutions at 4 p.m. ET. New Season/Colonial Management Group CEO Jim Shaheen, the foundation’s vice president, will moderate the hourlong panel that will feature Hackensack Meridian Health Carrier Clinic President Donald Parker, the foundation’s president; Vanderbilt Psychiatric Hospital and Clinics President Mary Pawlikowski, the foundation’s secretary; and Susan Wright, director of BayCare Behavioral Health’s Behavioral Health Operations and this year’s Annual Meeting program chair. Panelists will discuss best practices on a variety of topics and answer questions from Shaheen and audience members. Earlier presenter John Pallasch will also participate in the panel’s question-and answer period. Please join us for both sessions in the Salamander’s Grand Ballroom.

Tuesday’s Parity Panel to Feature DOL Official Lisa Gomez and Former U.S. Rep. Patrick Kennedy on Tuesday, June 13

NABH President and CEO Shawn Coughlin will moderate a parity panel discussion with Lisa Gomez, assistant secretary for employee benefits security at the U.S. Labor Department, and former U.S. Rep. Patrick Kennedy (D-R.I.). on Tuesday, June 13 at 9:30 a.m., the Annual Meeting’s second day. Before she was sworn in last October, Gomez was a partner with the law firm Cohen, Weiss and Simon LLP and chair of the firm’s management committee. She has deep technical and practical experience in the field of employee benefits law and spent almost three decades representing various Taft-Hartley and multiemployer pension and welfare plans, single employer plans, jointly administered training program trust funds, a federal employees health benefit plan, and other plans covering employees in a range of industries. Gomez earned her bachelor’s degree at Hofstra University and her law degree at Fordham. Former Rep. Kennedy is the CEO of The Kennedy Forum, a not-for-profit he founded in 2013 to unite advocates, business leaders, and government agencies to advance evidence-based practices, policies, and programming mental health and addiction. During his time in Congress, Kennedy was the lead author of MHPAEA. Kennedy is also the founder of Don’tDenyMe.org, an educational campaign that empowers consumers and providers to understand parity rights and connects them to essential appeals guidance and resources; and co-founder of One Mind, an organization that pushes for greater global investment in brain research. The panel will take place in the Grand Ballroom and will discuss the landmark 2008 parity law and the work that remains to secure the law’s promise.

Center for Medicaid & CHIP Services CMO Aditi Mallick, M.D. to Address Attendees on Tuesday

Aditi Mallick, M.D., chief medical officer at the Center for Medicaid and CHIP (Children’s Health Insurance Program) Services (CMCS), will discuss her department’s mental health and substance use disorder initiatives at the 2023 Annual Meeting on Tuesday, June 13 at 11 a.m. Dr. Mallick leads the Center’s clinical strategy and cross-center work on health equity, social determinants of health, and innovation in whole-person care among other areas. Before joining CMCS, Dr. Mallick led the COVID-19 Response Command Center for the North Carolina Department of Health and Human  Services (NCDHHS), where she oversaw strategic and operational efforts around vaccination, testing, case investigation, and contact tracing statewide. A core focus of her COVID-19 work was ensuring equitable access and improving outcomes for historically marginalized populations. Before her work at NCDHHS, Dr. Mallick worked closely with a range of healthcare stakeholders across the public and private sectors – including state Medicaid agencies, provider organizations, managed care organizations, and other payors – focusing on strategy, innovation, and data-driven change implementation. Dr. Mallick continues to care for patients and brings that experience to her work at CMS. She earned her bachelor’s degree with honors from Harvard College, her medical degree from Stanford University School of Medicine, and completed internal medicine residency at Massachusetts General Hospital and Harvard Medical School.

NABH President and CEO Shawn Coughlin to Address Attendees at Annual Meeting Luncheon

Please join us for this year’s Annual Meeting Luncheon on Tuesday, June 13 at noon to hear from NABH President and CEO Shawn Coughlin. Coughlin will provide updates on NABH’s work and initiatives and will help prepare any attendees who will head to Capitol Hill for congressional visits following the luncheon. This year’s Annual Meeting Luncheon will take place in the hotel’s Gallery Room.

Hill Day Returns!  

For the first time since 2019, NABH is eager to welcome its members and guests back to Hill Day on Tuesday, June 13 from 1:30 to 5 p.m. ET. This year NABH is working with the firm Advocacy Associates to help schedule congressional meetings and briefings on Capitol Hill for interested Annual Meeting attendees during Hill Day. NABH will help prepare interested attendees by providing materials through a mobile app. For those attending Hill Day this year: please look for additional correspondence on Friday, June 9. Also, Hill Day participants—and all Annual Meeting attendees—can review the association’s 2023 Advocacy Priorities and Contingency Management fact sheet before or during the Annual Meeting.

U.S. Sen. Chris Murphy to Address Attendees at Annual Meeting Policy Breakfast

U.S. Sen. Chris Murphy (D-Conn.) will address attendees at the 2023 Annual Meeting policy breakfast on Wednesday, June 14 at 9:30 a.m. ET. Sen. Murphy serves on the Senate Foreign Relations Committee, the Health, Education, Labor and Pensions (HELP) Committee, and the Appropriations Committee. Before he was elected to the Senate, Sen. Murphy represented Connecticut’s fifth congressional district for three terms in the U.S. House of Representatives. Murphy is known in Congress as a leading voice for stronger anti-gun violence measures, a smarter foreign policy, and reform of our nation’s mental health system. Before he was elected to Congress, Murphy served for eight years in the Connecticut state legislature. Murphy graduated with honors from Williams College in Massachusetts and received his law degree from the University of Connecticut School of Law. Please help us welcome Sen. Murphy on Wednesday.

The NABH team wishes everyone a safe trip to Washington, and we look forward to seeing you soon!

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

U.S. Sen. Chris Murphy to Address Attendees at Annual Meeting Policy Breakfast

NABH is pleased to announce U.S. Sen. Chris Murphy (D-Conn.) will address attendees at the 2023 Annual Meeting policy breakfast on Wednesday, June 14 at 9:30 a.m. ET. Sen. Murphy serves on the Senate Foreign Relations Committee, the Health, Education, Labor and Pensions (HELP) Committee, and the Appropriations Committee. Before he was elected to the Senate, Sen. Murphy represented Connecticut’s fifth congressional district for three terms in the U.S. House of Representatives. Murphy is known in Congress as a leading voice for stronger anti-gun violence measures, a smarter foreign policy, and reform of our nation’s mental health system. Before he was elected to Congress, Murphy served for eight years in the Connecticut state legislature. Murphy graduated with honors from Williams College in Massachusetts and received his law degree from the University of Connecticut School of Law. Please help us welcome Sen. Murphy on June 14. And if you haven’t done so yet, please be sure to register for the Annual Meeting.

NABH Education and Research Foundation to Present Workforce Panel at Annual Meeting

The NABH Education and Research Foundation is pleased to lead a panel discussion about workforce challenges and potential solutions during the Annual Meeting on Monday, June 12 at 4 p.m. ET. New Season/Colonial Management Group CEO Jim Shaheen, the foundation’s vice president, will moderate the hourlong panel that will feature Hackensack Meridian Health Carrier Clinic President Donald Parker, the foundation’s president; Vanderbilt Psychiatric Hospital and Clinics President Mary Pawlikowski, the foundation’s secretary; and Susan Wright, director of BayCare Behavioral Health’s Behavioral Health Operations and this year’s Annual Meeting program chair. Panelists will discuss best practices on a variety of topics and answer questions from Shaheen and audience members. The panel will follow a 3 p.m. workforce presentation from John Pallasch, founder and CEO of One Workforce Solutions and former assistant secretary for employment and training at the U.S. Labor Department. Pallasch will participate later in the panel’s question-and answer period. Please join us for both sessions in the Salamander’s Grand Ballroom on the Annual Meeting’s first day. We look forward to seeing you there!

Reminder: Hill Day is Back!  

NABH is excited to welcome its members and guests back to Hill Day during the 2023 Annual Meeting! This year NABH is working with the firm Advocacy Associates to help schedule congressional meetings and briefings on Capitol Hill for interested Annual Meeting attendees during Hill Day on Tuesday, June 13 from 1:30 to 5 p.m. ET. NABH will help prepare interested attendees by providing materials through a mobile app. There is still time to take advantage of this free opportunity. Please indicate that you want to participate in Hill Day when you register for the 2023 Annual Meeting or contact Emily Wilkins at NABH.

SAMHSA Awards Grants to Bolster Mobile Response Teams for 988 Lifeline

The Substance Abuse and Mental Health Services Administration (SAMHSA) has awarded 13 grants to communities to create new or enhance existing mobile crisis response teams to support the national 988 Suicide and Crisis Lifeline. In an announcement, HHS noted the Biden administration has invested about $3.8 billion through the American Rescue Plan and more than $800 million through the Bipartisan Safer Communities Act through SAMHSA programs as part of President Biden’s effort to improve access to mental healthcare, prevent overdoses, and save lives. “The expansion of mobile crisis response across the country is a big part of our efforts to achieve comprehensive, responsive crisis care services,” HHS Assistant Secretary for Mental Health and Substance Use and SAMHSA leader Miriam Delphin-Rittmon, Ph.D., said in an announcement. “Responding effectively to behavioral health crises in our communities will involve strong partnerships among first responders, community-based support services, and 988 Lifeline call centers.” Click here to view the list of grant awardees.

Reminder: HRSA’s Substance Use Disorder Treatment and Recovery Loan Repayment Program Now Open

The Health Resources and Services Administration’s (HRSA) Substance Use Disorder Treatment and Recovery Loan Repayment Program (STAR LRP) application is open now through mid-July. Anyone who is a behavioral health clinician or support worker, clinical support staff, or trained in substance use disorders may apply to the STAR LRP and receive up to $250,000 in loan repayment. In exchange, loan recipients must work full time for six years in a STAR LRP-approved facility. The application process ends on Thursday, July 13 at 7:30 p.m. ET. Click here to learn more.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

More than half of Americans who suffer from schizophrenia or another mental illness didn’t get the care they needed in 2021, the National Alliance on Mental Illness reports. A recent analysis in Kaiser Health News shows that coverage often depends on where you live—and how coverage of early psychosis treatment can be lifesaving. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH 2023 Annual Meeting is Approaching: Be Sure You’re Registered!

NABH’s 2023 Annual Meeting—Securing the Promise of Parity—is a little more than two weeks away! Please review our online preliminary program, learn about this year’s speakers, view the list of exhibitors and sponsors, register for the meeting, and reserve your hotel room, if you haven’t done so yet. We look forward to seeing you in Washington!

U.S. Surgeon General Releases Advisory on Social Media and Youth Mental Health

U.S. Surgeon General Vivek Murthy, M.D. this week released Social Media and Youth Mental Health, a new advisory that shows while social media may offer some benefits, there are “ample indicators” that social media can pose a risk of harm to the mental health and well-being of children and adolescents. The advisory notes that social-media use by young people is nearly universal, with up to 95% of young people ages 13-17 reporting using a social media platform and more than a third saying they use social media “almost constantly.” “The most common question parents ask me is, ‘Is social media safe for my kids?’” Murthy said in a news release about the advisory. “The answer is that we don’t have enough evidence to say it’s safe, and in fact, there is growing evidence that social media use is associated with harm to young people’s mental health,” he continued. “Children are exposed to harmful content on social media, ranging from violent and sexual content, to bullying and harassment. And for too many children, social media use is compromising their sleep and valuable in-person time with family and friends,” he added. “We are in the middle of a national youth mental health crisis, and I am concerned that social media is an important driver of that crisis – one that we must urgently address.” Murthy’s office reported that adolescents spending more than three hours per day on social media face double the risk of experiencing poor mental health outcomes, such as symptoms of depression and anxiety; yet one 2021 survey of teenagers found that, on average, they spend 3.5 hours a day on social media.

NIMH Finds Youth Suicide Rates Increased During the COVID-19 Pandemic

The National Institute of Mental Health this week released research that shows 5,568 youth died by suicide during the first 10 months of the COVID-19 pandemic, which was higher than the expected number of deaths had the pandemic not occurred. Higher-than-expected suicide rates were found a few months into the pandemic, starting in July 2020. According to the research, the increase in suicide deaths varied significantly by sex, age, race and ethnicity, and suicide method. For this period, researchers also found higher-than-expected suicide deaths among males, preteens aged 5–12 years, young adults aged 18–24 years, non-Hispanic American Indian or Alaskan Native youth, and non-Hispanic Black youth as compared with before the pandemic. Suicide deaths involving firearms were also higher than expected, the study showed.

CMS Reports to Congress on SUD Planning Grant Implementation

The Centers for Medicare & Medicaid Services (CMS) has released the Initial Report to Congress that the SUPPORT Act requires. The 2018 law directs CMS to release three reports to Congress, and the one released this week provides details on states awarded planning grants under the SUPPORT Act, the criteria used to select these states, and initial activities proposed or carried out under the planning grants. Findings in the report are from the first 13 months of the planning period of the demonstration: Sept. 30, 2019-Oct. 31, 2020.

Now Open: HRSA’s Substance Use Disorder Treatment and Recovery Loan Repayment Program

The Health Resources and Services Administration (HRSA) announced this week that the agency’s Substance Use Disorder Treatment and Recovery Loan Repayment Program (STAR LRP) application is open now through mid-July. Anyone who is a behavioral health clinician or support worker, clinical support staff, or trained in substance use disorders may apply to the STAR LRP and receive up to $250,000 in loan repayment. In exchange, loan recipients must work full time for six years in a STAR LRP-approved facility. The application process ends on Thursday, July 13 at 7:30 p.m. ET. Click here to learn more. Also this week, HRSA announced a grant program for professionals focused on behavioral health workforce education and training for children, adolescents, and transitional-aged youth. The grant’s purpose is to address the behavioral health needs of children, adolescents, and transitional-aged youth by increasing the supply and distribution of behavioral health providers in rural and underserved communities. Click here to view the grant opportunity.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

A new study published in Health Affairs found that although almost all insurance plans covered immediate-release buprenorphine in 2021 (with a general trend of decreasing prior authorization requirements and quantity limits since 2017), only two payers had relatively low coverage of extended-release buprenorphine, with only 46% of commercial plans and only 19% of Medicare Advantage plans covering this formulation. The study authors recommended that policymakers and researchers “concerned with buprenorphine insurance barriers should shift their attention to extended-release buprenorphine.” For questions or comments about this CEO Update, please contact Jessica Zigmond.

Please Meet with NABH’s Exhibitors and Sponsors at the 2023 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 June 12-14 at the Salamander Washington, DC. Before then, you can view a complete list of our exhibitors and sponsors on our Annual Meeting homepage. Also, please be sure 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!

U.S. Labor Department Projects Five Mental Health Jobs Will Grow ‘Much Faster’ than Average from 2021-2031

The U.S. Labor Department’s (DOL) Bureau of Labor Statistics projects these five mental health-related careers will grow “much faster” than average between 2021-2031: mental health and substance abuse social workers; substance abuse, behavioral disorder, and mental health counselors; community health workers; healthcare social workers; and marriage and family therapists. “Together, they employed about 761,000 workers in 2021 —and they are expected to have more than 91,000 openings on average each year through 2031,” DOL reported in its blog. “The education typically required to enter these occupations ranges from a high school diploma to a master’s degree, and they all pay around or more than the $46,310 median for all occupations in 2022.” Click here to learn more about growth projection for each position.

CMS Releases Guide for Medicaid School-based Services

The Centers for Medicare & Medicaid Services (CMS) this week released a guide for Medicaid school-based services to make it easier for schools to deliver and receive payment for healthcare services to millions of eligible students. CMS worked with the U.S. Department of Education to produce the Comprehensive Guide to Medicaid Services and Administrative Claiming, which is a result of the Bipartisan Safer Communities Act. “With this guide, we are helping states and schools bring health care to kids where they are, rather than the other way around,” CMS Administrator Chiquita Brooks-LaSure said in a statement. “Children spend most of their waking hours in school. We also know that children have suffered serious declines in access to mental and behavioral healthcare services during the COVID-19 pandemic. We’re making it easier for states and schools to maximize Medicaid coverage to grow connections to care.” Medicaid and CHIP cover more than half of all U.S. children, or more than 41 million children, according to CMS. The guide is intended to help states and schools leverage Medicaid and CHIP, and it maps out how they can build a bridge between education and healthcare, including mental healthcare, to support children enrolled in these programs and help them thrive.

House and Senate Committees Press Insurers for Information on Claims

Two congressional oversight committees this week pressed the nation’s insurers for information regarding denial of claims in one instance and denial of care in Medicare Advantage in the second. Republicans from the House Energy and Commerce Committee sent a letter to Cigna President and CEO David Cordani asking for clarification after online news source ProPublica released an investigative report that suggested the insurance company’s physicians reject claims without reading them. Meanwhile, the Senate Homeland Security & Governmental Affairs Committee Permanent Subcommittee on Investigations hosted a hearing about delays and denials of care in Medicare Advantage. That hearing follows an April 2022 report from the HHS Office of Inspector General that found Medicare Advantage insurers have denied some coverage or payment for services that would have been covered under traditional Medicare.

Federally Supported Study Finds More than Half of Physicians Ranked Stigma as Highest Barrier to Treating Patients for OUD

A University of Vermont study of more than 450 clinicians and counselors in rural New England found that more than half (55%) ranked stigma as the highest barrier to treating patients for opioid use disorder (OUD) among other factors that included time and staffing, medication diversion, and organizational/clinic barriers. Meanwhile, 60% of physicians and 51% of counselors surveyed disagreed that medications for OUD “replace addiction to one kind of drug with another.” However, among clinicians with the ability to prescribe, there was considerable difference in this belief, depending on whether they were currently treating with medications for OUD, or MOUD. “More than 80% of those currently treating with MOUD believed it is not an addiction replacement; among those not currently treating with OUD, fewer than half felt that way,” the Federal Office of Rural Health Policy (FORHP) announced. FORHP is part of HHS’ Health Resources and Services Administration and supports the Center on Rural Addiction at the University of Vermont, which conducted the study.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

The Centers for Disease Control and Prevention reports that more Black Americans died from fentanyl overdoses than from any other drug in 2021 and at far higher rates than whites or Hispanics. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH to Host Parity Panel with DOL Official Lisa Gomez and Former U.S. Rep. Patrick Kennedy on Tuesday, June 13

NABH President and CEO Shawn Coughlin will moderate a parity panel discussion with Lisa Gomez, assistant secretary for employee benefits security at the U.S. Labor Department, and former U.S. Rep. Patrick Kennedy (D-R.I.). on Tuesday, June 13, the second day of the 2023 Annual Meeting. Before she was sworn in last October, Gomez was a partner with the law firm Cohen, Weiss and Simon LLP and chair of the firm’s management committee. She has deep technical and practical experience in the field of employee benefits law and spent almost three decades representing various Taft-Hartley and multiemployer pension and welfare plans, single employer plans, jointly administered training program trust funds, a federal employees health benefit plan, and other plans covering employees in a range of industries. Gomez earned her bachelor’s degree at Hofstra University and her law degree at Fordham. Former Rep. Kennedy is the CEO of The Kennedy Forum, a not-for-profit he founded in 2013 to unite advocates, business leaders, and government agencies to advance evidence-based practices, policies, and programming mental health and addiction. During his time in Congress, Kennedy was the lead author of the Mental Health Parity and Addiction Equity Act. Kennedy is also the founder of Don’tDenyMe.org, an educational campaign that empowers consumers and providers to understand parity rights and connects them to essential appeals guidance and resources, and co-founder of One Mind, an organization that pushes for greater global investment in brain research. The panel will begin at 9:30 a.m. ET in the Salamander’s Grand Ballroom and will discuss the landmark 2008 parity law and the work that remains to secure the law’s promise. Please be sure 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!

CMS Coverage for PHP Telehealth Services Ends With COVID-19 PHE’s Conclusion

The Centers for Medicare & Medicaid Services (CMS) has shared with NABH and other stakeholders the agency’s plans to end telehealth coverage for partial hospitalization program (PHP) services implemented during the COVID-19 Public Health Emergency (PHE) when the PHE concluded at the end of Thursday, May 11. In addition, CMS has explained that telehealth coverage will continue through December 2024 for Intensive Outpatient Program (IOP) services that qualify under the outpatient prospective payment system as “remote mental health services.” NABH continues to communicate with key Members of Congress to clarify the legislative intent behind the telehealth coverage extensions that were authorized in the Consolidated Appropriations Act, 2023 last December. The NABH team understands that some Members of Congress intended for the telehealth coverage extension to include PHP services. Given the persistent confusion on these matters, NABH has urged CMS to issue clarification in writing. NABH will keep members apprised of our efforts to extend telehealth coverage for PHP services.  

DEA Rule to Extend Telemedicine Flexibilities for Prescription of Controlled Substances Effective May 11

The U.S. Drug Enforcement Administration’s (DEA) temporary extension of COVID-19 telemedicine flexibilities for prescription of controlled medications took effect Thursday, May 11. Under the DEA’s rule, the agency has extended the full set of telemedicine flexibilities adopted during the PHE for six months through Nov. 11, 2023. For any practitioner-patient telemedicine relationships that have been or will be established up to Nov. 11, 2023, the full set of telemedicine flexibilities regarding prescription of controlled medications established during the PHE will extend for one year through Nov. 11, 2024. In a letter to DEA on March 31, NABH advocated to remove requirements for in-person medical examinations for Schedule II stimulant medications for ADHD and Schedule III-V mental health medications. Please contact Sarah Wattenberg, NABH’s director of quality and addiction services, with questions or comments.

SAMHSA and FDA Officials Release Letter to Practitioners to Promote Medication First Model

Officials from the Substance Abuse and Mental Health Services Administration (SAMHSA) and the U.S. Food and Drug Administration (FDA) this week sent a letter to healthcare practitioners noting that although counseling and other services are important parts of treatment plans, they should not be prerequisites for receiving medication. “An often-cited barrier to prescribing buprenorphine for the treatment of OUD is the perception that patients must engage in counseling and other services in order to start or continue receiving the medication,” wrote Miriam Delphin-Rittmon, Ph.D. and Patrizia Cavazzoni, M.D. “This letter serves to clarify the importance of counseling and other services as part of a comprehensive treatment plan, but to also reiterate that the provision of medication should not be made contingent upon participation in such services,” they added. Delphin-Rittmon serves as the assistant secretary for mental health and substance use at SAMHSA and Cavazzoni is the director of the FDA’s Center for Drug Evaluation and Research.

SAMHSA Announces Funding Opportunity for Cooperative Agreements for 988 Suicide and Crisis Lifeline Crisis Center Follow-Up Programs

SAMHSA has announced it anticipates funding a total of $5 million in 10 awards to expand efforts among 988 lifeline centers to support individuals in follow-up programs. Specifically, the money would support individuals post-contact to provide continued support and linkages to decrease suicide risk by 1) ensuring the systematic follow-up of suicidal persons who contact the 988 suicide and crisis lifeline; 2) providing enhanced crisis stabilization coordination, crisis respite, mobile crisis outreach response services, and other services on the crisis continuum of care; 3) reducing unnecessary police engagement; and 4) improving connections for high-risk populations. Click here to learn more.

SAMHSA Distributes Additional Grant Funding for Programs to Combat Overdose and SUD

Also this week, SAMHSA announced awards in four grant programs totaling nearly $11.3 million in additional funding to support the Biden administration’s ongoing efforts nationwide in prevention, treatment, recovery support, and harm reduction. The four grant programs are Screening, Brief Intervention to Referral Treatment (SBIRT) (nearly $6.9 million); Grants to Prevent Prescription Drug/Opioid Overdose-Related Deaths ($2.6 million); Target Capacity to Expansion-Special Projects ($1.1 million); and Provider’s Clinical Support System to universities (more than $725,000). Click here to learn more about the programs

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

The Centers for Disease Control and Prevention reports that overdose deaths increased by 279% for drug overdoses involving fentanyl during the five-year study period to 21.6 per 100,000 standard population in 2021 from 5.7 per 100,000 standard population in 2016. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Hill Day Returns to NABH Annual Meeting Program!

NABH is excited to welcome its members and guests back to Hill Day during the 2023 Annual Meeting! This year NABH is working with the firm Advocacy Associates to help schedule Capitol Hill meetings and briefings for interested Annual Meeting attendees during Hill Day on Tuesday, June 13 from 1:30 to 5 p.m. ET. NABH will help prepare interested attendees by providing materials through a mobile app. To take advantage of this free opportunity, please indicate that you want to participate in Hill Day when you register for the 2023 Annual Meeting, or contact NABH Administrative Coordinator Emily Wilkins. Please remember to reserve your hotel room at the Salamander Washington, DC, if you haven’t done so yet. We look forward to seeing you next month!

HHS Launches FindSupport.gov During First Week of Mental Health Awareness Month

HHS on Thursday launched FindSupport.gov, a website designed to help the public identify available resources, explore unbiased information about various treatment options, and learn how to find the support they need for problems related to mental health, drugs, or alcohol. HHS’ Substance Abuse and Mental Health Services Administration (SAMHSA) and the Centers for Medicare & Medicaid Services (CMS) developed the concept for FindSupport.gov as a response to research that people were looking for an unbiased, trustworthy source of information to receive support for mental health and substance use issues. The department also developed a brief video to highlight the new website. Also Thursday, HHS hosted its Support is Here to Strengthen Mental Health summit, where HHS Secretary Xavier Becerra said the Biden administration is saying to all who are struggling with mental health that support is here. “I am proud that we are changing the way mental health is viewed in this country because mental health is health, period.” Becerra tweeted. The summit and new website coincide with the first week of Mental Health Awareness Month, which the United States has observed since 1949. The month-long observance is meant to fight stigma, provide support, educate the public, and advocate for policies that support the millions of Americans affected by mental illness. Click here to learn more, and please remember to follow us @NABHbehavioral and on LinkedIn at the National Association for Behavioral Healthcare.

DEA Extends COVID-19 Telehealth Flexibilities for Prescription of Controlled Medications for Now

The U.S. Drug Enforcement Administration (DEA) on Wednesday said it will extend its COVID-19 telemedicine flexibilities for prescription of controlled medications as the agency works to determine how to move forward in a way that gives Americans access to needed medicine with the appropriate safeguards. An announcement from DEA noted the agency received a record number of comments on its proposed telemedicine rules, which prompted DEA and the U.S. Health and Human Services Department (HHS) to submit a draft temporary rule to the Office of Management and Budget requesting an extension. NABH submitted comments on this matter (see CEO Update, April 28, 2023). “Further details about the rule will become public after its full publication in the Federal Register,” the announcement said.

CMS’ Recent Proposed Rule Would Establish Network Adequacy Requirements and Payment Transparency in Medicaid MCOs

CMS’ recent Medicaid managed care proposed rule aims to strengthen standards for more timely access to care for Medicaid and Children’s Health Insurance Program (CHIP) managed care enrollees and establish new payment transparency requirements in fee-for-service and managed care programs. As NABH reported in last week’s CEO Update, CMS is proposing to establish maximum appointment wait-time standards for outpatient mental health and substance use disorder—adult and pediatric—and other services, including routine primary care. News reports offered details of a call that CHIP Services Director Daniel Tsai had with reporters, in which Tsai said, “The standards we established are what we call a national floor so a state is welcome to set a standard that is higher than that, [but] they must meet at least the standard that we outlined proposed in the proposed rule,” according to an article in Inside Health Policy, which noted the administration wants to align Medicaid wait-time standards with the two-week requirement for commercial plans.   The proposed rule would also require states to employ an independent company to conduct yearly “secret shopper surveys” that confirm a managed care plan is complying with appointment wait-time standards and the insurer’s provider directory is up-to-date. Regarding payment rates, Tsai was reported as saying that, historically, CMS, advocates, and providers do not have a good way of understanding and benchmarking where Medicaid payment rates are across different state programs. “So what we do propose is that every state has to make their base rates of payments transparently available and easily accessible, and every state has to benchmark their base rates for Medicaid relative to Medicare payment rates, which is a national standard that allows for comparison and easy benchmarking across states,” Tsai said.

Joint Commission Seeks Feedback on Proposed Workplace Violence Prevention Requirements for BHC Program

The Joint Commission this week opened its field review to gather feedback from behavioral healthcare organizations about their experiences with workplace violence to help provide the most evidence-based and relevant requirements for its Behavioral Health Care and Human Services (BHC) accreditation program. In its announcement, the Joint Commission said its field review will ask for comments on the potential new requirements and the larger context of how behavioral healthcare organizations are currently experiencing, preventing, and monitoring workplace violence. The field review is open through June 9 and takes about 15 to 20 minutes to complete. Click here to complete the questionnaire.   HRSA Payment Program for Rural Health Clinic Buprenorphine-Trained Providers Still Active HHS’ Health Services and Resources Administration (HRSA) has announced that Rural Health Clinics (RHCs) are still eligible to apply for a $3,000 payment on behalf of each provider trained to prescribe buprenorphine between Jan. 1, 2019 and Jan. 25, 2023. SAMHSA announced in January 2023 that clinicians no longer need a DATA 2000 Waiver to prescribe buprenorphine; however, the payment program to defray earlier training cost is still active. Launched in 2021, the program pays for providers who previously trained for the waiver to prescribe buprenorphine. HRSA said about $900,000 in program funding remains available for RHCs, which will be paid on a first-come, first-served basis until funds are exhausted. Send question to DATA2000WaiverPayments@hrsa.gov.

NIDA Study Finds Association Between Cannabis Use Disorder and Schizophrenia

A new National Institute of Drug Abuse (NIDA) study has found that young men between 21-30 years of age with a cannabis (marijuana) use disorder have an increased risk of developing schizophrenia. The findings are notable because they emphasize that cannabis use disorder appears to be a major modifiable risk factor for schizophrenia at the population level. After evaluating more than 6 million people in Denmark for more than five decades, researchers estimated that the percentage of cases of schizophrenia that may have been avoided by preventing cannabis use disorder was as high as 30% among men aged 21-30; 15% among men aged 16-49; and 4% among women aged 16-49. The study was a collaboration between authors at the Mental Health Services in the Capital Region of Denmark and NIDA at the National Institutes of Health.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We still seek data from additional members to support advocacy on health plan denials and prior-authorization timeliness. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

A new study reports three in 10 Americans say they know someone affected by opioid addiction; within that group, more than half say they know someone who has died from opioid use.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Pleased to Welcome HHS Secretary Xavier Becerra at 2023 Annual Meeting

U.S. Health and Human Services Department (HHS) Secretary Xavier Becerra, J.D. will address attendees at the 2023 NABH Annual Meeting on Monday, June 12 from 2:15 p.m. to 2:45 p.m. Secretary Becerra is the 25th secretary of HHS and the first Latino in U.S. history to hold the office. Previously Secretary Becerra was California’s attorney general and before that served for 12 terms in the U.S. House of Representatives, where he was the first Latino to serve as a member of the powerful House Ways and Means Committee. Secretary Becerra also served as chairman of his party’s caucus and as the ranking member of both the Ways and Means Subcommittee on Health and the Ways and Means Subcommittee on Social Security. Born in Sacramento, Secretary Becerra is the son of working-class parents. He was the first in his family to receive a four-year degree, earning his bachelor’s degree in economics from Stanford University. He earned his law degree from Stanford Law School. Please 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!

CMS Releases FAQs About Transition Period Following End of Covid-19 PHE

The Centers for Medicare & Medicaid Services (CMS) has released a fact sheet of frequently asked questions to help providers prepare for the transition period after the Covid-19 public health emergency (PHE) ends on May 11. Although certain waivers and flexibilities CMS granted during the pandemic are set to expire, others will be permanent or extended due to congressional action. For instance, the Consolidated Appropriations Act, 2023 extended many telehealth flexibilities through Dec. 31, 2024, including: people with Medicare can access telehealth services in any geographic area in the United States, rather than only those in rural areas; people with Medicare can stay in their homes for telehealth visits that Medicare pays for rather than traveling to a healthcare facility; and certain telehealth visits can be delivered audio-only (such as a telephone) if someone is unable to use both audio and video, such as a smartphone or computer. The fact sheet also noted that Medicare Advantage plans may offer additional telehealth benefits and that individuals should check with their plan about coverage. “For Medicaid and CHIP, telehealth flexibilities are not tied to the end of the PHE and have been offered by many state Medicaid programs long before the pandemic,” CMS noted in the fact sheet. “Coverage will ultimately vary by state. CMS encourages states to continue to cover Medicaid and CHIP services when they are delivered via telehealth.

DEA Requests Extension on Agency’s Final Rule on Telehealth Prescribing of Controlled Substances

The Drug Enforcement Administration (DEA) has asked the White House for an extension on the release of the DEA’s final rule on telehealth prescribing of controlled substances. The extra time would permit telehealth services to continue under COVID-19 policies temporarily. NABH’s letter to DEA in late March was among the more than 18,000 comments that DEA received about telehealth services; the agency likely needs additional time to finalize the rule and avert disrupting current telehealth practices after the PHE ends on May 11.

CMS Releases Proposed Rules on Access and Quality in Medicaid & CHIP

CMS late Thursday released notices of proposed rulemaking (NPRMs)—Ensuring Access to Medicaid Services (Access NPRM) and Managed Care Access, Finance, and Quality (Managed Care NPRM) that NABH is reviewing. To improve access to care, the Managed Care NPRM proposes to establish maximum appointment wait-time standards for outpatient mental health and substance use disorder—adult and pediatric—and other services, including routine primary care (also adult and pediatric). CMS will accept comments on the proposed rules until Monday, July 3.

NIH Seeks to Expand Peer Reviewer Pool to Ensure Review Committees are Diverse and Inclusive

The National Institutes of Mental Health (NIMH) is seeking to expand its pool of peer reviewers with mental health researchers who can offer diverse perspectives in the peer-review process. The NIMH peer-review process aims to make certain that scientific experts evaluate grant applications in a manner free from what the National Institutes of Health deems as inappropriate incidences. Peer reviewers provide feedback on the scientific merit of those applications. Click here to learn more about eligibility requirements for peer reviewers and here to submit an application.

SAMHSA Announces Funding Opportunity to Promote Physical-Behavioral Healthcare Integration

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced it will award a total of about $29 million in a new grant funding opportunity intended to integrate physical healthcare and behavioral healthcare. The opportunity is not open directly to healthcare providers, but rather to the states. Specifically, states and state agencies—such as the state mental health authority, the single state agency for substance use services, the state’s Medicaid agency, and the state health department—are eligible to apply. SAMHSA’s announcement said it anticipates awarding 14 grants and the length of the project is five years. Click here to learn more.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal! We are still seeking data from additional members to support advocacy on health plan denials and prior authorization timelines. If you are a new participant, please e-mail NABH Administrative Coordinator Emily Wilkins for support.

Fact of the Week

A recent study in JAMA Psychiatry suggests that estimates of long-term exposure to multiple air pollutants were associated with increased risk of depression and anxiety. Researchers concluded that the non-linear associations may have important implications for policymaking in air pollution control. An article this week in Kaiser Health News also explored the connection between anxiety and pollution.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

Former DOL Assistant Secretary for Employment and Training John Pallasch to Kick Off 2023 Annual Meeting

NABH is pleased to announce John Pallasch, former Senate-confirmed assistant secretary for employment and training at the U.S. Labor Department (DOL), will kick off the association’s 2023 Annual Meeting with his presentation on Monday, June 12 at the Salamander Washington, DC.   Currently Pallasch is the founder and CEO of One Workforce, a workforce consultancy in Aiken, S.C. He served previously as executive director of Kentucky’s Office of Employment and Training, and—in his first stint at DOL—as deputy assistant secretary in the department’s Mine Safety and Health Administration.   Pallasch has spent more than 20 years influencing organizational personnel, efficiency, and productivity in the public and private sectors. He will draw from those experiences to help NABH members think more critically about their workforce challenges and more creatively about how to solve them.   Pallasch graduated from Ohio State and later earned a law degree from Pepperdine University School of Law. Please help us welcome him in the Salamander’s Grand Ballroom on Monday, June 12 at 2:45 p.m. ET.   If you haven’t done so yet, please register for the Annual Meeting and reserve your hotel room today.  We look forward to seeing you in Washington!

CMS Final Rule Establishes Mental Health Facilities and SUD Treatment Centers as Essential Community Providers

In a final rule this week, the Centers for Medicare & Medicaid Services (CMS) expanded access to care for low-income and medically underserved communities by establishing two new essential community provider (ECP) categories for mental health facilities and SUD treatment centers. The changes came in the Patient Protection and Affordable Care Act (ACA) notice of benefit and payment parameters (NBPP) for 2024. This annual notice administers policy changes for plans on the ACA exchanges and sets rates and risk-model specifications. The decision to categorize mental health facilities and SUD treatment centers as ECPs is a win for NABH; in late January, NABH advocated for these ECP categories in its comment letter to CMS about the agency’s proposed NBPP rule for 2024. “NABH strongly supports CMS’ proposal to expand its network adequacy criteria by creating two distinct essential community provider categories for mental health facilities and substance use disorder (SUD) treatment centers,” NABH President and CEO Shawn Coughlin wrote in the association’s letter. “To construct each county-level network, the rule would require insurers on the health exchanges to attempt to contract with at least one SUD Treatment Center and at least one Mental Health Facility.” The final rule takes effect 60 days after it appears in the Federal Register.

CMS Announces Opportunities to Increase Care Access, Including SUD Treatment, for Incarcerated Individuals

CMS this week announced a new opportunity for states to help increase care for individuals who are incarcerated in the period immediately before their release to help them thrive as they re-enter communities. The new Medicaid Reentry Section 1115 Demonstration Opportunity would allow state Medicaid programs to cover services that address various health concerns, including substance use disorders and other chronic health conditions. In an announcement Monday, CMS Administrator Chiquita Brooks-LaSure said the agency reached a milestone in expanding access through Medicaid. “This guidance outlines a pathway to implement historic changes for individuals who are incarcerated and eligible for Medicaid, she said. “By improving care and coordination prior to release from the justice system, we can help build a bridge back to the community and enhance individual and collective public health and public safety outcomes.” Click here to read the letter from Daniel Tsai, deputy administrator and director at the Center for Medicaid and CHIP Services, to state Medicaid directors.

NIH Study Shows Prevalence of Stimulant Therapy for ADHD Associated with Higher Rates of Prescription Stimulant Misuse in Teens

Researchers have found a strong link between the prevalence of prescription stimulant therapy for attention-deficit/hyperactivity disorder (ADHD) and rates of prescription stimulant misuse—taken in a way other than directed by a clinician— by students in middle schools and high schools. The study this week in JAMA Network Open emphasized the need for assessments and education in both schools and communities to prevent medication-sharing among teens. “This is especially important considering non-medical use of prescription stimulants among teens remains more prevalent than misuse of any other prescription drug, including opioids and benzodiazepine,” NIH noted in a news release about the study. The National Institutes of Health’s National Institute on Drug Abuse (NIDA) and the U.S. Food and Drug Administration supported the study, which used data between 2005 and 2020 by the Monitoring the Future (MTF) study. The MTF is a large, multicohort survey of legal and illicit drug use among American adolescents in eighth, 10^th, and 12^th grades. NIDA also funds the MTF.

Reminder: Public Comments on SAMHSA’s 2023-2026 Draft Strategic Plan Due April 27

The Substance Abuse and Mental Health Services Administration (SAMHSA) is seeking public comment on the agency’s draft 2023-2026 SAMHSA Strategic Plan that presents a person-centered mission and mission highlighting SAMHSA’s priorities and principles. SAMHSA’s five priority areas include preventing overdose; enhancing access to suicide prevention and crisis care; promoting resilience and emotional health for children, youth, and families; integrating behavioral and physical healthcare; and strengthening the behavioral healthcare workforce. The agency’s four core principles are equity, trauma-informed approaches, recovery, and commitment to data and evidence. Comments on the draft plan are due by 5 p.m. ET next Thursday, April 27. Click here to submit comments.

Reminder: 2023 NABH Exhibitor and Sponsor Guide Ad Deadline is Today, April 21

NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it!   All ads are due today, Friday, April 21, 2023. 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 Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

The U.S. Drug Enforcement Administration’s (DEA) National Prescription Drug Take Back Day is tomorrow, Saturday, April 22. DEA reflects the agency’s commitment to health and safety, encouraging the public to remove unneeded medications from their homes as a measure of preventing medication misuse and opioid addiction from starting.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Proposes 3% Increase in Payment Rates to Inpatient Psychiatric Facilities for 2024

The Centers for Medicare & Medicaid Services (CMS) is proposing to update Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) payment rates by 1.9% in fiscal year (FY) 2024, or $55 million, relative to current rates. This update includes a 3.2% market basket increase, a 0.2 percentage point productivity cut, and a 1.0% decrease to outlier payments. Other notable components of the agency’s proposed IPF PPS rule this week include: Proposed Modification to the Regulation on Excluded Units Paid Under the IPF PPS: Responding to increased mental health needs—including the need for available inpatient psychiatric beds—CMS is proposing greater flexibility for hospitals to open and bill Medicare for a new IPF distinct part unit. Specifically, beginning in FY 2024, CMS would allow hospitals to open a new unit at any time during the cost reporting period, with 30-day advance notice to the CMS regional office and Medicare administrative contractor. An announcement about the proposed rule said “CMS believes this proposal would alleviate unnecessary burden and administrative complexity placed upon hospitals when opening new psychiatric units, helping to expand access to behavioral healthcare” in line with the agency’s behavioral healthcare strategy. Proposed Updates to the IPFQR Program The rule also proposes to adopt three quality measures focused on health equity for the IPFQR Program. First, beginning in FY 2026, a Facility Commitment to Health Equity measure would ask IPFs to attest to its efforts to address health equity across five domains: (1) Equity is a Strategic Priority; (2) Data Collection; (3) Data Analysis; (4) Quality Improvement; and (5) Leadership Engagement. Second, a Screening for Social Drivers of Health (SDOH) measure would assess the percentage of patients over 17 who are screened for five specific health-related social needs (HRSNs) — food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety. Voluntary reporting would begin in the calendar year 2025, with payments affected beginning in FY 2027. Finally, CMS would adopt a Screen Positive Rate for SDOH measure beginning with voluntary reporting in CY 2024 and payment impact in FY 2027. This process measure assesses the percentage of patients who screen positive for each of the noted HRSNs in this quality measure. Request for Information (RFI) to Inform the Revisions to the IPF PPS Required by the Consolidated Appropriations Act, 2023 (CAA, 2023): Meanwhile, CMS noted in the rule that it has continued to analyze more recent IPF cost and claim information in an ongoing effort to refine the IPF PPS. In its FY 2023 IPF PPS proposed rule, CMS issued a technical report and sought comments on the results of the latest refinement analysis in preparation to propose IPF PPS patient-level and non-regression-derived refinements to be effective in FY 2024. Subsequently, new provisions in the CAA, 2023 require CMS to revise payments under the IPF PPS for Rate Year 2025 (or FY 2025 under the IPF PPS) as the U.S. Health and Human Services secretary determines appropriate. Consequently, CMS has included a request for information (RFI) that will be used to inform future payment revisions. Also in the proposed rule, CMS has addressed the specific types of data and information that the CAA, 2023 suggests CMS may collect, as well as soliciting comments on additional data and information that could be collected to inform future payment revisions. CMS will accept public comments on the proposed rule through Monday, June 5.

Final Medicare Advantage Rule for 2024 Addresses Many NABH Priorities

Earlier this week, the Centers for Medicare & Medicaid Services (CMS) issued its contract year 2024 final rule related to the Medicare Advantage (MA) program, which addresses multiple, long-standing concerns of the NABH. In particular, we are pleased with the rule’s extensive improvements related to prior authorization, network adequacy, and quality of care, including measures that:

• Require MA plans to comply with the general coverage and benefit conditions of the Traditional Medicare program, along with national and local coverage determinations (LCD), and related regulations;
• Apply prior authorization approvals to a patient’s full course of treatment for medically reasonable and necessary care, as determined by the treating physician;
• Codify appointment wait time standards for behavioral healthcare and other services;
• Add a 10 percentage point credit to insurers’ network adequacy assessment for the inclusion of clinical psychologists and licensed clinical social workers;
• Exempt emergency behavioral health services from the prior authorization process;
• Require MA organizations to:
  • include behavioral health services in their care coordination programs;
  • base medical necessity determinations on the individual circumstances of a specific patient, rather than on a proprietary algorithm or software;
  • create a utilization management committee that annually reviews coverage policies to ensure that coverage is “no more restrictive than traditional Medicare coverage criteria;’ and
  • include in their advertisements a specific Medicare Advantage plan name and ban the use words or imagery that is “misleading, confusing, or misrepresents the plan.”
• Clarify that insurers may deny care using proprietary criteria, only if traditional Medicare coverage rules are not fully established and the in-house coverage standards are based on “current evidence in widely used treatment guidelines or clinical literature made publicly available to CMS, enrollees, and providers.”

Of concern, is CMS’ exclusion of providers of medication for opioid use disorder from its network adequacy criteria. This proposal was not finalized because the elimination of the x-waiver requirement for buprenorphine providers removed the data source necessary for CMS to track those providers. The rule also explained that there are too few opioid treatment programs (OTPs) to establish access standards, and reminded MA organizations that they are required to include OTPs as part of their Part B coverage for OTP services or arrange out-of-network care at in-network cost sharing.

New Resource: ‘Using Contingency Management To Combat Stimulant Use Disorder’ Fact Sheet

NABH has produced Using Contingency Management To Combat Stimulant Use Disorder, a brief fact sheet that explains contingency management (CM) and highlights the association’s legislative request for Congress to direct federal agencies to replace the current $75 CM incentive payment limitation with scientifically proven incentive levels. “Decades of research and peer-reviewed literature validate the effective use of CM, which uses positive reinforcement to encourage abstinence from stimulant use,” NABH’s fact sheet explains. “Positive behavior reinforcement takes the form of predictable and meaningful financial incentives, such as gift cards (with restricted purchase guidelines) or prizes, which can be earned only when specific ‘target behaviors’ are achieved, such as drug-free urine samples.” The new resource is available on NABH’s homepage under “Latest Content” and also posted on NABH’s “Be an Advocate” page.

Reminder: Please Submit NABH’s Behavioral Health Information Technology Survey by April 12

NABH is seeking feedback from all system members about their experiences with behavioral health information technology as the association urges Congress and the Biden administration to extend incentives to behavioral healthcare organizations for adopting electronic health records. Please submit this brief survey by Wednesday, April 12. Your responses will help NABH in its advocacy efforts to urge Congress and the Biden administration to extend these incentives to behavioral healthcare organizations. Please e-mail Rochelle Archuleta if you have questions.

2023 Exhibitor and Sponsor Guide Advertising Deadline is Approaching!

NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it!   All ads for the guide are due by April 21, 2023. 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.

2023 ExNABH Annual Meeting Hotel Cut-Off Date is May 11!hibitor and Sponsor Guide Advertising Deadline is Approaching!

Please reserve your hotel room today at the Salamander Washington, DC (formerly the Mandarin Oriental hotel) for the 2023 NABH Annual Meeting from June 12-14, 2023! The hotel’s cut-off date is Thursday, May 11, 2023. And please visit our Annual Meeting webpage to register for the meeting, if you have not done so yet. We look forward to seeing you in Washington!

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

A recent Health Affairs study found that the proportion of adult primary care visits that addressed mental health concerns increased to 15.9% by 2016 and 2018 from 10.7% of visits in 2006–07. For questions or comments about this CEO Update, please contact Jessica Zigmond

NABH Releases 2023 Advocacy Priorities

NABH this week released its 2023 advocacy priorities, which reflect the association’s mission and outline the actions NABH will take to achieve its goals. Categorized under the headings “Mental Health” and “The Addiction Crisis,” NABH’s 2023 advocacy priorities include securing the promise of parity; persuading lawmakers to provide incentives for behavioral healthcare providers to establish and implement a solid behavioral health information technology infrastructure; advocating Congress to repeal the Institutions for Mental Diseases (IMD) exclusion; pushing the Centers for Medicare & Medicaid Services to ensure payment rates provide adequate and appropriate reimbursement for opioid treatment program services; maintaining tele-behavioral healthcare services, and more.   Please review this document and share it with others. If you have questions, please contact nabh@nabh.org.

FDA Approves First Over-the-Counter Naloxone Spray

The U.S. Food and Drug Administration (FDA) on Tuesday approved Narcan, 4 mg. naloxone hydrochloride nasal spray for over-the-counter (OTC), non-prescription use, making it the first naloxone product approved to use without a prescription. Naloxone is a medication that reverses the effects of opioid overdose rapidly and is the standard treatment for opioid overdose. The FDA’s action clears the way for this life-saving medication to be sold directly to consumers in drug stores, convenience stores, grocery stores, gas stations, and online. The move comes at a time when the Centers for Disease Control and Prevention released provisional data earlier this month that showed 101,750 reported U.S. fatal overdoses in the 12-month period ending in October 2022, while the predicted number of fatal doses for that period is even higher at 107,669. “As a physician, I have used Naloxone on people to reverse an opioid overdose hundreds of times and have witnessed firsthand its life-saving effects,” Rahul Gupta, M.D., director of the White House Office of National Drug Control Policy, said in a statement this week. “FDA’s announcement to make Narcan available over-the-counter is an important step to make this medicine accessible to more people at a time when the majority of overdose deaths are being driven by illicit opioids like fentanyl,” he added. “This move will also build on the progress made under the Biden-Harris administration to get more Naloxone into communities, expand access to treatment for substance use disorder, and reduce the supply of illicit drugs, which has resulted in a decline or flattening of overdose deaths for seven months in a row.” According to the FDA, the manufacturer determines the timeline for availability and price of this OTC product. Click here to learn more.

SAMHSA Warns Providers and Grantees About Xylazine Risks

In a letter this week, the Substance Abuse and Mental Health Services Administration (SAMHSA) alerted providers to the risks of xylazine, a non-opioid agent increasingly found in combination with opioids such as fentanyl. The letter said xylazine—which the FDA has not approved for use in humans—can cause severe circulatory changes with devastating effects on human tissue, leading to painful open lesions, necrosis, and potentially limb loss. “Practitioners must be aware of risks posed by xylazine and prepare to manage patients accordingly, Miriam Delphin-Rittmon, Ph.D., assistant secretary for mental health and substance use, wrote to providers. “SAMHSA’s goal with this alert is to provide information about the consequences of xylazine exposure, what practitioners can do to mitigate harm, and how SAMHSA is responding to this emerging public health challenge.” Known as “tranq” or “tranq dope” in the illicit drug market, xylazine can cause drowsiness, lethargy, and, in rare instances, apnea and death. SAMHSA encourages healthcare professionals and patients to report adverse events resulting from possible xylazine exposure to their local health department, poison center, or the American Association of Poison Control Centers at 1-800-222-1222. FDA’s MedWatch Adverse Event reporting may be completed online at www.fda.gov/medwatch.

SAMHSA Announces Three Recovery-Related Funding Opportunities

SAMHSA this week announced it will accept applications through May for three separate funding opportunities to implement and strengthen recovery services in communities. The programs include the Treatment, Recovery, and Workforce Support grant to implement evidence-based programs to support individuals in substance use disorder (SUD) treatment and recovery to live independently and participate in the workforce; the Recovery Community Services Program-Statewide Network, intended to strengthen community-based recovery organizations, their statewide networks of recovery stakeholders, and specialty and general healthcare systems as key partners in delivering state and local recovery support services; and the Recovery Community Services Program, which would provide peer recovery support services to individuals with SUD or co-occurring substance use and mental disorders, including those in recovery from these disorders. SAMHSA will accept applications for all three funding opportunities until May 30.

Reminder: SAMHSA Funding Opportunity to Establish or Implement Opioid Recovery Centers

SAMHSA has announced it will grant up to $1.4 million in two awards to establish or implement comprehensive treatment and recovery centers that provide a spectrum of treatment, harm reduction, and recovery support services to address America’s opioid crisis. Applications are due Tuesday, May 16. Click here to learn more and apply.

Advertise in the 2023 NABH Exhibitor and Sponsor Guide!

NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it!   All ads are due by April 21, 2023. 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 and Reserve Your Hotel Room Today for the 2023 NABH Annual Meeting!

Please join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Our preliminary program will be available soon. Meanwhile, please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

Between 2009 and 2019, the number of pediatric mental health hospitalizations increased by 25.8%, and these hospitalizations accounted for a significantly higher proportion of pediatric hospitalizations, according to a study published in JAMA this week. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Responds to Senate HELP Committee RFI About U.S. Healthcare Workforce Shortage

NABH thanks its many members who submitted comments detailing their workforce challenges and potential solutions, which helped form the association’s response to the Senate Health, Education, Labor & Pensions (HELP) Committee’s request for information earlier this week. In its six-page letter, NABH noted that America’s behavioral healthcare workforce shortage has reached a crisis point, with nearly 58 million adults reporting any mental illness, about 61 million people using illicit drugs, and more than 150 million people living in federally designated mental health professional shortage areas at a time when the U.S. psychiatrist workforce will contract through 2024 to a projected low of 38,821, equal to a shortage of between 14,280 and 31,091 psychiatrists. A diminished candidate pool, a limited employee pipeline, workplace violence, employee satisfaction in a post-pandemic environment, a highly competitive workforce, over-regulation, and an extremely limited health information technology infrastructure were the leading drivers of the segment’s workforce shortage, the association noted, based on NABH system member responses. The letter then summarized a range of solutions under the categories of reimbursement at parity, additional funding for training programs, and deregulation. NABH will discuss how to address the behavioral healthcare workforce shortage in two sessions at the 2023 NABH Annual Meeting on Monday, June 12.

NABH Addresses Federal Lawmakers’ Stigmatizing Comments about OTPs

NABH this week sent a letter to federal lawmakers expressing deep disappointment with the congressional leaders’ recent comments that compared the nation’s opioid treatment programs (OTPs) with drug cartels and characterized this behavioral healthcare segment as an industry protecting its profits. “These comments are highly stigmatizing to the approximately 18,000 staff who work in OTPs and have dedicated their careers to delivering life-saving services to individuals with opioid use disorders (OUD),” NABH wrote in a letter to Rep. Donald Norcross (D-N.J.) and Sen. Edward Markey (D-Mass.) “Your comments also perpetuate the ongoing stigma against medication-assisted treatment (MAT) that plagues our society,” the letter continued. “This stigma is one of the primary reasons that people with OUD do not seek, nor receive, MAT, even though it is the evidence-based, gold standard of care for patients suffering from OUD. We are confident you both agree that with our nation facing an overdose epidemic with one death every five minutes, we cannot afford to lose ground in the battle against stigmatization in addiction care.” The letter highlights strengths and weaknesses of recent regulatory reforms and current legislation. It also provides a series of recommendations for lawmakers, such as examining the effects of recent efforts to expand access, with a specific focus on understanding the root causes behind incremental overdoses as well as the disproportionate harm that marginalized populations suffer; addressing significant barriers to treatment; and studying the potential impact of leveraging community-based pharmacies in the United States to dispense methadone widely to patients while ensuring that adequate regulatory controls can be established, given the concerning behaviors by pharmacies that recent court proceedings have documented.

NABH Files Amicus Brief on Behalf of Nine Organizations in Wit v. UBH Ruling

NABH has filed an amicus brief that supports a petition for rehearing the ongoing Wit v. United Behavioral Health (UBH) case. A three-judge panel in the 9^th U.S. Circuit Court of Appeals on Jan. 26 replaced its March 2022 ruling in the Wit v. UBH case with a new opinion that was a major disappointment to both mental health patients and providers. NABH asserts the latest opinion will materially reduce the benefit of insurance because it does not protect medically necessary treatment based on generally accepted standards of care.

NIH Study Reveals Shared Genetic Markers Underlying SUD

Scientists have identified genes commonly inherited across addiction disorders, regardless of the substance used, according to a study published in Nature Mental Health. With support from the National Institute on Drug Abuse, the National Institute on Alcohol and Alcoholism, the National Institute of Mental Health, the Eunice Kennedy Shriver National Institute of Child Health and Human Development, and the National Institute on Aging, researchers at Washington University in St. Louis, along with more than 150 coauthors worldwide, analyzed genomic data from more than 1 million people. Their findings also reinforce the role of the dopamine system in addiction, by showing that the combination of genes underlying addiction disorders was also associated with regulation of dopamine signaling. Click here to learn more.

SAMHSA Announces Funding Opportunity to Establish or Implement Opioid Recovery Centers

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced it will grant up to $1.4 million in two awards to establish or implement comprehensive treatment and recovery centers that provide a spectrum of treatment, harm reduction, and recovery support services to address America’s opioid crisis. Applications are due Tuesday, May 16. Click here to learn more and apply.

Advertise in the 2023 NABH Exhibitor and Sponsor Guide!

NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it! All ads are due by April 21, 2023. 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 and Reserve Your Hotel Room Today for the 2023 NABH Annual Meeting!

Please join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

The National Alliance on Mental Illness (NAMI) reports that research shows the effects of solitary confinement on mental health are often fatal, both during and after incarceration. A recent showed individuals were overall 24% more likely to die in the first year after release, including from suicide (78% more likely) and homicide (54% more likely). They were also 127% more likely to die of an opioid overdose in the first two weeks after release. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Remembers Former Board Member Frank Fortunati, Jr., J.D., M.D.

NABH remembers with grateful appreciation Frank Fortunati, Jr., J.D., M.D., 58, who died March 5 after a protracted, courageous battle against prostate cancer. A psychiatrist, attorney, and pharmacist, Fortunati had served as assistant professor of psychiatry and deputy chair for Yale-New Haven Health System. Since 2016, he was the vice chief and medical director of psychiatry and behavioral health for Yale-New Haven Hospital, where he was also active in the department’s COVID Healthcare Worker Support Task Force and Anti-racism Task Force. Referred to as a true Renaissance Man, Fortunati was an accomplished musician who played saxophone, guitar, piano, and flute. His obituary noted that one of his great joys was performing with his friends and fellow psychiatrists in their band “Schedule II.” In the car, he enjoyed listening to jazz or classic Rock. He was also an avid gardener, spending hours growing and harvesting tomatoes, peppers, eggplants, grapes, and figs.   Fortunati served as a member of the NABH Board of Trustees from 2018-2020 and was also an engaged member of NABH’s Quality Committee, Workplace Violence Prevention Workgroup, and COVID-19 Task Force. His fellow board members and the Washington-based NABH team will remember how he always listened well and offered thoughtful, practical solutions to any topic—and proposed solutions that made life better for patients and the healthcare teams who cared for them. “Fortunati led by example, often serving in multiple roles (vice chief, section head, inpatient medical director),” the Yale School of Medicine wrote in an announcement about his death. “He earned the respect of everyone who worked with him. His credibility enabled him to drive change and improve quality. He put others ahead of his personal needs, repeatedly declining to complete the paperwork necessary for his own promotion in the service of looking out for others.” Fortunati is survived by his wife, Karen; children Jenna and Frankie; other family members; and the Fortunati family’s three cherished dogs. Funeral services were held at Saint Mary Church (Precious Blood Parish) in Milford, Conn. on March 11.

NABH Raises Information System Limitations and Prior Authorization Concerns with CMS

NABH this week submitted comments to the Centers for Medicare & Medicaid Services (CMS) about the agency’s electronic prior authorization proposed rule as it pertains to behavioral healthcare patients and providers. Under the direction of the NABH Managed Care Committee, the association raised concerns that the current limitations of the behavioral healthcare sector’s information system infrastructure are such that, without federal investment in compliant information technology to enable behavioral healthcare connectivity, most behavioral healthcare providers will remain shut out of 1) the interoperable exchange of patient health information, and 2) the electronic prior authorization processes that the rule proposes. NABH’s letter also strongly supports modifying existing regulation to treat prior authorization approvals as a promise of payment that cannot be retracted, in addition to a determination of whether an item or service is medically necessary.

NABH Opposes Proposed FTC Ban on Non-Compete Clauses

In comments submitted today, NABH asked the Federal Trade Commission (FTC) to withdraw its proposed rule that would ban non-compete clauses. NABH’s opposition to this proposal was based on three distinct concerns: the rule proposes an overly simplified, one-size-fits-all approach for all employees across all industries; given the workforce disruptions related to the COVID-19 pandemic, now is not the time to upend the healthcare labor markets; and, finally, the FTC lacks the statutory authority to promulgate this wide-reaching regulation.

Members of Congress Request Telehealth Parity Guidance from DOL

A bipartisan group of Members of Congress have sent a letter to the U.S. Labor Department (DOL) urging the department to provide guidance regarding parity enforcement for mental health and substance use disorder (SUD) services delivered via telehealth. In the letter, House members expressed concern that health plans may be less motivated to cover behavioral healthcare telehealth services after the COVID-19 public health emergency is scheduled to end on May 11. “Since the onset of the pandemic, telehealth use has risen dramatically, with 41% of MH/SUD care delivered via telehealth by October 2020,” the letter noted. “Mental health conditions continue to be the top claims diagnosis in the commercial market rising from 30% in January 2020 to roughly 65% in November 2022,” it continued. “Given the immense need for MH/SUD services combined with acute behavioral health workforce shortages, we want to ensure insurance plans and issuers understand their responsibility under federal parity law as it relates to behavioral health services delivered via telehealth.” Click here to read the full letter.

SAMHSA Announces National Strategy for Suicide Prevention Funding Opportunity

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week announced it will grant five awards totaling $2 million to implement suicide prevention and intervention programs for adults that help implement the 2021 Surgeon General’s Call to Action to Implement the National Strategy for Suicide Prevention.   With an emphasis on older adults, adults in rural areas, and American Indian and Alaskan native adults, the program is meant to address the Call to Action’s broad-based public health approach to suicide prevention through enhancing collaboration among stakeholders such as county health departments, workplace settings, criminal justice setting, senior-serving organizations, and community firearm stakeholders. Applications are due Monday, May 15. Click here for more information.

Advertise in the 2023 NABH Exhibitor and Sponsor Guide! 

NABH will distribute the 2023 NABH Exhibitor and Sponsor Guide to all registrants at the 2023 NABH Annual Meeting from June 12-14, 2023 at the Salamander Washington, DC. Be sure your organization is included in it! All ads are due by April 21, 2023. 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. Registration is Open for the 2023 NABH Annual Meeting: Securing the Promise of Parity! Please join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

Black and Hispanic adults with co-occurring disorders were less likely to receive mental health or substance use treatment (47% and 43%, respectively) than White adults (64%), according to research from The Pew Charitable Trusts.  For questions or comments about this CEO Update, please contact Jessica Zigmond.

President Biden’s FY 2024 Budget Proposal Includes Strong Focus on Behavioral Healthcare Needs

Yesterday, President Biden issued his Fiscal Year 2024 budget proposal, which now goes to Congress for consideration. Key provisions include:   Elimination of the 190-day Lifetime Limit on Psychiatric Hospital Services. The proposed budget would rescind the current law limiting Medicare enrollees to a lifetime limit of 190-days inpatient psychiatric care. The purpose of this provision is to increase access to hospital-level care and advance parity between mental health and physical health coverage for patients with serious mental illness. The budget estimates that this item would generate a $2.4 billion cost to Medicare over 10 years. Greater Psychiatric Hospital Flexibility when Restoring Compliance with Conditions of Participation. In cases where a psychiatric hospital is non-compliant with the Medicare conditions of participation for a deficiency that does not jeopardize patient health and well-being, the proposed budget would give CMS flexibility to continue issuing Medicare payments if the facility is actively working to correct the deficiency, rather than terminate Medicare participation. Workforce. The proposed budget also includes a $2 billion mandatory Mental Health System Transformation Fund for workforce development and service expansion. In part, this workforce development effort would augment FY 2023 funding already enacted in law to train about 18,000 behavioral health providers— including clinicians, peer support specialists, and others—and increase the number of providers practicing in areas of high demand throughout the country. Parity. The proposed budget would apply to Medicare Advantage the 2008 Mental Health Parity and Addiction Equity Act, requiring health plans to offer mental health and substance use disorder benefits that are no more restrictive than the medical and surgical benefits they offer. It also requires health plans to use medical necessity criteria for behavioral health developed by nonprofit medical specialty associations, as well as regulation of behavioral health network adequacy, and the creation of a standard for parity in reimbursement. The budget estimates a $760 million cost over 10 years for these parity items. Learn more about the Biden administration’s FY 2024 budget proposal here.

Study Shows Opioids Cause Half of All Poisonings in U.S. Kids Aged 5 and Under

About 52% of poisoning deaths of U.S. children aged 5 and under in 2018 involved the ingestion of an opioid, according to a study published online this week in the journal Pediatrics. Researchers also found that opioids accounted for a progressively greater proportion of the substances contributing to poisoning-related deaths during the study period, from 24% in 2005 to 52% in 2018.   “As the types of opioids circulating during the current epidemic continue to evolve, policy and programmatic initiatives should focus on children in addition to adults,” the study’s authors wrote.  “Regulatory changes have improved the safety of OTC medications, but a substantial proportion of pediatric fatalities are still associated with this medication class.”

Thank You to Members Who Submitted Comments on Workforce Challenges & Solutions

NABH thanks all members who responded to our request for feedback about their system’s most critical workforce challenges and potential solutions. The NABH Research and Education Foundation is seeking comments in these two areas to help NABH respond to a request for information (RFI) that the Senate Health, Education, Labor & Pensions (HELP) Committee announced last week. The RFI follows a Feb. 16 hearing the Senate HELP Committee held to examine the root causes of America’s current healthcare workforce shortages and explore potential solutions.   If you haven’t sent comments and would like to contribute, please send your feedback as an attachment to foundation@nabh.org by the close of business on Monday, March 13.

Registration is Open for the 2023 NABH Annual Meeting: Securing the Promise of Parity!

Please join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Manatt Telehealth Webinar Recording Now Available

NABH thanks its members who helped the NABH Education and Research Foundation and Manatt produce a joint issue brief, Telehealth is Effectively Augmenting Traditional Partial Hospitalization and Intensive Outpatient Programs last month. In case you missed it, Manatt led a webinar on March 1 that highlighted the telehealth issue brief’s findings. Click here to submit a brief form to watch the recorded webinar. NABH is grateful to Abhi Pardeshi from UHS, Dylan Ross from Rogers Behavioral Health, and T.J. Vlavianos from Northwell Health’s Zucker Hillside Hospital for joining NABH President and CEO Shawn Coughlin as the webinar’s panelists.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

Males make up 25% of people with anorexia. Because they are often diagnosed later than females, they are at higher risk of dying, according to the Center for Discovery. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Registration is Open for the 2023 NABH Annual Meeting: Securing the Promise of Parity!

Please join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Please Send Us Your Feedback on Workforce Challenges & Solutions

The NABH Research and Education Foundation is seeking comments from NABH members on 1) the main drivers of your system’s workforce shortages, and 2) your ideas for solutions. NABH will gather this collective feedback and respond to the request for information (RFI) that the Senate Health, Education, Labor & Pensions (HELP) Committee announced thursday. The RFI follows a Feb. 16 hearing the Senate HELP Committee held to examine the root causes of America’s current healthcare workforce shortages and explore potential solutions. Please send your comments as an attachment to foundation@nabh.org by the close of business on Monday, March 13. Thank you for your help with this critical issue!

DEA Proposes Two Telemedicine Regulations

The Drug Enforcement Administration (DEA) recently published two telemedicine rules that, taken together, largely revert to pre-COVID requirements for an in-person medical evaluation prior to prescribing controlled substances. DEA’s Notices of Proposed Rulemaking (NPRM) for buprenorphine and telemedicine without an in-person medical evaluation propose permitting the following two scenarios under which a telemedicine prescription can take place: Scenario A: Permitting a virtual first prescription by the prescribing practitioner without an in-person medical evaluation for an initial 30-days of non-narcotic Schedule III-V or buprenorphine-controlled substances. The NPRM proposes specific processes and documentation requirements for this scenario, such as checking the PDMP and noting ‘telemedicine’ on the face of the prescription. Scenario B: Permitting a qualified telemedicine referral in which a second DEA-registered practitioner performs an in-person exam and makes a referral to the prescribing practitioner. Under this scenario, Schedule II-V and narcotic substances can be prescribed. The NPRM proposes processes and documentation for these referrals, such as a written referral and transfer of medical records prior to prescribing. To continue prescribing after 30-days under Scenario A, a one-time in-person medical evaluation is required. The in-person evaluation requirement can be satisfied in three ways:

• Through an evaluation by the telemedicine prescribing practitioner;

• Through an evaluation conducted as a three-way audio-visual exam in which the prescribing practitioner, another DEA-registered referring provider, and the patient participate;

• Through a ‘qualified telemedicine referral’ by another DEA-registered practitioner who has seen the patient in-person and who adheres to specific procedures and documentation for the referral.

Meanwhile, if a telemedicine prescription for a controlled substance was initiated during the public health emergency (PHE), the NPRM proposes a 180-day transition period during which time an in-person medical evaluation must take place. If the NPRM is finalized by May 11, 2023 (the designated end of the PHE), an individual inducted during the PHE would have to have an in-person medical evaluation by November 2023. This extends to all prescriptions for controlled substances II-V initiated during the PHE. The NPRM do not include the long-awaited special registration rule, which would have allowed certain clinicians to prescribe controlled substances via telemedicine without an in-person evaluation. Moreover, DEA said this NPRM satisfies its obligation to propose rules for a special registration. In addition, the revisions align with the Centers for Medicare & Medicaid Services’ updated definition of telehealth to include audio-only telemedicine of controlled substances for mental health where states permit it. These instances are both limited and situational. NABH will provide comments to DEA by the agency’s March 31 deadline. Please send any comments to Sarah Wattenberg at sarah@nabh.org by Friday, March 17.

SAMHSA Releases Report on Long COVID’s Effects on Behavioral Health

A meta-analysis of studies around the world showed that the overall prevalence of depression, anxiety, and sleep disturbances among COVID-19 survivors was 45%, 47%, and 34%, respectively, according to a report released this week from the Substance Abuse and Mental Health Services Administration (SAMHSA). The Centers for Disease Control and Prevention (CDC) defines Long COVID as “new, returning, or ongoing symptoms that last four or more weeks following acute COVID-19 diagnosis.” SAMHSA’s report, Overview of the Impacts of Long COVID on Behavioral Health, examines the effects of the deadly virus in a variety of areas, including cognitive and psychiatric symptoms associated with Long COVID, a widening of health disparity gaps, potential long-term implications, and future directions for Long COVID recovery. “Among the most common symptoms of Long COVID is a gradient of cognitive and psychiatric sequelae (e.g., depression, anxiety, PTSD), which may portend significant consequences for patient functioning and quality of life,” the report noted. The study also said that in comparison with those not affected, COVID-19 survivors show increased rates of mental health and cognitive problems.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

Research has shown that, regardless of COVID-19 status, 53% of healthcare workers reported symptoms of at least one mental health condition, including depression (32%), anxiety (30%), PTSD (37%), and suicidal ideation (8%), according to SAMHSA’s Overview of the Impacts of Long COVID on Behavioral Health. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Registration is Open for the 2023 NABH Annual Meeting: Securing the Promise of Parity!

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). NABH’s theme this year is Securing the Promise of Parity, which recognizes the Mental Health Parity and Addiction Equity Act’s (MPAEA) 15^th anniversary and that we have more work to do to ensure the landmark law is implemented fully. Please visit our Annual Meeting homepage to register, reserve your hotel room, and view our Annual Meeting At-a-Glance. We look forward to seeing you in Washington!

Reminder: NABH-Manatt Telehealth Issue Brief Webinar on Wednesday, March 1

Manatt will host a webinar featuring NABH President and CEO Shawn Coughlin and NABH members as panelists on Wednesday, March 1 at noon ET to highlight findings from the telehealth issue brief that the NABH Education and Research Foundation and Manatt released this month. The telehealth issue brief is the first resource from the NABH Education and Research Foundation, which worked with NABH members and Manatt to compile and evaluate data to measure the impact that telehealth services have had on access and outcomes. The study showed how telehealth services effectively augment traditional partial hospitalization programs (PHP) and intensive outpatient programs (IOP). NABH urges its members to read the issue brief and share it with others. The association has also created a social media toolkit with shareable graphics that highlight key research from the study. Members can access the issue brief and social media toolkit on the NABH Education and Research Foundation’s Resources page. Click here to register for next week’s free webinar.

Biden Administration Will Allow States to Use Medicaid to Cover SUD for Incarcerated Persons

The Biden administration will allow states to use Medicaid funding to cover substance use disorder (SUD) treatment for incarcerated persons at state jails and prisons, news outlets reported this week. According to Politico, Rahul Gupta, M.D., director of the Office of National Drug Control Policy, said Tuesday that the Centers for Medicare & Medicaid Services (CMS) plans to release guidance this spring that outlines how states could use the program and federal dollars to pay for treatments before people are released. The story also quoted Gupta as saying the guidance is a “smart move” and that all 112 of the nation’s federal prisons will offer medication-assisted treatment for SUD by this summer.

NIH Trial to Compare Effects of Prescribed Buprenorphine or Methadone in Office Settings

The National Institutes of Health (NIH) will conduct a hybrid effectiveness/implementation trial to compare patients’ ability to remain in treatment when they’re prescribed buprenorphine or methadone in an office-based setting, STAT News reported today. According to the story, the clinical trial, scheduled for this year, is the first of its kind in the “fentanyl era.” “While we do have hints from the scientific literature that methadone has better outcomes with respect to retention in treatment and decreases in illicit drug use, we actually don’t have that literature in patients who are primarily using fentanyl,” David Fiellin, M.D., director of Yale Medical School’s Program in Addiction Medicine and the researcher overseeing the trial, said in the story. Click here for details about the NIH study.

CMS Releases Preliminary Medicaid and CHIP Data Snapshot

CMS this week released Medicaid and CHIP and the Covid-19 Public Health Emergency, a data snapshot that compares healthcare service utilization patterns, including behavioral healthcare services, in Medicaid and the Children’s Health Insurance Program (CHIP) during the Covid-19 pandemic from March 2020 through July 2022. Section five of the report presents the behavioral healthcare content, including services delivered via telehealth and a breakdown of services for adults and children enrolled in these programs. More than 137 million Americans—including children, pregnant women, parents, seniors, and individuals with disabilities—were enrolled across each state’s Medicaid or CHIP for at least one day during the public health emergency.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Fact of the Week

Black patients are 1.6 times more likely to experience an involuntary psychiatric hospital admission than non-Black patients, according to a study about racial and ethnic inequities published in Psychiatric Services.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

FDA Advisors Recommend Over-the-Counter Use of Narcan

A U.S. Food and Drug Administration (FDA) advisory panel this week voted 19-0 to recommend the agency approve the anti-opioid overdose drug Narcan be made available as an over-the-counter drug. Narcan is currently available by prescription only, and the change would make it the first opioid overdose reversal drug to be made available over the counter. News reports noted the FDA advisors also asked that the manufacturer make it more clear to users how to administer the product. The FDA is expected to make a final decision by March 29.

CDC Releases Youth Risk Behavior Survey Data Summary & Trends Report: 2011-2021

Female students were nearly twice as likely to attempt suicide during the past year compared with their male peers, with nearly six in 10 feeling persistently sad or hopeless and more than one in 10 attempting suicide, the Centers for Disease Control and Prevention (CDC) reported in its Youth Risk Behavior Survey Data Summary & Trends Report: 2011-2021 this week. The data provide a critical view of U.S. adolescent health and well-being related to sexual behavior, substance use, experiences of violence, mental health, and suicidal thoughts and behaviors. This year’s report also includes data on students’ experiences of unstable housing, school connectedness, and parental monitoring to expand understanding of young people’s environments and opportunities to improve them. In the CDC’s words, the findings “tell a distressing story” about the health and well-being of our country’s young people. According to the report, female students experienced more violence, mental health challenges, suicidal thoughts and behaviors, and substance use than their male peers. For instance, the percentage of female students who had ever experienced forced sex increased for the first time in 10 years, with 14% of female students having this experience. Meanwhile, attempted suicide was higher among Black students than students from other groups and increased among Black and White students from 2011 to 2021. And LGBQ+ students were nearly four times as likely as their heterosexual peers to attempt suicide during the past year, with more than two in 10 reporting this experience.

CDC Provisional Data Show U.S. Drug Overdose Deaths High but Declining

Provisional data from the CDC this week show the number of U.S. drug overdose deaths, while still high, has declined. The CDC predicts there were 106,840 drug overdose deaths for the 12-month period ended September 2022 compared with 107,937 predicted drug overdose deaths for the 12-month period ended August 2021. And when comparing month-over-month statistics in 2022, the numbers show a steady decline, starting with 110,317 predicted overdose deaths in March 2022. In a statement last month, Office of National Drug Control Policy (ONDCP) Director Rahul Gupta, M.D. attributed the progress to the Biden administration’s efforts to remove barriers to treatment and disrupting the supply of illicit drugs.

SAMHSA Releases National Substance Use and Mental Health Services Survey, 2021

More than two-thirds of substance use treatment facilities (69.5%) offered pharmacotherapies as part of their treatment services, with a higher percentage of substance use facilities reporting they used medication-assisted treatment (MAT) for treating opioid use disorder (55.3%) than for treating alcohol use disorder (37.9%). Those were among the findings of the Substance Abuse and Mental Health Services Administration’s (SAMHSA) National Substance Use and Mental Health Services Survey, 2021 released this week.   Researchers gathered data from April 30, 2021 through January 10, 2022 for the 35-page report, which is the most comprehensive national source of data on substance use and mental health treatment facilities, its territories, and Washington, D.C.

NABH Submits Comments to SAMHSA on Opioid Treatment Program Regulations

This week NABH submitted a comment letter to SAMHSA on the Opioid Treatment Program (OTP) regulations 42 CFR part 8. In it, NABH wrote that the association appreciates SAMHSA’s flexibility to OTPs, including new authority to provide methadone induction via telehealth. NABH was the first organization to advocate for this change when COVID-19 social-distancing measures made it hard for individuals to access methadone treatment. NABH expressed concerns and called for SAMHSA to remove changes to accreditation standards that would prematurely trigger one-year or non-accreditation status. Click here to read NABH’s letter.

NABH Submits Comments to CMS on Medicare Advantage

Also this week, NABH submitted comments to the Centers for Medicare & Medicaid Services (CMS) about policy and technical changes to Medicare Advantage (MA) for calendar year 2024. NABH noted that the association appreciates the proposed rule’s focus on improving access to and quality of care through increasing both the oversight and transparency of insurers. In particular, NABH supports the rule’s proposed improvements related to prior authorization, network adequacy, and quality of care, many of which NABH and its partners have long pursued. The association outlined a series of recommendations to CMS on topics such as clarifying “Original Medicare” standards as minimum requirements for MA; improving medical necessity; streamlining prior authorization requirements; and, regarding the rule’s proposed reduction of the overpayment window, allowing a reasonable time of about six months for providers to conduct investigations, and, when necessary, process a refund. Click here to read NABH’s letter.

Reminder: NABH-Manatt Telehealth Issue Brief Webinar on Wednesday, March 1

Manatt will host a webinar featuring NABH President and CEO Shawn Coughlin and some NABH members as panelists on Wednesday, March 1 at noon ET to highlight findings from the telehealth issue brief that the NABH Education and Research Foundation and Manatt released this month. The telehealth issue brief is the first resource from the NABH Education and Research Foundation, which worked with NABH members and Manatt to compile and evaluate data to measure the impact that telehealth services have had on access and outcomes. The study showed how telehealth services effectively augment traditional partial hospitalization programs (PHP) and intensive outpatient programs (IOP). NABH urges its members to read the issue brief and share it with others. The association has also created a social media toolkit with shareable graphics that highlight key research from the study. Members can access the issue brief and social media toolkit on the NABH Education and Research Foundation’s Resources page. Click here to register for next month’s free webinar.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Details Coming Soon for the NABH 2023 Annual Meeting

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). Details coming soon.

Fact of the Week

Some data brokers are marketing highly sensitive data on individuals’ mental health conditions on the open market, with seemingly minimal vetting of customers and seemingly few controls on using purchased data, according to a study from Duke University’s Sanford School of Public Policy. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Becerra Renews COVID-19 Public Health Emergency Through May 11

U.S. Health and Human Services Department (HHS) Secretary Xavier Becerra on Thursday renewed the nation’s COVID-19 public health emergency (PHE) status for another 90 days through May 11. “Based on current trends regarding COVID-19, the U.S. Department of Health and Human Services is planning for this to be the final renewal and for the COVID-19 PHE to end on May 11, 2023,” Becerra wrote to the nation’s governors on Feb. 9. “Rather than 60 days’ notice, I am providing 90 days’ notice before the COVID-19 PHE ends to give you and your communities ample time to transition.” Becerra’s letter also noted that the Biden administration’s whole-of-government approach to combatting the deadly virus has helped transition the country away from the emergency phase. Since Omicron peaked at the end of January 2022, daily COVID-19 reported cases are down 92%; COVID-19 deaths have declined by more than 80%; and new COVID-19 hospitalizations are down nearly 80%, Becerra’s letter noted.

NIMH to Host Webinar Next Week on the Opioid Crisis and HEALing Communities Study

The National Institute on Mental Health (NIMH) will host a webinar next Tuesday to discuss how the HEALing Communities Study (HCS) is testing the prevention and treatment of opioid misuse in communities that the nation’s opioid crisis has hit hardest. Sharon L. Walsh, Ph.D., professor of behavioral science, psychiatry, pharmacology and pharmaceutical sciences at the University of Kentucky’s Colleges of Medicine and Pharmacy, will describe how the HCS has begun to expand access to evidence-based care, improve data availability and timeliness, address social determinants of health, reduce stigma through public health communications campaigns, and modify relevant policies. Walsh also serves as director of the Center on Drug and Alcohol Research and the Substance Use Disorder Priority Research Area. She is the principal investigator of the HCS at the University of Kentucky. The HCS tests the integration of prevention, overdose treatment, and medication-based treatment in select communities. Click here to register for the free webinar, which will begin at 2 p.m. ET on Tuesday, Feb. 14.

SAMHSA Announces Funding Opportunity for Assertive Community Treatment Programs for Youth and Adults with SMI

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week announced it will award more than $5 million to establish or expand and maintain Assertive Community Treatment (ACT) programs for transition-aged youth and adults with serious mental illness (SMI).   The program’s purpose is to improve behavioral health outcomes for individuals by reducing rates of hospitalization, mortality, substance use, homelessness, and involvement with the criminal justice system. Click here to learn more about the opportunity. Applications are due by Monday, April 10.

NIDA Reports Increased Activity in ‘Blue Lotus’ Drug

The National Institute on Drug Abuse (NIDA) reported this week that, in response to mentions of blue lotus for the first time from a Rapid Street Reporting (RSR) site visit in Austin, the substance has experienced steady activity in the past three years, with activity peaking in early and late 2022. Also known as Nymphae caerulea, blue lotus is a water lily primarily found in East Africa and the Arabian Peninsula. The flower contains aphorphine, a dopamine agonist, and is sold primarily as tea extracts or incense. Click here to learn more about blue lotus and the RSR team’s other recent findings in NIDA’s Feb. 10 newsletter.

In Case You Missed It: NABH Education and Research Foundation and Manatt Produce Issue Brief on Telehealth Services in PHP and IOP

The NABH Education and Research Foundation on Feb. 1 released an issue brief that shows how telehealth services effectively augment traditional partial hospitalization programs (PHP) and intensive outpatient programs (IOP). The telehealth issue brief is the first resource from the NABH Education and Research Foundation, which worked with NABH members and Manatt to compile and evaluate data to measure the impact that telehealth services have had on access and outcomes. NABH urges its members to read the issue brief and share it with others. The association has also created a social media toolkit with shareable graphics that highlight key research from the study. Members can access the issue brief and social media toolkit on the NABH Education and Research Foundation’s Resources page. Manatt will host a webinar about the issue brief’s findings on Wednesday, March 1 at noon ET. Click here to learn more and register for the free webinar. The NABH Education & Research Foundation fields independent studies and partners with other organizations to identify and develop best practices and improve NABH members’ ability to support the country’s behavioral health needs.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Details Coming Soon for the NABH 2023 Annual Meeting

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). Details coming soon.

Fact of the Week

Medicare Advantage (MA) enrollment increased by 22.2 million beneficiaries, or 337%, from 2006 through 2022, while traditional Medicare enrollment declined by 1.0 million, or −2.9% during that period, according to a study published this week in the journal Health Affairs. The increase in MA enrollment and penetration “indicates that beneficiaries are reforming Medicare with their feet,” the study’s authors wrote. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Education and Research Foundation Partners with Manatt to Produce Issue Brief on Telehealth Services in PHP and IOP

The NABH Education and Research Foundation this week released an issue brief that shows how telehealth services effectively augment traditional partial hospitalization programs (PHP) and intensive outpatient programs (IOP). The telehealth issue brief is the first resource from the NABH Education and Research Foundation, which worked with NABH members and Manatt to compile and evaluate data to measure the impact that telehealth services have had on access and outcomes. Results from the study show that using telehealth services improved access to care and optimized the reach of existing personnel. The initial findings from several NABH members also indicated that, relative to in-person services, telehealth delivery-of-care produced similar or better outcomes for PHP and IOP patients. The telehealth issue brief’s key findings also include: During the COVID-19 crisis, regulatory flexibilities enabled traditional in-person PHPs and IOP programs to implement telehealth services rapidly. Using telehealth to deliver PHP and IOP services has improved access to care for remote patients and those facing other access obstacles. Emerging research is showing that, relative to in-person care, the use of telehealth in PHPs and IOPs generally is improving the quality of clinical care, patient satisfaction and the overall efficiency of the healthcare system. NABH urges its members to read the issue brief and share it with others. The association has also created a social media toolkit with shareable graphics that highlight key research from the study. Members can access the issue brief and social media toolkit on the NABH Education and Research Foundation’s Resources page. Manatt will host a webinar about the issue brief’s findings on Wednesday, March 1 at noon ET. Click here to learn more and register for the free webinar. The NABH Education & Research Foundation fields independent studies and partners with other organizations to identify and develop best practices and improve NABH members’ ability to support the country’s behavioral health needs.

New 9th Circuit Court of Appeals Ruling Threatens Behavioral Healthcare Coverage

A three-judge panel in the 9^th U.S. Circuit Court of Appeals on Jan. 26 replaced its March 2022 ruling in the Wit v. United Behavioral Health (UBH) case with a new opinion that is a major disappointment to both mental health patients and providers. NABH asserts the latest opinion will materially reduce the benefit of insurance because it does not protect medically necessary treatment based on generally accepted standards of care. NABH refuses to allow insurers to deny medically appropriate care to those who need it and will file a new amicus brief and request that the 9^th Circuit rehear the case. The U.S. District Court for the Northern District of California’s initial ruling on this class action case in 2019 affects more than 100 million health insurance enrollees. The ruling, considered one of the most significant of the last decade, found that UBH’s reimbursement guidelines for psychiatric conditions were non-compliant with generally accepted standards of care and treatment. In its ruling, the District Court articulated a series of clinical standards for behavioral healthcare treatment that emphasized the need for treatment to sustain improvement, rather than only address an immediate clinical crisis. The District Court also applied a holistic approach that required treatment for both primary and comorbid impairments, such as the combination of depression and a substance use disorder. A year after this finding, the District Court ordered UBH to reprocess more than 50,000 claims it had initially denied. The 9^th Circuit Court of Appeals subsequently undid this ruling with its 2022 memorandum. While the latest ruling in this case is a disappointment, NABH and other behavioral healthcare groups found both positive and negative elements in it. These include: Positive Factors:

• The 9^th U.S. Circuit Court of Appeals found that UBH violated its fiduciary duty to all class members by using medical necessity criteria that were infected by UBH’s financial conflict of interest.
• The 9^th U.S. Circuit Court of Appeals upheld the U.S. District Court’s finding that UBH broke the laws of four states, which required UBH to apply specific substance use criteria to evaluate medical necessity.

Negative Factors:

• The 9^th U.S. Circuit Court of Appeals held that UBH does not have to reprocess over 60,000 claims for class members denied coverage under UBH’s flawed guidelines, contrary to longstanding precedent on reprocessing as an ERISA remedy.
• The 9^th U.S. Circuit Court of Appeals held that all ERISA class action members must first exhaust their administrative remedies, even if doing so would be futile, as the U.S. District Court found was the case here.
• The 9^th U.S. Circuit Court of Appeals held that insurers may use medical necessity criteria that are inconsistent with generally accepted standards of care.

CMS Updates Audit Protocol for Medicare Advantage Payments

The Centers for Medicare and Medicaid Services (CMS) on Jan. 30 issued a final rule related to using risk adjustment to ensure accurate payment for services provided under Medicare Advantage (MA). Modifications to the risk adjustment audit protocol, called risk adjustment data validation (RADV), and the related overpayment refund process were initially issued in a 2018 proposed rule. Final action was delayed until now, in part, due to the COVID-19 pandemic. The final rule reflects estimates from the HHS Office of the Inspector General of more than $15 billion in MA overpayments in fiscal year 2019, or about 7% of total payments. The final rule takes effect April 3, 2023 and has an estimated recovery amount of $4.7 billion in over 10 years. NABH supports this final rule’s objective to increase oversight of payment accuracy under MA and improve the alignment between payments and medically necessary services for enrollees. To align MA payments with the clinical needs of enrollees, CMS risk-adjusts payments based on patients’ health status and key characteristics. The goal of risk adjustment is to pay less for healthier enrollees and more for more medically complex enrollees. To identify any inaccuracies in MA risk-adjustment’s impact on payments, CMS conducts retrospective RADV audits of a sample of each plan’s enrollees—typically about 200 per plan— to review their medical records to quantify any gaps between medically necessary care and reimbursed services. Extrapolation: Beginning with payment year (PY) 2018, rather than PY 2011, as proposed, the overpayments quantified through RADV audits will be extrapolated to the full MA contract. While not articulated in the final rule, CMS’ extrapolation methodology will be disclosed to MA insurers and be focused on insurers identified as being at highest risk for improper payments. CMS stated that its use of extrapolation is intended to incentivize meaningful steps by its contractors to reduce improper MA risk-adjusted payments. Overpayments identified for PYs 2011 through 2017 will be refunded to CMS without the application of extrapolation. FFS Adjuster: In addition, as proposed, the final rule will not apply an adjustment factor (known as an FFS Adjuster) to RADV audit findings, which is a form of risk adjustment. This final position is based on recent case law, which found that the FFS adjuster must be applied to MA payments but not refunded overpayments, including those identified during a RADV audit.

Congressional Research Services Releases Parity Report

The Congressional Research Service (CRS)—the public policy research institute of the U.S. Congress—this week released a report that explains mental health/substance use disorder benefit coverage and parity requirements and the types of private health insurance plans subject to those requirements. The report includes a brief review of relevant legislative history, including changes enacted in December 2022, and a discussion and examples of required federal agency activities. The CRS focused on federal private insurance requirements; it does not compare state requirements or actual plan variation in coverage. It also does not examine mental health benefits in Medicare and Medicaid. Click here to read the report.

National Institute of Mental Health Develops Strategic Framework to Address Youth Mental Health Disparities

The National Institute of Mental Health (NIMH) has developed the National Institute of Mental Health (NIMH) Strategic Framework for Addressing Youth Mental Health Disparities for fiscal years 2022–2031, a resource intended to provide a conceptual approach to help guide NIMH activities, including research funding, stakeholder engagement, and workforce development related to research on the mental health needs of youth affected by racial and ethnic health disparities. “Our country is in the midst of a youth mental health crisis, including alarming increases in youth suicide in recent years,” Christina P.C. Borba, Ph.D., M.P.H., wrote in the framework’s foreword message. “We also know that youth exposed to racism, discrimination, and other adverse experiences, as well as those from disadvantaged and underserved communities, are disproportionately impacted by mental illnesses, and frequently experience reduced access to high-quality, evidence-based mental health services and receive fewer follow-ups in a variety of provider settings,” Borba continued. “Addressing these challenges will require sustained attention, effort, and resources – all built on a foundation of high-quality research.”

News Report Shows How States are Responding to Synthetic Opioid Nitazene

The news outlet Axios recently examined how nitazene, a synthetic opioid thought to be 40 times more powerful than fentayl, is complicating the public health response to the opioid crisis in various states. Nitazene comes in powder, pill, and liquid form and requires significant lab work to trace. “Often laced into substances that users think is fentanyl or heroin, it’s potentially lethal or can cause a more severe onset of withdrawal symptoms,” the story noted. The Centers for Disease Control and Prevention (CDC) last September published a study on nitazene-related deaths in Tennessee from 2019-2021 and reported that nitazenes are an emerging group of highly potent psychoactive substances for which tests are not often included in standard toxicology panels. “Given their potency, raising awareness about nitazenes and implementing strategies to reduce harm through increased testing, surveillance, and linkage to treatment for substance use disorders are of vital importance,” the CDC study said. “More data are required to better understand this emerging group of psychoactive substances in the United States.”

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Details Coming Soon for the NABH 2023 Annual Meeting

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). Details coming soon.

Fact of the Week

A new Pew Research Center study shows that 40% of parents report they are “extremely/very” worried that their children might struggle with anxiety or depression at some point. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Submits Comment Letter on Federal and State Health Exchange Proposed Rule for 2024 Today, NABH submitted comments on the Contract Year 2024 proposed rule related to the federal and state health exchange marketplace. NABH expressed support for the generally positive rule, including its multiple proposals to assist consumers seeking to enroll in exchange-based health plans and, ultimately, to access mental health and substance use disorder treatments. Our comments also called for the Centers for Medicare & Medicaid Services (CMS) to, rather than merely requiring a minimal contracting attempt, as proposed, require health plans to meet a minimum contracting level based on a percentage of available mental health facilities and substance use disorder treatment centers. In addition, the letter urged CMS to evaluate the current level of actual coverage for mental health services being provided by plans on the federal and state marketplace. We also called on CMS to study the impact of insurer network expansion practices that result in some behavioral health sites and services being unilaterally added to, or “deemed” members of, health plan networks and paid an in-network rate that was already rejected by the provider. The comment deadline for this proposed rule is Monday, January 30. CMS Approves California’s Medicaid 1115 Demonstration Amendment to Support Care for Justice-Involved Individuals and Contingency Management  The Centers for Medicare & Medicaid Services (CMS) approved a first-of-its-kind demonstration amendment in California which will provide a set of critical pre-release services and improve access to needed care for people returning home from jails and prisons. This approval marks the first time Medicaid will pay for pre-release services to incarcerated individuals.  As part of the approval, California will also increase and sustain provider payment rates and Medicaid managed care payment rates in behavioral health and select other services. In another first for the country, the waiver also includes approval for the use of contingency management for individuals with stimulant use disorders (StUDs). The waiver outlines procedures and protocols for using financial incentives in a 24-week program to reinforce the non-use of stimulants. The protocol is followed by six or more months of additional recovery support services. Importantly, the protocols integrate measures to protect against fraud and abuse, first identified by the Motivational Incentives Policy Group, of which NABH is a member. The waiver introduced Medicaid reimbursable services provided by a Contingency Management Coordinator, a new job classification. It is believed that this pilot will serve as a template for other states that are seeking to integrate treatment for individuals with StUD.

SAMHSA Announces Funding Opportunity for Community Programs to Help Youth and Young Adults at High Risk for Psychosis

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced that applications are open for a program to provide trauma-informed, evidence-based interventions to youth and young adults who are at clinical high risk for psychosis. Award recipients are expected to use evidence-based intervention to improve symptomatic and behavioral functioning; enable youth and young adults to resume age-appropriate social, academic, and/or vocational activities; delay or prevent the onset of psychosis; and minimize the duration of untreated psychosis for those who develop psychotic symptoms. The deadline for applications is Tuesday, March 14. Click here to learn more and to apply.

CDC Study Shows that Treating Substance Use Disorders Costs Employer-sponsored Health Insurance over $35 Billion per Year

This week, the Centers for Disease Control and Prevention (CDC) released a study assessing the medical cost of substance use disorders for US employers, employees, and health insurance plans.  The study assessed 162 million non-Medicare eligible enrollees with employer-sponsored health insurance in 2018.  The study determined that the total annual medical cost in that population was $35.3 billion and alcohol-related disorders and opioid-related disorders were the most costly. It should be noted that this amount is a fraction of the $1.1 trillion of the total personal health care expenditures paid by private insurance in the US in 2018.

NABH Mourns Behavioral Healthcare Industry Leader Joey Jacobs

NABH mourns the passing of retired behavioral healthcare executive and leader Joey J. Jacobs, 69, who died Jan. 14 in Nashville following an extended illness. Jacobs held various roles at Nashville, Tenn.-based HCA Healthcare and co-founded Psychiatric Solutions before he sold the company 13 years ago. Jacobs was also the chair and CEO of Franklin, Tenn.-based Acadia Healthcare, all NABH system members.  A former member, Jacobs served on the NABH Board from 2005 through 2009 when NABH was the National Association of Psychiatric Health Systems. In addition to his wife, Debbie Hammer Jacobs, Jacobs is survived by two sons, Brent and Scott; three grandchildren; and other family members. Services were held on Jan. 20.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Details Coming Soon for the NABH 2023 Annual Meeting

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). Details coming soon.

Fact of the Week

A new cross-sectional study including 74,474 opioid-involved deaths, buprenorphine was involved in 2.6% of opioid-involved overdose deaths during July 2019 to June 2021. Although monthly opioid-involved overdose deaths increased, the proportion of involving buprenorphine fluctuated—but did not increase. For questions or comments about this CEO Update, please contact Jessica Zigmond.

SAMHSA Announces Monica Johnson as 988 & Behavioral Health Crisis Coordinating Office Director

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced this week that Monica Johnson, M.A., LPC is the new director of the 988 & Behavioral Health Crisis Coordinating Office. Johnson has worked in the behavioral health field for 26 years and most recently served as the interim commissioner for the Georgia Department of Behavioral Health & Developmental Disabilities. SAMHSA’s announcement noted that Johnson has overseen and implemented successfully several programs funded through SAMHSA, the Bureau of Justice Assistance, the Office of Juvenile Justice Delinquency Prevention, and the U.S. Education Department. Johnson earned an undergraduate degree in psychology from Kennesaw State University in Georgia and a graduate degree in professional counseling and psychology at Argosy University in Virginia. She is the recipient of the Intensive Cognitive Behavior Therapy for Schizophrenia Certification at the Aaron T. Beck Institute for Cognitive Behavior Therapy in Philadelphia.

CMS to Host Call About Administration Simplification Proposed Rule on Jan. 25

The Centers for Medicare & Medicaid Services (CMS) National Standards Group will host a call to discuss the Administrative Simplification: Adoption of Standards for Health Care Attachments Transactions and Electronic Signatures, and Modification to Referral Certification and Authorization Transaction proposed rule next Wednesday, Jan. 25 from 2 p.m. to 3:30 p.m. ET. The agency will use the 90-minutes session to provide an overview of the proposed rule and also offer background on the current standards, expectations of what the proposed rule is meant to do, and information about how to submit comments. Click here to register.

CMS to Host Educational Session on Advancing Interoperability and Improving Prior Authorization Processes Proposed Rule

The CMS Office of Burden Reduction and Health Informatics will host a virtual education about the Advancing Interoperability and Improving Prior Authorization Processes proposed rule on Thursday, Feb. 9 from noon to 1 p.m. ET. On Dec. 6, CMS issued the prior authorization proposed rule, which aims to improve patient and provider access to health information and streamline processes. Click here to read the agency’s fact sheet.     Next month’s educational session is intended to help participants learn about the rule’s provisions and hear how the proposed rule builds on current CMS interoperability policies. Participants will be permitted to ask questions. Click here to register by Feb. 8.

ASAM to Release Training Module on Level of Care Certification Next Month

The American Society of Addiction Medicine (ASAM) and CARF International announced that a training module to introduce updated rating elements to the ASAM Level of Care Certification (LOCC) will be available on Feb. 15. ASAM and CARF International announced the LOCC’s updated rating elements in July 2022, and residential treatment programs that are applying for the ASAM LOCC for levels 3.1, 3.5, and 3.7 will be responsible for meeting the updated elements as part of their certification survey. These facilities will also be responsible for meeting the existing rating elements listed in the ASAM LOCC manual.

Joint Commission Releases Sentinel Event Alert About Eliminating Racial & Ethnic Disparities in Pregnant and Postpartum Patients

The Joint Commission this week released a Sentinel Event Alert about eliminating barriers and racial disparities causing mortality and morbidity in pregnant and postpartum women. Along with the announcement, the Joint Commission released a Quick Safety that addresses mental health conditions and their role in maternal death.

SAMHSA Publishes Guide on Expanding Access to Behavioral Healthcare Services for People Experiencing Homelessness

SAMHSA this week released a guide that highlights strategies for behavioral healthcare and housing providers to conduct outreach and engage with individuals experiencing homelessness. The new resource also includes strategies for how to initiate behavioral healthcare treatment as individuals wait to receive housing and retain them in their recovery efforts after they find housing.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Details Coming Soon for the NABH 2023 Annual Meeting

Please plan to join us in Washington, DC from June 12-14, 2023 for this year’s NABH Annual Meeting at the Salamander Washington, DC (formerly the Mandarin Oriental hotel). Details coming soon.

Fact of the Week

A recent study found that those on medical addiction therapy had a 63% lower likelihood of an alcohol-related liver disease diagnosis. For questions or comments about this CEO Update, please contact Jessica Zigmond.

HHS Awards Nearly $245 Million to Support Youth Mental Health and the Healthcare Workforce

The U.S. Health and Human Services Administration (HHS) announced this week it awarded nearly $245 million in funding from the Bipartisan Safer Communities Act to support youth mental health and help the healthcare workforce address mental health needs.   The funding—released through the Substance Abuse and Mental Health Services Administration (SAMHSA) and Health Resources and Services Administration (HRSA)—is for a variety of programs and grants, including Project Advancing Wellness and Resiliency in Education (Project AWARE) to help develop and support school-based mental health programs and services; Mental Health Awareness Training grants to prepare and train school personnel, emergency first responders, law enforcement, and others to recognize the signs and symptoms of mental health challenges to enable early intervention; the National Child Traumatic Stress Initiative to improve treatment for children, adolescents, and families who have experienced traumatic events, and more.   In its announcement, HHS noted that the Bipartisan Safer Communities Act included nearly $60 million to support the integration of mental health training into the training of primary care clinicians, with a specific focus on preparing primary care providers to treat the mental health needs of children and adolescents. “Often the first person you turn to when you or your kids need mental health support is your trusted primary care provider—yet for too long, we haven’t given those primary care providers the mental health training they need to help, HRSA Administrator Carole Johnson said in the announcement. “With funding from the Bipartisan Safer Communities Act, the Health Resources and Services Administration is investing in making mental health a part of primary care training so that there is no wrong door when your family needs support.”

National Academies to Host Virtual Webinars About 988 Implementation on Jan. 20 and 23

The National Academies Forum on Mental Health and Substance Use Disorders will host two virtual webinars about the challenges and opportunities related to the implementation of the 988 behavioral health crisis hotline at the state and local levels. The discussions will provide an overview of how 988 has been implemented and will also feature best practices. The two-hour webinars will be held on Friday, Jan. 20 and Monday, Jan. 23; both will begin at 12:30 p.m. ET. Click here to register.

CMS to Host National Stakeholder Call with Administrator Brooks-LaSure on Jan. 24

The Centers for Medicare & Medicaid Services (CMS) will host a national stakeholder call featuring CMS Administrator Chiquita Brooks-LaSure and her leadership team to discuss the agency’s accomplishments in 2022 and priorities for 2023. Click here to register.

Register Today for the 2023 Rx and Illicit Drug Summit in Atlanta

The 2023 Rx and Illicit Drug Summit will be held in Atlanta from April 10-13 and will include nearly 100 educational sessions organized in nine different tracks to highlight the most effective strategies for prevention, treatment, and recovery. The meeting’s advanced rate ends on Jan. 27. Click here to register.

NABH’s 2023 Priorities Featured in Mental Health Weekly & Alcohol and Drug Abuse Weekly

In case you missed it, NABH President & CEO Shawn Coughlin discussed the association’s priorities for 2023 and NABH Director of Quality and Addiction Services Sarah Wattenberg reflected on accomplishments of 2022 and hopes for the New Year in Mental Health Weekly and Alcohol and Drug Abuse Weekly, respectively.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting! Details coming soon.

Fact of the Week

In a cohort study of 5,142,577 commercially insured adults across all 50 states, the weekly rate of in-person mental health service utilization decreased by more than 50% after the Covid-19 pandemic started; however, concurrent increases in telehealth led to a slight increase in total utilization for anxiety disorders and stability in total volume of service for other disorders, according to a new study published in JAMA Health Forum. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Welcomes Harsh K. Trivedi, M.D., M.B.A as 2023 Board Chair

NABH is pleased to welcome Sheppard Pratt President & CEO Harsh K. Trivedi, M.D., M.B.A as the association’s board chair for 2023. Harsh has served as an NABH board member as well as a member of the association’s workplace violence prevention workgroup and Covid-19 task force. A graduate of the Mount Sinai School of Medicine, Harsh completed his general psychiatry residency at the Zucker Hillside Hospital/Albert Einstein College of Medicine. He completed his child and adolescent psychiatry training at Children’s Hospital Boston/Harvard Medical School. Harsh has served as president and CEO at Sheppard Pratt in Baltimore since 2016. NABH is eager to work with Harsh as the association celebrates its 90^th anniversary in 2023!

SAMHSA Releases National Survey on Drug Use and Health for 2021

About one in four U.S. adults had a mental illness and more than 16% of the population—or more than 46 million people—met the criteria for substance use disorder (SUD) in 2021, according to the Substance Abuse and Mental Health Services Administration’s (SAMHSA) National Survey of Drug Use and Health (NSDUH).   Released annually, the latest report for the 2021 calendar year also found that younger people reported even higher levels of mental illness—one in three for those between the ages of 18 and 25. Meanwhile, nearly 94% of people with SUD didn’t receive any treatment in 2021. “Every year since 1971, this survey has given us a window into our nation’s mental health and substance use challenges and 2021 was no different,” HHS Secretary Xavier Becerra said in an announcement about the survey. “As the findings make clear, millions of Americans young and old faced mental health and substance use challenges – sometimes both at once – during the second year of the pandemic,” he continued. “As we work to improve behavioral health across the nation, HHS is committed to ensuring that all people facing mental health or substance use challenges are connected to appropriate services and supports.” SAMHSA noted that estimates from the 2021 NSDUH should not be compared with estimates from previous years because the Covid-19 pandemic necessitated methodological changes to the data collection process.

CMS Issues Information Bulletin on Medicaid Provisions in Consolidated Appropriations Act, 2023

The Centers for Medicare and Medicaid Services (CMS) on Thursday issued an informational bulletin that highlights provisions in the Consolidated Appropriations Act, 2023 (CAA, 2023) related to the Medicaid continuous enrollment condition. The CAA, 2023 updates certain Medicaid and Children’s Health Insurance Program (CHIP) provisions, including significant changes to the continuous enrollment condition of the Family First Coronavirus Response Act. Under the CAA, 2023, expiration of the continuous enrollment condition will no longer be linked to the Covid-19 public health emergency (PHE); instead, the condition will end on March 31, 2023. After the condition ends, states will have up to 12 months to initiate, and 14 months to complete, a renewal for all individuals enrolled in Medicaid, CHIP, and the Basic Health Program. Click here for more details.

HRSA Urges Nurses to Apply for Nurse Corps Loan Repayment Program

The Health Resources and Services Administration (HRSA) this week announced a reminder that the Nurse Corps Loan Repayment Program opens soon. As part of the program, certain eligible nurses could qualify for up to 85% of unpaid debt. In return, they would be required to serve at least two years in a critical shortage facility in a high need area or accredited school of nursing in a U.S. state or territory. Nurses must work at eligible facilities for this program, which include public or non-profit medical facilities. Click here to learn about eligibility and application requirements.

Bipartisan Policy Center to Host Behavioral Healthcare Workforce Panel Discussion

The Bipartisan Policy Center (BPC) will host a panel discussion about the organization’s federal policy recommendations to address the huge gap between need and care on Tuesday, Jan. 24. The BPC noted that as of March 2021, about 37% of Americans lived in mental health shortage areas. Panelists will highlight findings of a new BPC report, Filling the Gaps in the Behavioral Health Workforce, which recommends ways to bolster the role of behavioral healthcare workers such as peer specialists, community health workers, and paraprofessionals, as well as community members who can help support the licensed workforce. Click here to register for the hourlong webinar that starts at noon ET on Jan. 24.

Reminder: Apply for HRSA Grants to Reduce Neonatal Abstinence Syndrome in Rural Settings

The Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy will invest $20 million in about 40 grants to reduce the incidence of neonatal abstinence syndrome (NAS) in the nation’s rural communities. According to HRSA’s announcement, grant recipients will collaborate with local, state, and regional stakeholders to provide coordinated, trauma-informed, and family centered behavioral and maternal healthcare services—including medication-assisted treatment—to rural pregnant and post-partum women and their families. Applicant organizations may be in either an urban or rural area; however, all activities supported by the program must exclusively occur in HRSA-designated, rural areas. The agency will accept applications through March 8, 2023.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

While visits to pediatric emergency rooms rose 1.5% from 2015 to 2021, visits for mental health crises increased 8% a year, according to a new study in JAMA Pediatrics. The study also found that 13% of those young patients returned in six months. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Two Proposed Rules Would Improve Prior Authorization and Network Adequacy

The Centers for Medicare & Medicaid Services (CMS) this week released two proposed rules related to longstanding concerns with Medicare Advantage (MA) plans and other insurers that are designed to improve quality of care and plan accountability. These rules respond to the HHS Office of Inspector General’s report earlier this year about inappropriate prior authorization denials by MA plans as well as 4,000 comments in 2022 from stakeholders, including NABH, on related concerns. Contract Year 2024 Proposed Rule on Medicare Advantage: Released Wednesday, this proposed rule includes significant MA refinements related to behavioral healthcare, such as a prior authorization exemption for emergency mental health services needed to evaluate and stabilize patients. It also proposes implementing a 10-percentage point payment add-on for telehealth services provided by clinical psychologists, licensed clinical social workers, and those who prescribe medication for opioid use disorder. To assist patients seeking care, the rule proposes appointment wait-time standards for primary care and behavioral healthcare services. It would also require mid-year notices for enrollees with a behavioral health or primary care provider who dropped from their plan network. Regarding network adequacy, CMS proposes adding clinical psychologists, licensed clinical social workers, and those who prescribe medication for opioid use disorder to the list of specialty types that CMS uses to evaluate MA networks. To improve parity in access, the proposed rule would also require most MA organizations to include behavioral healthcare services in care coordination programs. In addition, the rule clarifies that plans should include both physical and mental conditions in their coverage of emergency medical care. Also, to address stakeholders’ concerns regarding the dramatic increase in opioid overdose deaths during the Covid-19 pandemic, the rule proposes that MA organizations designate in their provider directories those who obtained a waiver from the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Drug Enforcement Administration to treat patients with medications for opioid use disorder and are listed on SAMHSA’s Buprenorphine Practitioner Locator. Comments to CMS are due by Monday, Feb. 13, 2023. Federal Health Exchange Notice of Benefit and Payment Parameters for 2024: On Monday, the agency issued a proposed rule related to all health insurers participating in federal and state health insurance exchanges. Specifically, CMS would categorize mental health facilities and substance use disorder (SUD) treatment centers as essential community providers and require insurers to include at least one of these providers in each network. Previously, mental health facilities and SUD treatment centers had been designated in the “other” category. In addition, the rule would require contract reviews to assess the actual availability of SUD and mental health services. To address concerns about reduced access to care after the Covid-19 public health emergency ends, CMS has proposed extending by 60 to 90 days those who would otherwise lose Medicaid or Children’s Health Insurance Program coverage in January 2024. Comments on this rule will be accepted during the 45-day period after the rule is published in the Federal Register.

SAMHSA’s Proposed Rule Permits Methadone Prescribing for New Patients via Telemedicine

SAMHSA this week proposed updating federal regulations to permit using audio-visual telehealth services for any new patient treated with methadone in an Opioid Treatment Program (OTP) under specific conditions. In a proposed rule, SAMHSA said federal regulations should be updated to allow using audio-visual telehealth services for patients treated with methadone in OTPs only if a program physician, or an authorized healthcare professional under the supervision of a program physician, determines that an adequate evaluation of the patient can be accomplished via an audio-visual telehealth platform. This change is not extended to using audio-only telehealth platforms and applies only to ordering methadone that an OTP dispenses under existing OTP procedures. In addition, SAMHSA’s proposed changes would update 42 CFR Part 8 by removing stigmatizing or outdated language; supporting a more patient-centered approach to treatment; and reducing barriers to receiving care. SAMHSA’s proposed changes also would revise standards to reflect an OTP accreditation and treatment environment that has evolved since Part 8 became effective in 2001. Consequently, SAMHSA said its proposed revisions reflect evidence-based practice, language that aligns with current medical terminology, effective patient engagement approaches, and the workforce providing services in OTPs, including:

• expanding the definition of an OTP treatment practitioner to include any provider who is appropriately licensed to dispense and/or prescribe approved medications. The current Part 8 rule defines a practitioner as being: “a physician who is appropriately licensed by the State to dispense covered medications and who possesses a waiver under 21 U.S.C.823(g)(2).” During the Covid-19 public health emergency, this has been formally expanded to align with broader definitions of a practitioner (nurse practitioners, physician assistants, etc.), and OTPs reported that this change was essential in supporting workflow and access;
• adding evidence-based delivery models of care, such as split dosing, telehealth, and harm-reduction activities;
• removing such outdated terms as “detoxification”;
• updating criteria for provision of take-home doses of methadone;
• strengthening the patient-practitioner relationship through promoting shared and evidence-based decision-making;
• allowing for early access to take-home doses of methadone for all patients, to promote flexibility in creating plans of care that facilitate such every-day needs as employment, while also affording people with unstable access to reliable transportation the opportunity to also receive treatment; likewise, promoting mobile medication units to expand an OTPs geographic reach; and
• reviewing OTP accreditation standards.

According to SAMHSA, the changes– which are part of President Biden’s National Drug Control Strategy – come at a time when fewer than one out of 10 Americans can access treatment for substance use disorder. SAMHSA will accept public comments on the proposed rule until Feb. 14, 2023.

NASHP Brief Highlights State Opioid Spending Plans

The National Academy for State Health Policy has released Understanding Opioid Settlement Spending Plans Across States: Key Components and Approaches, which highlights how states are implementing structures to disburse the more than $50 billion in opioid settlement funds awarded to them. Opioid settlement funds began pouring into states this year, including about $26 billion from a settlement that 46 states agreed to with Johnson & Johnson (J&J), AmerisourceBergen, Cardinal Health, and McKesson in July 2021. To understand common challenges and potential best practices for state leaders, NASHP engaged state leaders nationwide to understand both the structure and status of their current opioid settlement planning activities. NASHP is also analyzing governing materials and entities such as state legislation, opioid settlement agreements and spending plans, advisory committees, and other groups charged with disbursing state funding, which are referenced in NASHP’s tracker.

SAMHSA Releases Resource Highlighting Drug-Related ED Visits in 2021

SAMHSA has released Drug Abuse Warning Network (DAWN): Findings from Drug-Related Emergency Department Visits, 2021, an analysis of DAWN data with a variety of information for drug-related emergency department (ED) visits last year. The report highlights nationally representative weighted estimates, including percent and unadjusted rates per 100,000, for all drug-related ED visits; nationally representative weighted estimates for the top five drugs in drug-related ED visits; an assessment of trends and drugs involved in polysubstance ED visits in a subset of sentinel hospitals; and the identification of drugs new to DAWN’s Drug Reference Vocabulary.

Brookings Institution Releases Papers on Behavioral Health Integration and Youth Services

The Brookings Institution this week released two academic white papers related to behavioral healthcare: Making Progress on Integration of Behavioral Health Care and Other Medical Care and Meeting the Moment Children’s Mental Health: Recommendations for Federal Policy.   The first is a 10-page analysis of recent policy efforts in the nation’s evolving healthcare system, and the second paper seeks to clarify the potential sources of the persistent problems in mental illnesses in children. The 22-page youth services white paper also considers what tools the federal government should employ to address the crisis.

Reminder: Apply for HRSA Grants to Reduce Neonatal Abstinence Syndrome in Rural Settings

The Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy will invest $20 million in about 40 grants to reduce the incidence of neonatal abstinence syndrome (NAS) in the nation’s rural communities. According to HRSA’s announcement, grant recipients will collaborate with local, state, and regional stakeholders to provide coordinated, trauma-informed, and family centered behavioral and maternal healthcare services—including medication-assisted treatment—to rural pregnant and post-partum women and their families. Applicant organizations may be in either an urban or rural area; however, all activities supported by the program must exclusively occur in HRSA-designated, rural areas. HRSA will offer a webinar for applicants on Wednesday, Jan. 4, 2023 from 2 p.m. to 3 p.m. ET; registration is not required. The agency will accept applications through March 8, 2023.

Reminder: NABH 2023 Board Election Ballots Due Friday, Dec. 30 

NABH has e-mailed system members NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2023 Board. If you have not done so, please vote for the open Board Chair-Elect position and one available Board seat; 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. 30, 2022. New Board members and the Board Chair-elect will take office in January 2023.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Fentanyl is now the leading cause of death for Americans between the ages of 18 and 49, according to a Washington Post analysis of death data for 2021 from the Centers for Disease Control and Prevention. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Proposes Electronic Prior Authorization for Providers and Payers

The Centers for Medicare & Medicaid Services (CMS) this week released a proposed rule that would require certain providers and payers to implement an electronic prior-authorization process, shorten the timeframe for payers to respond to prior-authorization requests, and work to make the prior-authorization process more efficient and transparent. An announcement from CMS said the proposed requirements would apply to Medicare Advantage (MA) organizations, state Medicaid and Children’s Health Insurance Program (CHIP) agencies, Medicaid managed care plans, CHIP managed care entities, and qualified health plan issuers on the federally facilitated exchanges. The agency estimates that these proposed policies could create efficiencies that would save physician practices and hospitals more than $15 billion over a 10-year period. The rule would automate essential prior-authorization functions related to documentation, requests, and decisions. Also, payers would be required to provide a clear reason for denials and to respond to urgent prior-authorization requests within 72 hours and standard requests within seven days. The proposed electronic platform is the already-established “Patient Access API,” which uses the Health Level 7^® format. The rule also would enhance patients’ access to their own information on prior- authorization requests, approvals, and related information by requiring online reporting of certain performance metrics. CMS is seeking information from stakeholders on the following topics:

• How to standardize data on patients’ social risk factors (e.g., housing instability, food insecurity) that influence patient health and health care utilization;
• How to advance electronic data exchange among behavioral health providers;
• How to improve the exchange of medical documentation between and among providers/suppliers and patients (for the purpose of care coordination);
• How to enable the connection of health information networks to advance cross-organization interoperability, such as the prior-authorization improvements in this rule, including incentives for payers; and
• Evidence-based policies that CMS could pursue to leverage health IT, data sharing, and interoperability to improve maternal health outcomes.

NABH will address these and the rule’s other key provisions in the association’s formal comments. CMS will publish the rule in the Federal Register on Dec. 13, 2022 and accept comments through March 13, 2023.

Biden Administration Launches Opioid Overdose Dashboard

The Biden Administration on Thursday unveiled a website featuring the Office of National Drug Control Policy’s (ONDCP) new Opioid Overdose Tracker to monitor non-fatal, opioid overdoses in the pre-hospital setting in an effort to prevent overdose deaths. Non-fatal overdoses are a good predictor of fatal overdoses, Biden administration officials said during a news briefing Wednesday according to Politico. People who experience at least one non-fatal overdose are about two to three times more likely to eventually die from one, they said. Earlier this year, the Centers for Disease Control and Prevention estimated that 80,816 Americans died from opioid overdoses in 2021, increasing from an estimated 70,029 in 2020. Using data submitted to the National Emergency Medical Services Information System (NEMSIS), the new dashboard contains one interactive page with a geo-surveillance view, and its data set includes all de-duplicated Emergency Medical Services (EMS) patient care reports for a rolling time period that meet specific inclusion criteria. In 2022, all 50 states, three territories (the Virgin Islands, Guam, and the Northern Mariana Islands), and Washington, D.C. had submitted data to the national database, according to NEMSIS. The NEMSIS Technical Assistance Center collects data from about 95% of all EMS agencies in the United States that respond to 911 requests for emergency care and transport patients to acute care facilities. According to a National Public Radio story, ONDCP Director Rahul Gupta, M.D. told reporters during a call that “We could see tens of thousands of additional lives saved” with the new tool, which Gupta said he hopes first responders, clinicians, and policymakers will use to connect people to care and also minimize response times and ensure that resources are available. NABH has advocated that the dashboard be updated in 2023 to use numbers at the state and county levels, as well as the national level.

New Report Shows Number of Patients Receiving Medications for Opioid Use Disorders in OTPs

Of the 512,224 patients in Opioid Treatment Programs (OTPs) who reported using medications for opioid use disorders (MOUDs), 476,763 reported using methadone, 33,473 reported buprenorphine, and the remaining 1,988 reported using naltrexone, according to a new report from the National Association of State Alcohol and Drug Abuse Directors (NASADAD). NASADAD partnered with the American Association for the Treatment of Opioid Dependence (AATOD) for the study, which was funded to determine the number of patients who receive MOUDs in OTPs, the types of federally approved medications that patients use in treatment, and the specific formulations of medication used among the patient population. Researchers analyzed data from 1,547 Opioid Treatment Programs (OTPs) nationwide that completed the survey, reflecting an 85-percent response rate. The Substance Abuse and Mental Health Services Administration funded the study through the agency’s Opioid Response Network.

MedPAC Discusses Draft Recommendations for 2024 Physician Payment Increases

The Medicare Payment Advisory Commission (MedPAC) this week discussed draft recommendations to increase the Medicare base payment rate for physician and other health professional services by 1.25% in 2024, a rate that is half of the forecasted increase in the Medicare Economic Index for 2024. Current law calls for no updates to 2024 payment rates relative to 2023 levels. The commission also discussed supporting a payment add-on for services for low-income Medicare beneficiaries (15% for primary care; 5% for non-primary care), which new Medicare spending would fund. The purpose of these items is to help maintain access to physician services for Medicare beneficiaries. Both measures received substantial support from the commissioners, and they are expected to be approved as formal recommendations to Congress when MedPAC convenes in January to vote on these and other Medicare payment adequacy recommendations for 2024.

HHS Highlights Progress to Mark One-Year Anniversary of HHS’ Overdose Prevention Strategy

Since the Biden administration released its Overdose Prevention Strategy a year ago, the number of healthcare providers with waivers to prescribe buprenorphine for opioid use disorder increased by 19% and the number of naloxone prescriptions filled in pharmacies has increased by 37%, HHS announced late last week. The announcements were made in conjunction with a news conference HHS Secretary Xavier Becerra held to mark the first anniversary of the Biden administration’s Overdose Prevention Strategy. During the news conference, Becerra highlighted some of the strategy’s recent actions, including an announcement from the Centers for Disease Control and Prevention (CDC) that state, local, and territorial awardees of the CDC Overdose Data to Action cooperative agreement can use a portion of their funds to purchase naloxone; and the U.S. Food and Drug Administration’s notice last month that certain naloxone products have the potential to be safe and effective for over-the-counter use.

HRSA to Invest $20 Million in Grants to Reduce Neonatal Abstinence Syndrome in Rural Settings

The Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy will invest $20 million in about 40 grants to reduce the incidence of neonatal abstinence syndrome (NAS) in the nation’s rural communities. According to HRSA’s announcement, grant recipients will collaborate with local, state, and regional stakeholders to provide coordinated, trauma-informed, and family centered behavioral and maternal healthcare services—including medication-assisted treatment—to rural pregnant and post-partum women and their families. Applicant organizations may be in either an urban or rural area; however, all activities supported by the program must exclusively occur in HRSA-designated, rural areas. HRSA will offer a webinar for applicants on Wednesday, Jan. 4, 2023 from 2 p.m. to 3 p.m. ET; registration is not required. The agency will accept applications through March 8, 2023.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

A new study published in The Lancet Psychiatry found that people with severe mental illness have an elevated risk for several chronic health problems even before they receive their first diagnosis of a severe mental illness. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Senate Finance Committee Releases ‘Fifth and Final’ Mental Health Parity Discussion Draft

Senate Finance Committee leaders on Thursday released what they said is their fifth and final legislative mental health parity discussion draft in their effort to place access to behavioral healthcare on par with physical healthcare in Medicare and Medicaid.   Previous iterations of the draft were released in May, June, September, and November this year. Policies in the final draft include: strengthening the accuracy of provider directories in Medicare Advantage plans; strengthening requirements in Medicaid for managed care organizations and states to maintain regularly updated provider directories that include, in part, information on accessing care from behavioral health professionals; directing the Government Accountability Office (GAO) to conduct a study of the differences in enrollee cost-sharing and utilization management between behavioral and non-behavioral health services in Medicare Advantage and compared with traditional Medicare; requiring Medicare to provide guidance to health care providers detailing the extent to which Medicare beneficiaries with substance use disorders can receive partial hospitalization program services; and directing GAO to report on Medicaid payment rates for behavioral health services compared to medical and surgical services across a sample of states. “Too often the notion of mental health parity falls short of reality,” Senate Finance Committee Chairman Ron Wyden (D-Ore.) said in an announcement about the discussion draft. “These policies represent the first step towards addressing the mental health parity and ghost network challenges that I intend to build on in the coming months—especially the challenges I hear about consistently from families at home who aren’t able to find available mental health professionals covered in their insurance networks,” he added.

HHS Releases Proposed Rule to Revise 42 CFR Part 2 Regulations

The U.S. Health and Human Services Department (HHS) this week released a proposed rule to revise regulations known as 42 CFR Part 2, or “Part 2,” which protect the confidentiality of substance use disorder (SUD) treatment records. Specifically, Part 2 protects “records of the identity, diagnosis, prognosis, or treatment of any patient which are maintained in connection with the performance of any program or activity relating to substance abuse education prevention, training, treatment, rehabilitation, or research, which is conducted, regulated, or directly or indirectly assisted by any department or agency of the United States.”  The protections are meant to address concerns that discrimination and fear of prosecution deter people from entering treatment for SUD. The rule proposes a host of revisions, including, but not limited to: permitting Part 2 programs to use and disclose Part 2 records based on a single prior consent signed by the patient for all future uses and disclosures for treatment, payment, and healthcare operations; permitting the redisclosure of Part 2 records as permitted by the Health Insurance Portability and Accountability Act (HIPAA) privacy rule by recipients that are Part 2 programs, HIPAA-covered entities, and business associates, with certain exceptions; and expanding prohibitions on using and disclosing Part 2 records in civil, criminal, administrative, or legislative proceedings conducted by a federal, state, or local authority against a patient, absent a court order or the consent of the patient. HHS released a summary of the proposed rule’s provisions and will accept comments for up to 60 days after the proposed rule is published in the Federal Register.

DEA Lab Testing Reveals 6 out of 10 Fentanyl-Laced, Fake Prescription Pills Contain a Potentially Lethal Dose of Fentanyl

The Drug Enforcement Administration (DEA) this week alerted the public of a sharp rise nationwide in the lethality of fentanyl-laced, fake prescription pills.   In a public safety alert, the agency said the DEA laboratory found that of the fentanyl-laced, fake prescription pills analyzed in 2022, six out of 10 contained a potentially lethal dose of fentanyl. This is an increase from DEA’s previous announcement in 2021 that four out of 10 fentanyl-laced fake prescription pills were found to contain a potentially lethal dose. According to the alert, the pills are largely made by two Mexican drug cartels, the Sinaloa Cartel and the Jalisco (CJNG) Cartel, to look identical to real prescription medications, including OxyContin®, Percocet®, and Xanax®, and they are often deadly. In 2021, the DEA seized more than 20.4 million fake prescription pills, and earlier this year, the DEA conducted a nationwide operational surge to target the trafficking of fentanyl-laced fake prescription pills and, seized 10.2 million fake pills in all 50 states in just more than three months. The DEA’s One Pill Can Kill campaign alerts the American public of the dangers of fake prescription pills.

NIDA Director Volkow Calls for Dismantling Stigma at Intersection of HIV and Meth Use 

In her blog post to commemorate World Aids Day on Thursday, Dec. 1, National Institute on Drug Abuse (NIDA) Director Nora Volkow, M.D. promoted NIDA’s video “Sex, Meth and HIV,” to emphasize that in order to end the HIV epidemic it is important to recognize and respect both the complexity and needs of sexual and gender minorities who use drugs. “Like other drugs, methamphetamine may help individuals cope with mental health challenges like depression, anxiety, and trauma,” Volkow wrote. “Some gay and bisexual men use methamphetamine to enhance sexual experience and sense of connectedness,” she added. “It can also temporarily boost self-confidence among individuals who may experience stigma and shame surrounding sexuality or other aspects of their lives.” Volkow referenced a 2020 study in the Journal of Acquired Immune Deficiency Syndromes (JAIDS), which showed that a third of new HIV transmissions among sexual and gender minorities who have sex with men were in people who regularly use methamphetamine.   On a related note, at a conference in Boston last month, Volkow said American physicians should “absolutely” be allowed to prescribe methadone to their patients. “There’s absolutely no reason why not,” Volkow said, according to a story in STAT. “There are countries where physicians are providing methadone, and the outcomes are actually as good as those they get [at] methadone clinics.”

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting! Fact of the Week The likelihood that someone with serious mental illness will be the victim of a violent crime is 11.8 higher when compared with the general public. For questions or comments about this CEO Update, please contact Jessica Zigmond.

HHS Announces $350 Million Initiative to Boost Covid-19 Vaccinations

The U.S. Health and Human Services Department’s (HHS) Health Resources and Services Administration (HRSA) on Tuesday announced a $350 million initiative for HRSA-supported health centers to increase Covid-19 vaccinations in their communities, with a specific focus on underserved populations. The funding will help health centers provide Covid-19 vaccines through mobile, drive-up, walk-up, or community-based vaccination events, including working with community-based organizations and other efforts to increase administering Covid-19 vaccines. According to HHS, health centers have administered more than 22 million vaccines in underserved communities nationwide, of which 70% to patients of racial and ethnic minorities.

Study Shows Shortage of Mental Healthcare Providers Associated with Higher Youth Suicide Rate

Counties with a shortage of mental healthcare providers were connected to higher rates of youth suicide, researchers reported this week in JAMA Pediatrics. The study noted that that while the findings are based on data from 2015 and 2016, the report comes at a time with the number of Americans living in areas with a shortage of mental health professionals is growing. Federal data show more than 150 million people live in such areas. Meanwhile, researchers initially found that counties with provider shortages had a 41% higher youth suicide rate: 5.09 per 100,000 youths compared with 3.62 per 100,000 in counties without shortages. And when the researchers controlled for socioeconomic and other confounding factors—rural and high-poverty areas are known to have higher suicide rates—they still found that living in a county with a shortage of mental health workers was associated with a 16% higher youth suicide rate. “Strategies to ameliorate mental health professional workforce shortages…. may be considered in comprehensive youth suicide prevention programs,” the authors concluded.

NABH and Other Groups Urge Congress to Support Medicare Mobile Crisis Intervention Benefit

NABH is one of more than 50 organizations that sent a letter to House and Senate leaders urging the federal lawmakers to include a mental health crisis intervention benefit in the Medicare program in Congress’ end-of-year legislative package. The organizations represent mental health and substance use treatment providers, crisis centers, family members, advocates, justice-focused organizations, and payers committed to strengthening access to mental healthcare and substance use treatment. The letter explains that in the most recent discussion draft on Integration, Coordination, and Access to Care, the Senate Finance Committee included a key provision of payment for mobile crisis response intervention services under the Physician Fee Schedule, which would add this benefit to the Medicare program. Mobile crisis teams include mental health professionals and individuals who provide peer-support services who are trained to de-escalate a situation and help the individual connect with services and supports.   “Since its launch in July, calls to the 988 Lifeline increased exponentially even more than predicted in SAMHSA’s December 2020 capacity report to Congress. Data from September 2022 vs. September 2021 show calls answered increased by 40%, chats answered increased by 218%, and texts answered increased by 1153%,” the letter said. “While one-time grant funds are helpful to initiate programs, they are not sufficient to sustain them, especially in light of increasing demand,” the letter continued. “In 2021, Congress provided incentives to states to increase Medicaid coverage of mobile crisis teams. Now, it should allow a mobile crisis intervention benefit in Medicare.”

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have submitted data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Researchers have identified variations in 10 genes that significantly raise the risk for schizophrenia—information that could help identify new treatment targets, according to the National Institutes of Health, which funded one of the largest genetic studies of its kind.

Happy Thanksgiving from NABH!

The NABH staff wishes its members and their families a very happy, healthy, and safe Thanksgiving! For questions or comments about this CEO Update, please contact Jessica Zigmond.

News Reports Signal HHS Will Extend Covid-19 PHE Through April 2023

Several news outlets have reported that the U.S. Health and Human Services Department (HHS) intends to extend the existing Covid-19 Public Health Emergency (PHE) through April 2023. The current PHE—which has been extended many times since 2020—is effective through Jan. 11, 2023.

FDA Announces Preliminary Assessment of Certain Naloxone Products for Over-the-Counter Use

The U.S. Food and Drug Administration (FDA) this week issued a Federal Register notice that includes the agency’s preliminary assessment that certain naloxone drug products—up to 4 milligrams (mg) nasal spray and up to 2 mg autoinjector for intramuscular (IM) or subcutaneous (SC) use—may be approvable as safe and effective for nonprescription use. In its announcement about the notice, FDA said this move is “intended to facilitate both the development and approval of nonprescription naloxone products; however, it is not a final determination that certain naloxone drug products are safe and effective for nonprescription use, and it does not mandate an immediately effective switch to nonprescription/over-the-counter (OTC) availability for naloxone.” The announcement also said the FDA needs additional data, such as product-specific data on the nonprescription user interface design, including packaging and labeling, before it makes its final determination.

CMS Releases Medicaid and CHIP Access Data Brief

The Centers for Medicare & Medicaid Services (CMS) this week released a data brief that includes a snapshot of selected metrics in three essential dimensions of Medicaid and Children’s Health Insurance (CHIP) access. Culling data from various sources, CMS developed the brief to show access to Medicaid and CHIP coverage, measured by enrollment and retention; access to services, with a focus on mental health conditions and substance use disorders; and perceived access, measured by beneficiary experiences in managed care.

SAMHSA’s GAINS Center to Host Webinar About Project ECHO and SUD on Nov. 21

The Substance Abuse and Mental Health Services Administration’s (SAMHSA) GAINS Center on Monday, Nov. 21 will host “Black Robes and White Coats: Using Project ECHO to Increase Judiciary Knowledge about Substance Use Disorder,” a webinar that will provide an overview of the pilot Project ECHO for the Judiciary. The purpose of Project ECHO for the Judiciary is for participating judges to learn about treatments for opioid disorder and develop a better understanding of substance use disorders to help inform their decisions in the courtroom. The webinar will begin at 2:30 p.m. ET on Monday. Click here to register.

FDA to Host Stakeholder Call About Naloxone Access on Nov. 28

The top leaders at FDA and SAMHSA will host a stakeholder call on Monday, Nov. 28 to discuss naloxone access and harm reduction. FDA Commissioner Robert Califf, M.D. and Marta Sokolowska, deputy center director for substance use and behavioral health in FDA’s Center for Drug Evaluation and Research, will lead the call, and SAMHSA Assistant Secretary for Mental Health and Substance Use Miriam Delphin-Rittmon, Ph.D. will participate. “Every person who experiences an opioid overdose, whether it is with prescribed medication or an illicit drug, should have access to naloxone,” FDA said in its announcement about the call. “Entities such as harm-reduction programs help save lives by making naloxone available in underserved communities,” it continued. “The agency intends to stand by these efforts by supporting their ability to acquire FDA-approved naloxone products, and we recently issued the guidance, Exemption and Exclusion from Certain Requirements of the Drug Supply Chain Security Act (DSCSA) for the Distribution of FDA-Approved Naloxone Products During the Opioid Public Health Emergency,” it said, adding that FDA recognizes this action alone is not enough and that there is more work to do. The hourlong Zoom call will begin at 2:30 p.m. ET. Click here to register.

Reminder: Please Submit Data to Enhance NABH’s Managed-Care Advocacy Efforts

Thank you to all members who have already submitted your data to NABH’s denial-of-care portal. Your data will help NABH highlight problems in the field related to health plan denials and timeliness. Several policymaking entities are interested in these data, which could support advocacy for expanded access to care. For new participants, please e-mail Emily Wilkins, NABH’s administrative coordinator, for support.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Demand for anxiety and depression treatment remains high for the third consecutive year, and 60% of practitioners report they no longer have openings for new patients, according to the American Psychological Association’s 2022 Covid19 Practitioner Impact Survey. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Releases Final Physician Fee Schedule and OPPS Rules for 2023 

Telehealth services authorized temporarily during the Covid-19 public health emergency (PHE) will extend through at least 2023 and for at least 151 days after the PHE ends, the Centers for Medicare & Medicaid Services (CMS) announced in the agency’s final 2023 Physician Fee Schedule (PFS) this week. CMS’ decision to extend the telehealth services benefit will allow for additional data collection to evaluate a possible permanent addition as a Medicare benefit. CMS issued the regulation on the same day it released the final Outpatient Prospective Payment System (OPPS) rule for next year. In that regulation, CMS implemented a 4.1% payment increase for outpatient facilities in 2023. Please read below for additional details about the final regulations. 2023 Physician Fee Schedule Final Rule: The PFS final rule directs CMS to implement an approximately 4.5-percent reduction—reflecting a decrease of $1.55— in the conversion factor, which the agency uses to calculate payments for physicians and the other clinicians paid under the PFS. CMS also updated the payment amount for the drug component of the opioid treatment bundle using the Producer Price Index (PPI) for Pharmaceuticals for Human Use and will do so annually to account for inflation. CMS will also modify the payment rate for the non-drug bundle to base the rate on a 45-minute –rather than a 30-minute—session, which better comports with OTP practices. Under the final rule, OTPs may also use audio-visual and audio-only telehealth for buprenorphine intake if the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Drug Enforcement Administration (DEA) grant permission. Also pending authorization from SAMHSA and DEA, OTPs may furnish periodic assessments via audio-only when video is not available for the duration of 2023. CMS also made final billing for mobile units in accordance with SAMHSA and DEA guidance. Locality adjustments will be applied and based on the location of the OTP hub. Meanwhile, the PFS final rule implements an exception to supervision requirements to allow marriage and family therapists, licensed professional counselors, addiction counselors, certified peer recovery specialists, and others to provide behavioral healthcare services while under general supervision, rather than “direct” supervision. This means practitioners now will be able to provide services without requiring that a physician or nurse practitioner be present on site. Responding to comments from the behavioral healthcare field, CMS also made final a new behavioral health integration service that a clinical psychologist or clinical social worker can perform when mental health services are the focal point of care integration, along with allowing a psychiatric diagnostic evaluation to initiate such integration services. CMS also made final several provisions related to accountable care organizations to grow participation in the program, incorporate recent lessons related to episode payment approaches, and advance equity among program participants. Outpatient Prospective Payment System Final Rule: Although the 4.1% payment increase for outpatient services is larger than CMS had proposed, NABH does not consider this payment update adequate to address the intense cost pressures—stemming from considerable increases in labor, supplies, equipment, drugs, and other expenses—that the association had highlighted. Regarding payments for 340B hospitals, the final OPPS rule ends the cuts that the U.S. Supreme Court found to be unlawful. Per the high court’s ruling, 340B payments in 2023 will return to pre-2018 levels: the average sale price plus 6% with an offsetting reduction to make the measure budget neutral, as required by law. The final rule falls short of reimbursing 340B payment cuts from previous years. NABH expects additional 340B rules from CMS by the summer of 2023. Both the PFS and OPPS final rules will take effect Jan. 1, 2023. NABH and Other Organizations Urge Federal Appropriators to Include Behavioral Health Funding in Continuing Resolution NABH and a dozen other behavioral health organizations on Friday send a letter to House and Senate appropriators requesting that federal lawmakers include appropriate funding levels for behavioral health treatment in the upcoming Continuing Resolution (CR) to keep the federal government operating. Specifically, NABH and the other organizations—including the American Psychiatric Association, the American Psychological Association, Mental Health America, the National Association of State Mental Health Program Directors— requested that Congress include $1.42 billion for the Community Mental Health Block Grant (MHGB), including a 10% set-aside for mental health crisis services within the MHGB; $60 million to expand the Mental Health Crisis Response Partnership Pilot Program; $747 million for the 988 behavioral health crisis hotline, including $30 million to provide specialized services for LGBTQ+ youth; $400 million for Certified Community Behavioral Health Clinics; and $10 million for the Behavioral Health Crisis 988 Coordinating Office. “Additional federal investments are needed to strengthen the 988 system to transform how our country responds to people in crisis,” the organizations wrote in the letter. “A continuing resolution of any length threatens our ability to meet the high and growing need for behavioral health treatment and care.”

SAMHSA to Host Webinar About CCBHC Certification Criteria Next Week

SAMHSA will host a webinar open to the public next Wednesday, Nov. 9 regarding updates to the Certified Community Behavioral Health Clinic (CCBHC) certification criteria. SAMHSA will provide a brief overview of CCBHCs, describe key elements of certification criteria and SAMHSA’s process for soliciting feedback from the field, and discuss how the public can provide feedback. The Zoom webinar will begin at 4 p.m. ET. The meeting ID is 160 306 8999 and the passcode is 160547.

SAMHSA Names Jennifer Fan as Director of Center for Substance Abuse Prevention

SAMHSA this week named Capt. Jennifer Fan, Pharm.D., J.D. as the acting director of the agency’s Center for Substance Abuse Prevention (CSAP). A commissioned officer in the U.S. Public Health Service, Fan served in SAMHSA from 2007 through 2021 in several roles, including acting CSAP deputy director, special assistant for the CSAP director, and CSAP’s subject matter expert on opioids and prescription drug misuse. She also served as the senior editor for the Surgeon General’s Spotlight on Opioids Report and helped to create SAMHSA’s Strategic Prevention Framework for Prescription Drugs (SPF Rx) grants and the Grants to Prevent Prescription Drug/Opioid Overdose-Related Deaths (PDO). Fan earned her doctorate in pharmacy from the University of Maryland School of Pharmacy and her law degree from the University of Baltimore School of Law.

SAMHSA Introduces ‘Screen 4 Success’ to Help Parents and Caregivers Understand Wellbeing of Children

SAMHSA recently announced Screen4Success, a new screening tool from the agency’s “Talk. They Hear You.” national prevention campaign that can help parents and caregivers better understand children’s health, wellness, and wellbeing, and find resources to address needs. Parents and caregivers can access the new tool on mobile devices through the Talk. They Hear You. campaign mobile app, which is available for free on the App Store, Google Play, and Microsoft store.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Fifty-three percent of those polled said the new 988 behavioral health crisis hotline will be effective to keep people in crisis out of jail, with Black (64%) and Hispanic (54%) adults more optimistic, the American Psychiatric Association reports. For questions or comments about this CEO Update, please contact Jessica Zigmond.

GAO Report Identifies Challenges and Opportunities to Recruit and Retain Behavioral Health Workforce

Financial, educational, and workplace challenges are three categories that pose the greatest challenges to recruiting and retaining behavioral health providers, the Government Accountability Office (GAO) concluded in a new report. The GAO was assigned to review what is known about the behavioral health workforce, offer information regarding both barriers to and incentives for recruiting and retaining providers, and identify what actions various U.S. Health and Human Services department (HHS) agencies are taking to recruit and retain these providers. In its comprehensive review, the GAO interviewed NABH staff as a stakeholder group. “Reimbursement rates and compensation for behavioral health services are low, according to stakeholders from multiple research organizations and behavioral health associations,” the report noted, adding that many programs designed to recruit diverse behavioral health providers only benefit individuals already studying in a behavioral health field and do not address the lack of a pipeline for underserved populations to enter the workforce. The GAO recommended that incentives such as loan repayment and scholarships for students seeking behavioral healthcare professions could help to address some of the barriers to entering the field. Learn more in highlights from the study and the full report.

HHS and U.S. Surgeon General’s Office to Host Mental Health Briefing Monday, Oct. 31

HHS and the U.S. Surgeon General’s office will host a briefing on Monday, Oct. 31 to discuss the Surgeon General’s Framework for Workplace Mental Health & Well-being, which will outline the foundational role that workplaces should play in promoting the health and well-being of workers and communities. The briefing will highlight the five essentials for workplace mental health and is intended to help organizations develop, institutionalize, and update policies, processes, and practices that best support the mental health and well-being of all workers. Click here to register for the 30-minute briefing, which will begin at 1:30 p.m. ET.

Commonwealth Fund Study Examines How Changing Opioid Addiction Treatment Delivery Could Reduce Death and Suffering

A new study from the Commonwealth Fund analyzes how government regulation and inadequate treatment capacity can limit patients’ access to lifesaving care and what policymakers could do to help combat opioid addiction. According to the report’s findings, opioids are involved in almost 75% of overdose deaths in the United States, which claim more than 100,000 lives per year. But while opioid addiction can be treated with effective medications, only 10% to 15% of U.S. residents with opioid use disorder receive them. “During Covid-19, the federal government showed flexibility by allowing OTPs (opioid treatment programs) to provide more take-home methadone doses, allowing buprenorphine treatment initiation via telehealth, and removing buprenorphine waiver training requirements for providers treating 30 or fewer patients,” the report noted. “Data indicate that methadone take-home flexibilities have not been associated with worse outcomes or significant misuse, and telehealth services have been associated with improved medication retention and lower overdose risk,” it continued. “Some of these provisions are temporary and could sunset or change after the COVID-19 public health emergency ends.”

CMS Administrator Brooks-LaSure to Host Webinar Next Week on CMS’ Strategic Plan

Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and her leadership team will provide an update on the agency’s strategic plan next Tuesday, Nov. 1. This is the agency’s fourth national stakeholder call with the administrator this year, and it’s intended to provide an opportunity for stakeholders to learn how they can partner with CMS to implement the agency’s strategic plan. The hourlong call will begin next Tuesday at 3 p.m. ET. Click here to register.

SAMHSA to Host Behavioral Health Services Information Virtual Workshop on Nov. 2

SAMHSA will host a virtual workshop next week to help providers learn how to access the agency’s available data on Behavioral Health Services Information System (BHSIS) and online treatment locator. Herman Alvarado, a supervisory social science analyst at SAMHSA’s Center for Behavioral Health Statistics and Quality, will provide an overview for participants. The event is intended to provide technical assistance to National Network to Eliminate in Behavioral Health (NNED) members and minority-service and under-resourced community-based organizations. The 90-minute virtual workshop will begin at 3 p.m. next Wednesday, Nov. 2. Click here to register.

NIH’s HEAL Initiative Highlights Examples of Successful Programs to Prevent and Treatment Opioid Misuse and Addiction

The National Institutes of Health’s (NIH) Helping to End Addiction Long-term, or HEAL, initiative— a trans-NIH research effort focused on improving prevention and treatment for opioid misuse and addiction and enhancing pain management—recently released examples of programs that have helped some of the youngest patients battling opioid misuse or addiction. HEAL funds more than 1,000 research projects in every U.S. state and is a $2.5 billion effort that has grown substantially this year, adding 10 new programs and more than 200 new projects that are seeking scientific solutions to prevent overdose and connect people to treatment for pain and addiction. Click here to learn about some innovative programs related to mobile apps.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal. Save the Date for the NABH 2023 Annual Meeting!  Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

By 2030, HHS’ Health Resources and Services Administration (HRSA) estimates a 20% decrease in the supply of adult psychiatrists to 27,020, while the agency estimates a 22% increase in the supply of child and adolescent psychiatrists to 9,830. For questions or comments about this CEO Update, please contact Jessica Zigmond.

MHA Releases ‘State of Mental Health in America’ Report for 2023

More than 50 million Americans experienced a mental illness between 2019 and 2020, while more than one in 10 youth in the United States experience depression that is severely impairing their ability to function at school or work, at home, with family, or in their social life, according to a new report from Mental Health America (MHA). The State of Mental Health in America is a nearly 40-page chartbook that provides a baseline to answer some questions about how many people in America need and have access to mental health services. The report is a companion piece to interactive data available on MHA’s website. Using publicly available data from the 50 states and Washington, D.C., MHA used a set of 15 measures, such as adults with any mental illness, adults with thoughts of suicide, and youth with substance use disorder in the last year. MHA noted that the Covid-19 pandemic negatively affected the ability to collect data for national surveillance in 2020; consequently, the indicators in this year’s report cannot be compared with previous years. The findings also reported that the majority of individuals with a substance use disorder in the U.S. are not receiving treatment, and that there are about 350 individuals for every one mental healthcare provider in the United States.

SAMHSA Announces $15 Million in Early 2023 for CCBHCs

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week announced it will award $15 million early next year to expand access to planning grants for certified community behavioral health clinics (CCBHCs) to all 50 states. This funding—along with the $300 million that SAMHSA awarded in September for both new and existing CCBHCs—comes from the Bipartisan Safer Communities Act that President Biden signed in June.

CMS Releases FAQs About Medicaid and CHIP Determinations and Renewals After PHE Ends

The Centers for Medicare & Medicaid Services on Oct. 17 answers to frequently asked questions about the agency’s March 2022 guidance to states regarding planning efforts to resume Medicaid and Children’s Health Insurance Program (CHIP) eligibility determinations and renewals after the Covid-19 public health emergency ends. The FAQs address the unwinding period, renewals and changes in circumstances, non-MAGI ex parte renewals, section 1902(e)(14)(A) waivers, premiums, fraud, and more.

New Reports Examine Telehealth Laws & Medicaid Policies and Trauma & Recovery for Youth

The Center for Connected Health Policy (CCHP) this week released its Fall 2022 summary of telehealth laws and Medicaid program policies, which allows users to export data for each state into a PDF document. CCHP provides bi-annual summary reports to provide a snapshot of the progress made in the past six months. Also this week, the National Child Traumatic Stress Network released A Trauma-Informed Guide for Working with Youth in Multiple Settings, which is intended for people who work with youth involved in multiple systems (YIMS) and their families to use a traumatic stress perspective and provide trauma-informed care. The report defines YIMS as children and adolescents who are under the care or supervision of multiple child and family-serving systems. They include “crossover youth” or “dually involved youth” who are involved in child welfare (CW) and in the juvenile justice (JJ) system. In addition to CW and JJ involvement, YIMS are also often simultaneously involved in an array of other service systems including immigration, legal, education, family services, physical and behavioral health systems and systems designed to serve those with developmental disabilities or who experience homelessness.

Register Today for Oct. 27 Webinar on CPT Coding and Billing Changes for Mental Health in 2023

The Association for Behavioral Health and Wellness, the American Psychological Association, and the American Psychiatric Association will host a webinar about what to expect in CPT coding and billing changes for mental health in 2023 on Thursday, Oct. 27. Stephen Gillaspy, Ph.D., senior director of health and healthcare financing at the American Psychological Association, will lead the presentation about the Centers for Medicare and Medicaid Services’ (CMS) proposed changes outlined in the agency’s 2023 physician fee schedule proposed rule. The webinar will focus on new CPT codes and changes to existing codes, expanding the outpatient Evaluation and Management (E/M) documentation guidelines to the facility setting, and other CMS proposals, such as “incident to” billing that, if implemented, will have a significant effect on mental and behavioral clinicians beginning Jan.  1, 2023. The hourlong webinar will begin at 12:30 p.m. ET. Click here to register.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

More seniors in 2022 (28%) than in 2021 (20%) said the cost of care affected their ability to seek treatment for a mental health condition, according to a survey of seniors that the Pan Foundation conducted in May 2022. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH 2023 Board Position Nominations Due Today!

The deadline to submit nominations for the 2023 NABH Board Chair-Elect and two available NABH Board seats is today, Friday, Oct. 14. The NABH Selection Committee is seeking senior managers who represent the association’s diverse membership related to levels of care, organizational structures, and size. Please download a nomination form to recommend individuals for the single-slate ballot in 2023. Also, please attach a curriculum vitae (CV) for every individual you recommend. This will help the Selection Committee in its deliberations. All NABH members are welcome to suggest themselves. Please return this form and candidates’ curricula vitae by Friday, Oct. 14, 2022, to maria@nabh.org.

Becerra Extends Covid-19 PHE for Another 90 Days

HHS Secretary Xavier Becerra on Thursday renewed the Covid-19 public health emergency (PHE) for an additional 90 days. Former HHS Secretary Alex Azar declared the Covid-19 PHE for the first time in January 2020 Since then, it has been renewed—either by Azar or Becerra— 10 times, making this week’s announcement the 11^th renewal.

Bipartisan Policy Center Recommends Extending Medicare Telehealth Benefits for Two Years Post Pandemic

Congress and the Biden administration should extend most of the Medicare program’s telehealth flexibilities for beneficiaries for two years after the Covid-19 pandemic ends and then evaluate the effects, the Bipartisan Policy Center (BPC) recommended in a report released this week. And that’s for a start. The report—totaling more than 80 pages—also concluded that researchers should evaluate the benefits of hybrid (both in-person and virtual) care models for primary and specialty care, including for which conditions and specialties it is most effective; further evaluate full telehealth flexibilities in the context of value-based payment models; and assess rigorously the quality of audio-only care. “Throughout this report, BPC recommends targeted adjustments to the current telehealth flexibilities; all recommended changes are in response to emerging evidence on benefits versus risks and to stakeholder concerns,” the researchers noted. “This approach would enable beneficiaries to maintain their access to telehealth services while minimizing risks to patients and the Medicare program, as well as provide time for policymakers to continue to review and assess the evidence.”

ONDCP to Host Webinar About Low-Threshold Buprenorphine on Monday, Oct. 17

The White Office of National Drug Control Policy (ONDCP) will host a webinar on Monday, Oct. 17 to examine low-threshold buprenorphine programs, which seek to reduce barriers that often limit access or reduce retention in care. ONDCP Director Rahul Gupta, M.D. will welcome participants to the webinar, which will feature evidence from experts in the field and include a panel discussion about policy and practice. The webinar will be held from 1 p.m. – 3 p.m. ET. Click here to register.

Register Today for Webinar on CPT Coding and Billing Changes for Mental Health in 2023

The Association for Behavioral Health and Wellness, the American Psychological Association, and the American Psychiatric Association will host a webinar about what to expect in CPT coding and billing changes for mental health in 2023 on Thursday, Oct. 27. Stephen Gillaspy, Ph.D., senior director of health and healthcare financing at the American Psychological Association, will lead the presentation about the Centers for Medicare and Medicaid Services’ (CMS) proposed changes outlined in the agency’s 2023 physician fee schedule proposed rule. The webinar will focus on new CPT codes and changes to existing codes, expanding the outpatient Evaluation and Management (E/M) documentation guidelines to the facility setting, and other CMS proposals, such as “incident to” billing that, if implemented, will have a significant effect on mental and behavioral clinicians beginning Jan.  1, 2023. The hourlong webinar will begin at 12:30 p.m. ET. Click here to register.

JAMA Pediatrics Examines Continued Rise of Unintentional Ingestion of Edible Cannabis in Toddlers

An analysis in JAMA Pediatrics this week concluded that immediate action should be taken to alter the current trajectory of unintentional pediatric ingestion of edible cannabis products. The article noted that cannabis is the third most used psychoactive substance worldwide, with use continuously rising in the U.S. adult population. Meanwhile, cannabis products are used commonly and stored in homes in which children are present and education from healthcare professionals about safe storage is lacking, the article continued. Consequently, children are at risk of being drawn to THC (tetrahydrocannabinol, the psychoactive compound of marijuana)-infused products that resemble their favorite snacks or candy. “Children with THC intoxication can present with neurologic impairment, including lethargy, ataxia, tachycardia, mydriasis, seizures, altered mental status, and hypotonia,” the article said. “However, given the unpredictability of the dose ingested, patient presentation can vary. Altered mental status in children results in broad differential diagnoses ranging from traumatic to infectious causes.”

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

A 2016 parent survey shows 64% of children with Attention Deficit/Hyperactivity Disorder (ADHD) had at least one other mental, emotional, or behavioral disorder, the Centers for Disease Control and Prevention reports. October is ADHD Awareness Month. Help the National Institute of Mental Health raise awareness by sharing these resources. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Seeking Candidates for 2023 Board Positions

The NABH Selection Committee is seeking nominations to fill the NABH Board Chair-Elect and two NABH Board seats that will become available in 2023. In particular, the committee wants to identify senior managers who represent the association’s diverse membership related to levels of care, organizational structures, and size. Please download a nomination form to recommend individuals for the single-slate ballot in 2023. Please attach a curriculum vitae (CV) for every individual you recommend. This will help the Selection Committee in its deliberations. All NABH members are welcome to suggest themselves. Please return this form and candidates’ curricula vitae by Friday, Oct. 14, 2022, to maria@nabh.org.

Harris Poll Shows Strong Public Support for Mental Health and Uncertainty on How to Help

Two in three U.S. adults say they believe they don’t have enough knowledge to tell if someone is considering suicide, while eight in 10 adults say they are open to learning how to help someone in need, according to a Harris Poll survey released this week. Since 2015, the American Foundation for Suicide Prevention (AFSP), the National Action Alliance for Suicide Prevention (Action Alliance), and the Suicide Prevention Resource Center (SPRC) have commissioned the Harris Poll to conduct bi-annual, nationally representative survey of adults in the United States to understand the public’s beliefs and attitudes about mental health and suicide. The survey evaluates what the public knows about to support someone who is struggling and their perceptions of barriers to help those at risk for suicide. This latest poll offers an early read on public awareness of 988, the national behavioral health crisis hotline that launched in July. Researchers found that while gains have been made in valuing mental health, there is not consistent societal support for mental healthcare. The findings show that 76% of Americans surveyed said they perceive mental health as equal to physical health, while 51% said they feel that physical health is treated as more important of the two. Meanwhile, 67% of those surveyed said they believe they have had a mental health condition at some point in their lives, up from 60% who said so in 2018 and 57% in 2018. “Overall, the poll indicates that progress has been made, but there is more to do,” the report noted. “We must continue to learn more about suicide and mental health particularly through increased research efforts, teach everyone how to help prevent suicide and strengthen mental health, and advocate for improved access to care and robust crisis services.”

ONDCP to Host Webinar About Low-Threshold Buprenorphine on Oct. 17

The White House Office of National Drug Control Policy (ONDCP) will host a webinar on Monday, Oct. 17 to examine low-threshold buprenorphine programs, which seek to reduce barriers that often limit access or reduce retention in care. ONDCP Director Rahul Gupta, M.D. will welcome participants to the webinar, which will feature evidence from experts in the field and include a panel discussion about policy and practice. The webinar will be held from 1 p.m. – 3 p.m. ET. Click here to register.

HRSA Previews Behavioral Health Training Opportunities for Primary Care Residents

The Health Resources and Services Administration (HRSA) this week announced a funding opportunity totaling nearly $60 million during a five-year period to support training to expand the public health workforce. The new program will train primary care residents in the prevention, identification, diagnosis, treatment, and referral of services for mental and behavioral health conditions. It is intended to benefit pediatric, adolescent, young adult, and other populations who are at-risk or have experienced abuse, trauma, or mental health and/or substance use disorders, including those related to the effects of gun violence. According to HRSA, awards will support both classroom training and clinical rotations that focus on mental and behavioral health conditions. Eligible entities include accredited public or not-for-profit private hospitals; schools of allopathic medicine or osteopathic medicine; residency programs accredited by the Accreditation Council for Graduate Medical Education in family medicine, general internal medicine, general pediatrics or combined internal medicine and pediatrics (“med-peds”); and tribes and tribal organizations, if otherwise eligible. Click here to be notified when this funding opportunity opens.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

A Harris Poll survey released this week found that more than half of adults in the United States say seeing a mental health professional is a sign of strength. For questions or comments about this CEO Update, please contact Jessica Zigmond.

House to Vote Friday on Senate-Approved Stopgap Spending Measure

The House of Representatives is expected to vote Friday on the short-term spending bill the Senate approved Thursday to avert a federal government shutdown and increase aid to Ukraine. Included in the legislation is a provision to continue funding the national 988 behavioral crisis hotline through Sept. 30, 2023, for which Congress has appropriated $62,000,000.

TODAY: SAMHSA to Moderate Recovery Month Panel at 1:15 p.m. ET

Acting Deputy Assistant Secretary Tom Coderre of the Substance Abuse and Mental Health Services Administration (SAMHSA) will moderate a panel discussion at 1:15 p.m. ET today, Friday, Sept. 30, the last day of National Recovery Month. Titled “Making Small Choices, Every Day,” the event will feature panelists who will discuss their recovery experiences while sharing success stories and providing hope that recovery is possible. The panel will address seeking treatment for mental illness or substance use disorders, overcoming challenges such as stigma, and helping the public understand the importance of helping those in recovery. SAMHSA will livestream the event on the agency’s Facebook page.

House Passes Bill to Bolster Mental Health Parity Protections for Workers

The House earlier this week passed the Mental Health Matters Act of 2022, a bill intended to hold employer-based health plans more accountable for inappropriate denials of mental health and substance use benefits. The legislation would give the U.S. Labor Department more authority to enforce plan requirements under the Mental Health Parity and Addiction Equity Act and the Employee Retirement Income Security Act. It also would ban forced arbitration agreements when plans deny benefits improperly, and ensure a fair standard of review from the courts. Before the bill passed, the White House released a Statement of Administrative Policy supporting the legislation. The White House noted that the Mental Health Matters Act also would improve the well-being of young children in Head Start and K-12 schools by building on President Biden’s efforts to increase the number of school-based mental health services providers, as well as authorizing grants to partnerships between high-need, local educational agencies, and institutions of higher education. NABH will continue to track developments related to this bill.

CMS Releases Latest Enrollment Figures for Medicare, Medicaid, and CHIP

The Centers for Medicare & Medicaid Services (CMS) this week released the agency’s latest enrollment figures for Medicare, Medicaid & the Children’s Health Insurance Program (CHIP), and the health insurance marketplaces, reporting that 156.5 million Americans have coverage in these federal health insurance programs. According to the latest figures, there are 89.4 million enrollees in Medicaid and CHIP, 64.6 million enrollees in Medicare, and 14.5 million people enrolled in state-based and federal health insurance marketplaces. The agency reported a subtotal figure of 168.5 million enrollees, which CMS then adjusted by subtracting 12 million to account for Americans who are dually eligible for both Medicare and Medicaid. Click here for a breakdown of the individual programs.

Former ONDCP Leaders Pen Opinion Piece on Increasing Recovery Services

On this last day of National Recovery Month, two former leaders at the White House Office of National Drug Control Policy wrote an opinion piece in The Hill newspaper to call for more training in addiction science and policymaking. In their blog, former ONDCP Director Michael Botticelli and Regina LaBelle, a former acting director at ONDCP and director of the Addiction and Public Policy Initiative at the Georgetown University Law Center’s O’Neill Institute, recognized the role that people in recovery play by building healthier communities. They also emphasized the need to remove barriers to healthcare, housing, and employment and education, including modifying the regulatory hurdles that reduce access to methadone.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Early intervention in psychosis programs contributed to, on average, 3.2 fewer hospitalizations and 2.7 more years employed during the course of patients’ lives compared with individuals with the same diagnosis who received standard care, according to a study published in Psychiatric Services. For questions or comments about this CEO Update, please contact Jessica Zigmond

Biden Administration Announces More Than $1.6 Billion for Communities to Address Addiction & Overdose Crises

The U.S. Health and Human Services Department (HHS) on Friday announced it will award more than $1.6 billion in investments to communities nationwide to address America’s addiction and overdose crises. Funding will come from the Substance Abuse and Mental Health Services Administration’s (SAMHSA) State Opioid Response (SOR) program and Tribal Opioid Response (TOR) grant program and the Health Resources and Services Administration’s (HRSA) rural communities’ opioid response programs.   “I have heard many stories of despair from individuals battling addiction and from families who have lost loved ones to overdose,” HHS Secretary Xavier Becerra said in the grant announcement. “Through these grants, we are investing in evidence-based supports and services for individuals, families, and communities on the road to recovery.” Click here to learn about the four individual grant opportunities.

Covid-19 PHE Will Likely Be Extended Due to Absence of 60-Day Termination Notice from HHS

The Covid-19 public health emergency (PHE) will most likely be extended for another 90 days after the PHE’s current Oct. 13, 2022 expiration date because HHS has not given states 60 days’ notice before termination. In January 2021, HHS’s Administration for Strategic Preparedness & Response (ASPR0 sent a letter to the nation’s governors outlining the commitment to a 60-day, PHE termination notice. HHS Assistant Secretary for Public Affairs Sarah Lovenheim posted a message on Twitter this past Monday, Sept. 19, that assured states and providers there will be at least two months’ notice before the PHE is allowed to expire. NABH will notify members about any updates related to the PHE’s end date.

National Center on Substance Abuse and Child Welfare to Host Sept. 27 Webinar on Contingency Management

SAMHSA announced this week that the National Center on Substance Abuse and Child Welfare will host a webinar on Thursday, Sept. 29 that highlights how contingency management can help families affected by substance use disorders. The webinar will provide an overview of contingency management, including details about implementation with different cultural populations. It will also show how Montefiore Medical Center in New York, a Regional Partnership Grant awardee, has implemented contingency management, and provide practical strategies for implementation. The webinar will begin next Thursday at 1:30 p.m. ET. Click here to register.

NIH-Led Study Shows Heart Medication Could Be Effective for Alcohol Use Disorder

A medication to treat heart problems and high blood pressure may also be effective for treating alcohol use disorder, according to a new study from researchers at the National Institutes of Health (NIH) and published in Molecular Psychiatry. The research shows evidence from experiments in mice and rats—as well as a cohort study in humans—that suggests the medication spironolactone could play a role in reducing alcohol drinking. Researchers from the NIH’s National Institute on Drug Abuse and the National Institute on Alcohol Abuse and Alcoholism, as well as from the Yale School of Medicine, produced the study. “Combining findings across three species and different types of research studies, and then seeing similarities in those data, gives us confidence that we are onto something potentially important scientifically and clinically,” Lorenzo Leggio, M.D., Ph.D., chief of the clinical psychoneuroendocrinology and neuropsychopharmacology section, a joint laboratory of NIDA and NIAAA, and one of the senior authors, said in an announcement about the research. “These findings support further study of spironolactone as a potential treatment for alcohol use disorder, a medical condition that affects millions of people in the U.S.”

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Prenatal cannabis exposure following the middle of the first trimester is associated with attention, social, and behavioral problems in children that persist into early adolescence, according to a recent study in JAMA Pediatrics based on research funded by the National Institute on Drug Abuse. For questions or comments about this CEO Update, please contact Jessica Zigmond.

NABH Annual Membership Updates Are Due Today, Sept. 16!

Today, Friday, Sept. 16, is the deadline for members to submit changes about their organizations for the online-only NABH 2022 Membership Directory. Last month NABH sent its system members a message with a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use this tool to verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all your system’s facilities so that we have a better picture of our diverse membership. If you need NABH to re-send the link, please contact Maria Merlie at maria@nabh.org. Thank you for your cooperation!

NABH Submits Comments on CMS’ Proposed Rule for Medicare Hospital Outpatient Prospective Payment System

NABH this week sent comments and recommendations to the Centers for Medicare & Medicaid Services (CMS) regarding the agency’s proposed Medicare Hospital Outpatient Prospective Payment System (OPPS) for calendar year 2023 (CY 2023). In its five-page letter, NABH proposed that CMS examine ways to account for increased costs to ensure that beneficiaries continue to have access to quality outpatient care and offered a range of recommendations, including: reducing the productivity cut for CY 2023; ensuring that non-340B hospitals remain unharmed; expanding telehealth services; and more.

CMS Announces Approval of Nation’s First Medicaid Mobile Crisis Intervention Services Program

The Centers for Medicare & Medicaid Services (CMS) this week announced approval of the Oregon Health Authority’s proposal to cover community-based stabilization services throughout the state. Oregon is the first state to seek and be granted approval for the new Medicaid option that became available to states in April 2022.  The program will provide community-based stabilization services to individuals experiencing mental health and/or substance use crises by connecting them to a behavioral health specialist 24 hours a day, every day of the year.

Sound the Alarm for Kids Virtual Roundtable is Today, Friday, Sept. 16 at 1 p.m. ET

Sound the Alarm for Kids will host “Helping Girls Thrive: A Conversation Examining Trends in Girls’ Mental Health” is today, Friday, Sept. 16 at 1 p.m. ET. The virtual roundtable discussion will examine the national campaign to raise awareness about today’s mental health crisis among children and teens and how to create change. Some of the speakers include Christina Bethell, Ph.D., M.P.H., M.B.A, director of the Child and Adolescent Health Measurement Initiative at Johns Hopkins University and Kelley Haynes-Mendez, Psy.D., senior director of the human rights team at the American Psychological Association. Click here to register.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Based on data from 14 state maternal mortality review committees, the Centers for Disease Control and Prevention (CDC) reports that mental health conditions—including suicide—are the 6th leading cause of pregnancy-related death. For questions or comments about this CEO Update, please contact Jessica Zigmond

NABH Welcomes Rochelle Archuleta as Executive Vice President for Government Relations and Public Policy

Rochelle Archuleta has joined NABH as executive vice president for government relations and public policy, effective Sept. 6. Rochelle brings to NABH 30 years of experience in the health policy, healthcare delivery system, and legislative arenas. During her 20-year tenure as a policy director for the American Hospital Association (AHA), Rochelle led AHA’s post-acute care policy team. In this role, Rochelle partnered with providers, policymakers, and leading trade associations on issues pertaining to the home health, skilled nursing facility/nursing home, inpatient rehabilitation facility, and long-term care hospital sectors. These advocacy efforts expanded to include issues of common concern to all post-acute care providers and their hospital partners, including issues pertaining to Medicare Advantage and commercial insurers, as well as the Medicare program’s effort to create a new, unified payment system to reimburse the aforementioned, post-acute care settings. “We are pleased to welcome Rochelle to our team,” said Shawn Coughlin, president and CEO at NABH. “Rochelle’s extensive work in healthcare policy, as well as her strong relationships with partner associations, will enhance NABH’s advocacy efforts—both with legislators and regulators.” Rochelle is a research fellow in the Georgetown University McCourt School of Public Policy and is a former David Winston Health Policy Fellow. She earned a master of science in health administration and a master of business administration from the University of Alabama at Birmingham School of Health Professions and a bachelor of arts in political science from the University of Colorado at Boulder.

NABH Submits Comments on CMS’ Proposed Medicare Physician Fee Schedule for 2023

NABH this week sent comments and recommendations to the Centers for Medicare & Medicaid Services (CMS) regarding the agency’s proposed Medicare physician fee schedule for fiscal year 2023. In its nine-page letter, NABH proposed revisions to the “Incident to” regulations and offered a range of recommendations related to the 2023 conversion factor, telehealth, opioid treatment services, coding and payment mechanisms, adjustments to the rate-setting methodology for behavioral health, and more.

HHS-OIG Report Shows Medicare Telehealth Fraud Was Rare During Covid-19 Pandemic

A new report from HHS’ Office of Inspector General (OIG) found a very small fraction of provider claims for Medicare telehealth services during the Covid-19 pandemic may have indicated fraud, waste, or abuse of those services.   The OIG’s offices analyzed Medicare fee-for-service claims data and Medicare Advantage encounter data from March 1, 2020 to Feb. 28, 2021 and focused on about 742,000 providers who billed for a telehealth services. Examining seven measures on different types of billing, investigators identified 1,1714 providers whose billing for telehealth services during the first year of the pandemic posed a high risk to the Medicare program. Those providers billed for telehealth for about half a million beneficiaries and received a total of about $127.7 million in Medicare fee-for-service payments, according to the report.   “Each of these 1,714 providers had concerning billing on at least 1 of 7 measures we developed that may indicate fraud, waste, or abuse of telehealth services,” the report noted. “All of these providers warrant further scrutiny. For example, they may be billing for telehealth services that are not medically necessary or were never provided.”

NABH Annual Membership Updates Are Due Next Friday, Sept. 16!

Next Friday, Sept. 16 is the deadline for members to submit changes about their organizations for the online-only NABH 2022 Membership Directory. Last month NABH sent its system members a message with a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use this tool to verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all your system’s facilities so that we have a better picture of our diverse membership. If you need NABH to re-send the link, please contact Maria Merlie at maria@nabh.org. Thank you for your cooperation!

Sound the Alarm for Kids to Host Virtual Roundtable on Friday, Sept. 16

Sound the Alarm for Kids will host “Helping Girls Thrive: A Conversation Examining Trends in Girls’ Mental Health” next Friday, Sept. 16 at 1 p.m. ET. The virtual roundtable discussion will examine the national campaign to raise awareness about today’s mental health crisis among children and teens and how to create change. Some of the speakers include Christina Bethell, Ph.D., M.P.H., M.B.A, director of the Child and Adolescent Health Measurement Initiative at Johns Hopkins University and Kelley Haynes-Mendez, Psy.D., senior director of the human rights team at the American Psychological Association. Click here to register.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

A recent study of 175,778 Medicare beneficiaries found that receipt of opioid use disorder-related telehealth services during the Covid-19 pandemic was associated with improved medications for opioid use disorder (MOUD) retention and lower odds of medically treated overdose, JAMA Psychiatry reports. For questions or comments about this CEO Update, please contact Jessica Zigmond.

September is National Recovery Awareness Month

This week kicked off National Recovery Month, a national observance every September since 1989 intended to promote and support new evidence-based treatment and recovery practices, the nation’s recovery community, and the dedication of service providers and community leaders who make recovery possible. During this past week’s Overdose Awareness Week, which concludes tomorrow, President Biden issued a National Recovery Month proclamation in which he acknowledged the more than 20 million Americans recovering from substance use disorder and highlighted his administration’s efforts to support recovery. “This year, we secured nearly $22 billion from the Congress to support drug prevention, treatment, harm reduction, and recovery support services, with a focus on underserved communities,” the president said in his proclamation. “With the additional $4 billion investment from our American Rescue Plan, my administration is expanding recovery community organizations, recovery high schools, collegiate recovery programs, and recovery residences.” For more information about National Recovery Month, please visit the Substance Abuse and Mental Health Administration’s (SAMHSA) website, and please remember to follow NABH @NABHbehavioral and on LinkedIn at the National Association for Behavioral Healthcare. HHS Announces $47.6 Million in New Grant Funding for School-Based Mental Health The U.S. Health and Human Services Department (HHS) this week announced $47.6 million in new grant funding opportunities through this Bipartisan Safer Communities Act to support mental health programs in schools. Of that amount, $37.6 million is allocated for Project Advancing Wellness and Resiliency in Education, or AWARE, which is meant to develop a sustainable infrastructure for school-based mental health programs and services that promote the healthy social and emotional development of school-aged youth and prevent youth violence in schools. The remaining $10 million is for the Resiliency in Communities after Stress and Trauma (ReCast) grant program, which helps assist high-risk youth and families by promoting resilience and equity in communities that have recently experienced civil unrest, community violence, and/or collective trauma through evidence-based, violence prevention, and community youth engagement programs, as well as connections to trauma-informed behavioral health services.

Nonfatal Opioid-Involved Overdoses in Emergency Departments Are Rising

The rate of nonfatal, opioid-involved overdose emergency medical services (EMS) encounters increased by an average of 4% quarterly from January 2018 – March 2022, according to new research from the Centers for Disease Control and Prevention (CDC). The findings also reported that rates increased across most sociodemographic and county characteristics. Researchers noted that monitoring nonfatal, opioid-involved overdose trends in EMS data in near real time can help identify where overdose affects communities disproportionately and direct equitable response and prevention efforts, such as increased access to harm-reduction services and connections to care and treatment. Click here to read the full CDC report.

Reminder: HRSA Announces Funding for 2023 Rural Health Network Development Program

Both not-for-profit and for-profit organizations are eligible to apply for the Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy’s (FORHP) 2023 Rural Health Development Program, a four-year program to support integrated healthcare networks to improve outcomes and strengthen the nation’s rural healthcare system. The FORHP will make 44 awards of up to $300,000 each as part of the program, which focuses on four domains: improving access by addressing gaps in care, workforce shortages, better workflows and/or improving the quality of healthcare services; expanding capacity and services by creating effective systems through the development of knowledge, skills, structures, and leadership models; enhancing outcomes by improving patient and/or network development outcomes through expanding or strengthening the network’s services, activities or interventions; and establishing sustainability by positioning the network to prepare for sustainable health programs through value-based care and population health management. FORHP will hold a webinar for applicants on Wednesday, Sept. 7, 2022 from 2 p.m. to 3:30 P.M. ET. Click here for more information about the grants and here for next month’s webinar link.

NABH Submits Medicare Advantage Program Recommendations to CMS

NABH this week responded to a request for information from the Centers for Medicare & Medicaid Services (CMS) about the Medicare Advantage (MA) program and behavioral health. In its letter, NABH cited a recent study that found MA networks included only 23% of psychiatrists in a county on average — lower than all other medical specialties. “Not surprisingly, MA enrollees with depressive symptoms report more difficulty accessing needed treatment and rated their experience with the MA plans as worse than in traditional Medicare,” the letter said. The association provided information and outlined recommendations related to advancing health equity, expanding access, encouraging innovation to promote patient-centered care, and engaging partners.

Extended Deadline: NABH Annual Membership Updates Are Due Friday, Sept. 16

NABH has extended the deadline to Friday, Sept. 16 for members to submit changes about their organizations for the online-only NABH 2022 Membership Directory. Last month NABH sent its system members a message with a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use this tool to verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all your system’s facilities so that we have a better picture of our diverse membership. If you need NABH to re-send the link, please contact Maria Merlie at maria@nabh.org. Thank you for your cooperation!

Enhanced NABH Denial-of-Care Portal is Now Available 

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Since October, the use of hashtags related to self-harm – such as “#shtwt, short for Self-Harm Twitter – has increased roughly 500%, averaging tens of thousands of mentions per month, according to a new study from the Network Contagion Research Institute and Rutgers University. For questions or comments about this CEO Update, please contact Jessica Zigmond

Extended Deadline: NABH Annual Membership Updates Are Due Friday, Sept. 16

NABH has extended the deadline to Friday, Sept. 16 for members to submit changes about their organizations for the online-only NABH 2022 Membership Directory. Last month NABH sent its system members a message with a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use this tool to verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all your system’s facilities so that we have a better picture of our diverse membership. If you need NABH to re-send the link, please contact Maria Merlie at maria@nabh.org. Thank you for your cooperation!

NABH and Partner Groups Ask HHS Secretary Becerra to Integrate Mental and Physical Health Within ASPR

NABH and more than 50 other advocacy organizations this week sent a letter to U.S. Health and Human Services Department (HHS) Secretary Becerra that urged the Biden administration to integrate mental and physical health within the Administration for Strategic Preparedness and Response (ASPR). Last month HHS announced that Becerra had elevated the then-existing Office of the Assistant Secretary for Preparedness and Response from a staff division to an operating division—taking the new name of the Administration for Strategic Preparedness and Response—in an effort to elevate ASPR to a standalone agency with the department, similar to the Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA), and Substance Abuse and Mental Health Services Administration (SAMHSA). HHS’ announcement said the change would allow ASPR to mobilize a coordinated national response more effectively and efficiently during future disasters and emergencies. This week, NABH was one of many organizations that called on HHS to use this opportunity to integrate mental and physical health when forming a national response to such events. “Therefore, with the elevation of ASPR within HHS, the Biden administration must seize this important opportunity to integrate our mental and physical health response in order to truly ensure ASPR is able to fulfill its mission to prepare and respond to health crises,” the organizations wrote in their letter to Becerra. “Needed steps include having senior positions within ASPR dedicated to ensuring the integration of mental health and substance use into all of ASPR’s work, as well as broader staff training to ensure personnel have sufficient background on why mental health is so important to emergency preparedness and response.” Click here to read the entire letter.

CEO Alliance for Mental Health Releases Updated Unified Vision for Transforming Mental Health and Substance Use Car

The CEO Alliance for Mental Health—of which NABH is a member organization— this week released an update Unified Vision for Transforming Mental Health and Substance Use Care for 2022. Please read the updated vision, which includes information related to the national 988 behavioral health crisis line that launched last month. Also, please remember to follow us @NABHbehavioral and on LinkedIn at the National Association for Behavioral Healthcare to share our posts about the vision.

HRSA Announces Funding for 2023 Rural Health Network Development Program

Both not-for-profit and for-profit organizations are eligible to apply for the Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy’s (FORHP) 2023 Rural Health Development Program, a four-year program to support integrated healthcare networks to improve outcomes and strengthen the nation’s rural healthcare system. The FORHP will make 44 awards of up to $300,000 each as part of the program, which focuses on four domains: improving access by addressing gaps in care, workforce shortages, better workflows and/or improving the quality of healthcare services; expanding capacity and services by creating effective systems through the development of knowledge, skills, structures, and leadership models; enhancing outcomes by improving patient and/or network development outcomes through expanding or strengthening the network’s services, activities or interventions; and establishing sustainability by positioning the network to prepare for sustainable health programs through value-based care and population health management. FORHP will hold a webinar for applicants on Wednesday, Sept. 7, 2022 from 2 p.m. to 3:30 P.M. ET. Click here for more information about the grants and here for next month’s webinar link.

Coalition on Physician Education in Substance Use Disorders Extends Submission Deadline for Curriculum Innovation Challenge

The Coalition on Physician Education in Substance Use Disorders (COPE), a partner organization to the Opioid Response Network, has extended the deadline for its Innovative Learning and Teaching About Substance Use/Opioid Use Disorders Curriculum Innovation Challenge to next Wednesday, Aug. 31 at 11:59 p.m. ET. The challenge is intended to support teams of medical school faculty and students in integrating addiction medicine/psychiatry content into core clerkship rotations. It is designed to foster engagement and collaboration between addiction medicine experts, medical school faculty (clerkship directors or the equivalent), and medical students using cutting-edge concepts and training tools. Through a series of virtual conferences, winning teams will be led in developing addiction medicine/psychiatry curriculum and planning subsequent implementation based on the needs of their school. Click here to learn more and apply.

Marijuana and Hallucinogen Use Among Young Adults Reached All-Time High in 2021

Marijuana and hallucinogen use reported by young adults 19 to 30 years old increased significantly in 2021 compared with five and 10 years ago, reaching historic highs in this age group since 1988, according to statistics released this week from the National Institute on Drug Abuse. The findings came from the Monitoring the Future panel study, which also reported that rates of past-month nicotine vaping, which have been gradually increasing in young adults for the past four years, also continued a general upward trend in 2021, despite leveling off in 2020. Past-month marijuana vaping, which had significantly decreased in 2020, rebounded to pre-pandemic levels in 2021. Click here to learn more.

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

About 6% of behavioral health providers and 29% of substance use treatment centers use electronic health record (EHR) technology, compared with more than 80% of hospitals that use EHRs, according to the Medicaid and CHIP Advisory Committee’s June report to Congress (see p. 84). For questions or comments about this CEO Update, please contact Jessica Zigmond

CMS Releases ‘Roadmap’ for Providers to Prepare for End of Covid-19 PHE

The Centers for Medicare & Medicaid Services this week released a series of fact sheets and resources to help the nation’s healthcare providers prepare for the end of the Covid-19 public health emergency (PHE), which will also end many of the flexibilities the agency offered during the global pandemic. A blog post from three CMS leaders noted that the agency learned from providers, facilities, insurers, and other stakeholders about what worked well—and didn’t—in relation to the agency’s waivers and other temporary measures. “Expanding telehealth is an example of a congressional change,” said the blog post from Jonathan Blum, CMS’ chief operating officer and principal deputy administrator; Carol Blackford, director of the agency’s hospital and ambulatory policy group; and Jean Moody-Williams, deputy director of the Center for Clinical Standards and Quality. “The Consolidated Appropriations Act, 2021 expanded access to telehealth services for the diagnosis, evaluation, or treatment of mental health disorders after the end of the PHE,” the authors continued. “These services have been so important to the health and well-being of Americans affected by Covid-19.” The post also noted that U.S. Health and Human Services Department (HHS) Secretary Xavier Becerra will give the healthcare community 60 days’ notice before the PHE ends. Providers can refer to a host of fact sheets and resources from CMS in links at the end of the blog post to help prepare as the PHE winds down.

CMS Rule Proposes Requiring Behavioral Health Quality Data Reporting

CMS on Thursday released a proposed rule that would require annual state reporting for three quality measure sets, including the behavioral health measures in the Core Set of Adult Health Care Quality Measures for Medicaid. The Behavioral Health Core Set includes 13 measures: a depression measure under the Primary Care Access and Preventive Care domain; four measures related to individuals with substance use disorders including one related to medication assisted treatment; two related to the prescribing of opioids; and six measures related to individuals with mental disorders. These core sets are designed to measure the overall national quality of care for beneficiaries, monitor performance at the state level, improve the quality of health care, and provide a national view of quality. CMS has proposed that reporting these measures—currently a voluntary practice—become mandatory in fiscal year 2024. Data reported in 2024 will reflect care delivered in calendar year 2023. “The Medicaid and CHIP Core Sets of quality measures for children, adults, and health home services are key to promoting health equity,” CMS Administrator Chiquita Brooks-LaSure said in an announcement. “They will allow us not only to identify health disparities but also to implement interventions based on the very data that make those disparities clear.” In addition to the Child and Adult Core Sets, CMS has proposed establishing reporting requirements for states that elect to implement one or both of the optional Medicaid health home benefits under sections 1945 or 1945A of the Social Security Act, which will measure healthcare quality for states that choose to establish “health homes.” Public comments about the proposed rule are due Oct. 21, 2022. The rule will be published in the Federal Register on Monday, Aug. 22.

New JAMA Study Shows Pervasiveness of Methamphetamine Use in Rural America

Findings from a JAMA Network Open study released this week show that nearly four of five people taking drugs in rural areas across 10 states used methamphetamine in the past 30 days. Meanwhile, non-fatal overdoses in the past six months were higher among people using both methamphetamines and opioids (22%), compared with opioids alone (14%), or methamphetamines alone (6%). “The challenge is compounded in rural communities that often lack buprenorphine prescribers: more than one-half of U.S. counties (53.4%) do not have a buprenorphine prescriber, leaving 30 million people in those counties without access to treatment,” the researchers wrote. “Similarly, rural opioid treatment programs are rare, leading to long driving times to access methadone,” they continued, adding that educational interventions are needed to train primary care physicians, who are essential providers of opioid use disorder treatment in rural America. “For example,” they wrote, “contingency management training interventions could be adapted to support rural primary care practitioners.”

NABH Annual Membership Updates Are Due Today

The deadline to submit changes about your organization for the online-only NABH 2022 Membership Directory is today, Friday, Aug. 19. Last month NABH sent its system members a message with a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use this tool to verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all your system’s facilities so that we have a better picture of our diverse membership. If you need assistance, please contact Maria Merlie at maria@nabh.org. Thank you!

Enhanced NABH Denial-of-Care Portal is Now Available

NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

A new study in The Lancet Psychiatry shows that up to two years after Covid-19 infection, the risk of developing conditions such as psychosis, dementia, brain fog, and seizures is still higher than after other respiratory infections; however, the findings also showed that while anxiety and depression are more common soon after a Covid-19 diagnosis, the mood orders are transient, becoming no more likely after the two months than following similar infections, such as the flu. To learn more, read this story in STAT. For questions or comments about this CEO Update, please contact Jessica Zigmond

Final 2023 IPF-PPS Rule Calls for 2.5% Payment Increase to IPFs in 2023

In a final rule released Thursday, the Centers for Medicare & Medicaid Services (CMS) said total estimated payments to inpatient psychiatric facilities (IPFs) are estimated to increase by 2.5%, or $90 million, in fiscal year 2023 relative to IPF payments in 2022. This is larger than the 1.5% payment increase the agency proposed this spring. For 2023, CMS is updating the IPF prospective payment system (PPS) rates by 3.8%, based on the final IPF market basket update of 4.1% minus a 0.3 percentage point productivity adjustment. CMS is also updating the outlier threshold so that estimated outlier payments remain at 2% of total payments. The agency estimates this will result in a 1.2% decrease to aggregate payments, due to updating the outlier threshold. CMS noted that due to rounding, the 3.8% increase to payment rates and the 1.2% decrease to outlier payments yield a 2.5% overall increase in IPF payments. A fact sheet from CMS highlights the final rule’s major provisions, including a permanent 5% cap policy to ease the impact of year-to-year changes in IPF payments related to decreases in the IPF wage index. Finally, CMS did not make final any changes for the IPF Quality Reporting Program in the 2023 final rule. Gov. Phil Murphy Announces ‘Strengthening Youth Mental Health Care’ as NGA Chair’s Initiative Incoming National Governors Association (NGA) Chair Gov. Phil Murphy (D-N.J.) announced “Strengthening Youth Mental Health Care” is his chair’s initiative as he leads the organization from 2022-2023. “We are all aware of the youth mental health crisis in our country,” Murphy said during the closing session of the NGA’s summer meeting in Portland, Maine. “It is a crisis that the pandemic did not create but exposed more fully,” he added. “It is one that we must tackle together, and tackle now.” Murphy also acknowledged access-to-care problems and highlighted the four pillars of his chair’s initiative: prevention and resilience building; increasing awareness and reducing stigma; access and affordability of quality treatment and care; and caregiver and educator training and support. Click here to read more about Murphy’s initiative. Opioid Response Network & National Association of Counties Offer Guidance on Managing Opioid Litigation Funds    The Opioid Response Network (ORN) and the National Association of Counties (NACo) have partnered to strengthen the association’s new Opioid Solutions Initiative and resource center, which offers guidance to U.S. counties about how to use funding from litigation between states and opioid manufacturers and distributors. The support center provides guidance on managing opioid litigation funds, information about effective substance use prevention, treatment and recovery approaches that are approved uses of settlement funds, case studies on evidence-based practices, and  — with help from the ORN — free, on-demand education and training. Click here to read more about NACo’s Opioid Solutions Center and click here to submit requests for free education and training. NABH Annual Membership Update: 2022 Membership Directory NABH is developing its online-only 2022 Membership Directory, an essential member benefit that helps the asssociation in its advocacy efforts. Earlier this week, NABH sent its system members a separate message that includes a link to the association’s membership-update tool. To help ensure we have the most accurate information on our members, please use the link to our membership-update tool and verify your system’s information. NABH has added several new categories this year. The answers to these questions will help us provide a more accurate description of our diverse membership to policymakers, regulators, partner organizations, and the media. Please be sure to enter information for all of your system’s facilities so that we have a better picture of our diverse membership. The deadline to submit your changes to NABH is Friday, Aug. 19, 2022. If you need assistance, please contact Maria Merlie at maria@nabh.org. Thank you! Enhanced NABH Denial-of-Care Portal is Now Available! NABH recently made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. “We know the best way to advocate for parity enforcement with regulators is to provide hard data from our members that show how insurers are not complying with the landmark 2008 parity law,” said NABH President and CEO Shawn Coughlin. “We hope these new changes will make it easier—and faster—for our members to use so that we can gather that critical data.” Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal. Save the Date for the NABH 2023 Annual Meeting! Please mark your calendars and plan to join us in Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting! Fact of the Week Calls to the new, national 988 behavioral health crisis hotline increased by 45% during the week after it transitioned to a three-digit number from a longer one. For questions or comments about this CEO Update, please contact Jessica Zigmond

ONDCP Director Identifies Gaps and Proposes Better System for Tracking Nonfatal Overdoses

In a recent JAMA commentary, the head of the White House Office of National Drug Control Policy (ONDCP) said the lack of real-time data for both fatal and nonfatal drug overdoses in the United States undermines the ability to respond accountably and restricts the potential to understand the effects of actions and investments. ONDCP Director Rahul Gupta, M.D., M.B.A., M.P.H., and David Holtgrave, Ph.D., also of ONDCP, argued that it’s essential to build the national data system while taking actions to prevent overdoses and save lives in the near term. “Once established, this national system should rapidly yield higher-quality, more complete, more timely, and more actionable data to inform increasingly effective policy making to prevent and treat overdose occurrences and build health equity,” the authors wrote. “Doing so will require the partnership of many, but there is not a moment to lose.”

Uniform Law Commission Agrees to Propose a Bill to State Legislatures That to Create More Consistency in Telehealth Laws

Politico reported this week that the influential Uniform Law Commission agreed to propose legislation to state legislatures that would try to create more consistency in telehealth laws and expand access to care across state lines. The commission nearly unanimously approved the model legislation after two years of deliberations and guidance from the American Medical Association, Federal Trade Commission, state medical boards, and telehealth groups. “It’s unclear how many states will move to create new laws around telehealth — or use the Uniform Law Commission’s model — but legislatures have embraced past proposals on issues ranging from regulation of organ donation to taxation of people who work in multiple states,” the story noted.

HRSA Payment Program for Rural Health Clinic Buprenorphine-Trained Providers Still Open

The nation’s rural health clinics (RHCs) still have an opportunity to apply for funding from the Health Resources and Services Administration’s (HRSA) program that pays providers who are waivered to prescribe buprenorphine, a medication used to treat opioid use disorder. Launched in 2021, HRSA’s program has about $1.2 million in program funding still available, and RHCs may apply for a $3,000 payment on behalf of each provider who trained to obtain the necessary waiver. HRSA said funds will be paid on a first-come, first-served basis until funds are exhausted. Please direct any questions to DATA2000WaiverPayments@hrsa.gov. In addition, the American Osteopathic Academy of Addiction Medicine and the Providers Clinical Support System are offering a free online course for waiver-eligibility training. Click here for more information.

Enhanced NABH Denial-of-Care Portal is Now Available!

NABH has made enhancements to its Denial-of-Care Portal that are intended to make the portal easier for members to use. A year ago, NABH developed the Denial-of-Care Portal to collect specific data on insurers who deny care—often without regard to parity or the effects on patients. Now the association has updated this resource to make it more user-friendly for members and also more aligned with what regulators need to identify parity violations. The updated portal includes fewer questions, which will require less time for members to complete. In addition, all questions are now optional. NABH hopes this will make it more likely for members to share the data they have. Lastly, NABH has added a checklist of “red flags” that were included in the 2022 MHPAEA Report to Congress from the U.S. Health and Human Services, Labor, and Treasury Departments in January. “We know the best way to advocate for parity enforcement with regulators is to provide hard data from our members that show how insurers are not complying with the landmark 2008 parity law,” said NABH President and CEO Shawn Coughlin. “We hope these new changes will make it easier—and faster—for our members to use so that we can gather that critical data.” Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Save the Date for the NABH 2023 Annual Meeting!

Please mark your calendars and plan to join us at the Mandarin Oriental Washington, DC from June 12-14, 2023 for next year’s NABH Annual Meeting!

Fact of the Week

Sixty-four percent of dual-eligible beneficiaries have a mental health diagnosis, according to a recent profile from research firm. ATI Advisory. For questions or comments about this CEO Update, please contact Jessica Zigmond

CMS Proposes to Modernize Coverage for Behavioral Health Services in 2023 Physician Fee Schedule Rule

The Centers for Medicare & Medicaid Services (CMS) on Thursday proposed new policies to update coverage for behavioral health services in the agency’s physician fee schedule proposed rule for 2023. In the rule, CMS proposes to address the behavioral healthcare workforce shortage by allowing licensed professional counselors (LPCs), marriage and family therapists (LMFTs), and other types of behavioral health practitioners to provide behavioral health services under general, rather than direct, supervision. CMS also proposes to pay for clinical psychologists and licensed clinical social workers to provide integrated behavioral health services as part of a patient’s primary care team. In addition, the rule proposes to bundle certain chronic pain management and treatment services into new monthly payments to help improve patient access to team-based, comprehensive, chronic pain treatment. And the agency is proposing to cover opioid treatment and recovery services from mobile units, such as vans, to increase access to services for people who are homeless or live in rural areas. Meena Seshamani, M.D., Ph.D., director for the Center for Medicare at CMS, and Douglas Jacobs, M.D., M.P.H., chief transformation officer at the Center for Medicare, co-authored a blog post Thursday about the behavioral health changes in the proposed rule.

Federal Health Officials Recommend ‘Preaddiction’ to Treat SUDs

Directors at the National Institutes of Health and the founder of the Treatment Research Institute this week recommended that the DSM-5 diagnostic categories “mild to moderate SUD” be a starting definition for the term preaddiction, a term they said could generate greater attention to the risks associated with early state substance use disorder (SUD) and help direct policies and resources to support preventive and early intervention measures. Nora Volkow, M.D., director of the National Institute on Drug Abuse, George Koob, Ph.D., director of the National Institute on Alcohol and Abuse and Alcoholism, and Tom McClellan, founder of the Treatment Institute wrote a commentary in JAMA Psychiatry this week that pushed for using the term preaddiction and highlighted lessons learned from Type 2 Diabetes and the role of “prediabetes” in their argument. As the authors explained, the American Diabetes Association in 2001 suggested the term prediabetes (defined by elevated scores on two laboratory tests: impaired glucose tolerance and impaired fasting glucose) to leverage public motivation to avoid serious diabetes. “Intervening early is not a new concept, nor is it easy to implement,” the authors wrote. “The diabetes field likely succeeded owing to a broad, well-organized, and sustained strategy applied concurrently at the clinical, public, and policy levels,” they said, adding that if an analogous approach is to be effective in the SUD field, it will require similarly integrated efforts in three areas: measures to define and detect preaddiction; engaging, effective interventions for preaddiction; and public and clinical advocacy. “The diabetes example illustrates why a similar strategy has not yet happened in the SUD field: poor integration into the rest of mainstream healthcare, lack of a prominent advocacy group demanding clinical and policy changes, and little reimbursement for interventions with less severe SUDs,” the authors noted. “Nonetheless, the diabetes example shows that an early intervention approach can work given a comprehensive, sustained effort. That example also suggests the potential impact from a parallel strategy to reduce addiction problems by more aggressive efforts to identify and reverse preaddiction.” Volkow discussed the issue further in her blog on July 6.

HUD Announces $365 Million Package to Address Unsheltered Homelessness and Homeless Encampments

The U.S. Housing and Urban Development Department (HUD) recently announced $322 million for permanent housing, supportive services, and other costs, and $43 million to fund about 4,000 new incremental housing choice vouchers. The Initiative for Unsheltered and Rural Homelessness through HUD promotes partnerships with healthcare organizations, public housing authorities and mainstream housing providers, and people with lived experience and expertise of homelessness. “President Biden is following through on his promise to unite our country by delivering funding for healthcare and services that support individuals who are unhoused,” Rahul Gupta, M.D., director of the White House Office of National Drug Control Policy, said in an announcement. “As a physician I have seen firsthand how important it is to address the social and economic conditions of a person’s life in order for them to realize the health and well-being every American deserves.” Click here to learn more in the full HUD announcement.

SAMHSA Releases Advisory on Peer Supports Services in Crisis Care

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released an advisory that discusses the role of peer support workers and models that are available to help individuals in crisis. The 17-page resource includes information about the evidence base for peer support services in crisis care, what peer support workers should do, how the recovery process looks different for everyone, and more.

Reminder: National Academies’ Forum on Mental Health and SUD to Host Workshop Next Week

The National Academies’ Forum on Mental Health and Substance Use Disorders will host a public workshop that focuses on early intervention for psychosis, current data on the epidemiology and outcomes for people at high risk for psychosis and those who have experienced a first psychosis, and ways to improve care for these patients. Sessions will provide an overview of the epidemiology for people with psychosis, discuss what services are available and highlight successful models of care, and examine policy solutions and strategies that the most effective for coordinated specialty services. The workshop will be held on Monday, July 11 from 11 a.m. to 5 p.m. ET. Click here to register.

Reminder: 2022 Annual Meeting Evaluation

If you attended the 2022 Annual Meeting in Washington, please take a few moments to complete this evaluation via Survey Monkey. Your feedback will help inform our future programs. Thank you.   Fact of the Week Comparing the Public Health Emergency (PHE) period (March 2020 to January 2022) with the pre-PHE period, mental health services for children covered by Medicaid has declined about 23%, according to preliminary data from CMS. For questions or comments about this CEO Update, please contact Jessica Zigmond

SAMHSA to Host Webinar on 42 CFR Part 2 Compliance Next Week

The Substance Abuse and Mental Health Services Administration (SAMHSA) will host a 90-minute webinar for business managers and compliance officers on July 7 to help ensure their organizations comply with SAMHSA’s 42 CFR Part 2 regulations. The lesson will highlight the latest updates released in January 2018; examine multiple scenarios and frequently asked questions related to SAMHSA’s mental health, substance abuse, and alcohol abuse records; and address proper ways to secure and/or release this information. SAMHSA urges practice managers, business associates who work with health records, compliance officers, physicians, and other medical professionals to attend the webinar on Thursday, July 7 at 1 p.m. ET. Click here to register.

White House Maternal Health Blueprint Aims to Increase Access to Behavioral Health Services

In its new White House Blueprint for Addressing the Maternal Health Crisis, the Biden administration has recommended 50 actions that more than a dozen federal agencies will take to improve maternal care in the United States, including some related to behavioral health. Released in June, the 68-page blueprint outlines five goals, starting with Goal #1: Increase Access to and Coverage of Comprehensive High-Quality Maternal Health Services, Including Behavioral Health Services. “We will continue to invest in maternal behavioral health by launching a 24/7 national support hotline for pregnant individuals and new mothers facing mental health challenges and improving provider education,” the blueprint noted in this first goal. “We will also strengthen access to perinatal addiction services by partnering with hospitals and community-based organizations to implement evidence-based practices,” it continued. “Congress must also take critical steps to bolster access to and coverage of maternal health services.” Other behavioral health-related action items include strengthening supports and access to perinatal addiction services for individuals with substance use disorder by partnering with hospitals and community-based organizations to implement evidence-based interventions, and appointing a dedicated associate administrator for women’s services at SAMHSA to lead its efforts in promoting positive mental health during pregnancy and in the postpartum period.

NABH Responds to AHRQ’s RFI About CAHPS Survey for Inpatient Mental Healthcare Settings

NABH this week responded to the Agency for Healthcare Research and Quality’s (AHRQ) request for information (RFI) regarding potential Consumer Assessment of Healthcare Providers and Systems (CAHPS) for Inpatient Mental Healthcare Settings. AHRQ’s detailed RFI seeks to identify the highest priority aspects patient experiences to include in measures and surveys, the benefits of collecting information about a patient’s experience from family members and caregivers, the challenges that exist in collecting this information, and much more. “During inpatient stays, patients are typically experiencing an increase in psychiatric symptomatology, including, but not limited to, hallucinations, paranoia, delusions, emotional lability, and fragmented cognitive processes,” NABH’s letter said in response to a question about the challenges in administering measures and surveys in mental healthcare settings. “Patients may thus be limited in their ability to express thoughts and feelings, to comprehend written material, or sustain their attention to complete a survey,” the letter continued. “For these reasons, we suggest limiting surveys to 20-25 questions, or 8-10.”

Reminder: National Academies’ Forum on Mental Health and SUD to Host Summer Workshop on Early Intervention for Psychosis on July 11

The National Academies’ Forum on Mental Health and Substance Use Disorders will host a public workshop that focuses on early intervention for psychosis, current data on the epidemiology and outcomes for people at high risk for psychosis and those who have experienced a first psychosis, and ways to improve care for these patients. Sessions will provide an overview of the epidemiology for people with psychosis, discuss what services are available and highlight successful models of care, and examine policy solutions and strategies that the most effective for coordinated specialty services. The workshop will be held on Monday, July 11 from 11 a.m. to 5 p.m. ET. Click here to register.

Reminder: 2022 Annual Meeting Evaluation

If you attended the 2022 Annual Meeting in Washington, please take a few moments to complete this evaluation via Survey Monkey. Your feedback will help inform our future programs. Thank you.

Fact of the Week

The United States requires about 6,600 new mental health practitioners to meet demand in regions the federal government has identified as health professional shortage areas, according to data from the Kaiser Family Foundation.

The NABH staff wishes you, your teams, and your families a happy and safe Independence Day weekend!

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

Senate Passes Gun-Control Bill with Mental Health Provisions

The Senate on Thursday passed the most significant gun-control legislation since the mid-1990s in a bill that includes about $15 billion in mental health and school security funding. The House is expected to vote today, June 24, on the measure. The Bipartisan Safer Communities Act expands the existing Medicaid Certified Community Behavioral Health Clinic (CCBHC) demonstration program to all states; helps states to implement, enhance, and expand school-based health programs under Medicaid through updated guidance, technical assistance, and state planning grants; requires the Centers for Medicare & Medicaid Services (CMS) to provide guidance to states on how they can increase access to behavioral health services through telehealth under Medicaid and CHIP; appropriates $150 million to help implement the upcoming 988 behavioral health crisis hotline; provides $500 million through the School-Based Mental Health Services Grant Program to increase the number of qualified mental health service providers that provide school-based mental health services to students in school districts with demonstrated need; and more. President Biden said he intends to sign the bill into law. “Last month, President Biden spent hours with the family members whose lives were forever changed by the recent shootings at a grocery store in Buffalo, New York and an elementary school in Uvalde, Texas,” said a Statement of Administration Policy from the Office of Management and Budget. “The family members delivered a simple message, which the president then relayed to the American people: do something. Do something to stop the carnage of gun violence that leaves behind grief and trauma in communities, both big and small, across the country.” The statement added that the bill advances President Biden’s agenda to expand access to mental health services and address the trauma of gun violence affecting so many communities. Click here to read the legislation.

House Passes Mental Health Bill to Reauthorize Funds for SAMHSA & HRSA

In a 402-20 vote Wednesday, the House of Representatives passed H.R. 7666, the Restoring Hope for Mental Health and Well-Being Act, which would reauthorize essential Substance Abuse and Mental Health Services (SAMHSA) and Health Resources and Services Administration (HRSA) programs to address the nation’s mental health and substance use crises. The bill would reauthorize and modify several programs, including the Community Mental Health Services Block Grant, the Substance Abuse Prevention and Treatment Block Grant, and grants related to suicide prevention and the behavioral health workforce. In remarks on the House floor, House Majority Leader Steny Hoyer (D-Md.) applauded the House Energy and Commerce Committee and all House members whose legislation was included in the package. “I hope this strong vote today will help move these critical policies through the Senate and see them quickly enacted into law,” Hoyer added. On Tuesday, the Biden administration said it supported the bill in a Statement of Administrative Policy.

World Health Organization Releases First World Mental Health Report Since 2001

The World Health Organization (WHO) has released its largest review of world mental health since it released World Health Report 2001: Mental Health: New Understanding, New Hope. The latest iteration, Transforming Mental Health for All, provides a roadmap for governments, academics, health professionals, and others to support the world in transforming mental health. “As the world comes to live with, and learn from, the far-reaching effects of the Covid-19 pandemic, we must all reflect on one of its most striking aspects – the huge toll it has taken on people’s mental health,” the nearly 300-page report noted. “Rates of already-common conditions such as depression and anxiety went up by more than 25% in the first year of the pandemic, adding to the nearly one billion people who were already living with a mental disorder,” it continued. “At the same time, we must recognize the frailty of health systems attempting to address the needs of people with newly-presenting as well as pre-existing mental health conditions.” The report also said that since 2001, countries worldwide have formally adopted international frameworks that guide them to act for mental health. And, it continued, WHO member states have adopted the Comprehensive Mental Health Action Plan 2013-2030, which commits them to meeting 10 global targets for improved mental health. Categorized in eight sections, the report examines principles and drivers in public mental health, assesses world mental health today, argues for investment in mental health, considers promotion and prevention strategies for change, and explores how to restructure and scale up care.

MACPAC Examines How Medicaid Policy Can Support Adopting Behavioral Health IT

In its June report to Congress, the Medicaid and CHIP Payment and Access Commission (MACPAC) analyzed how Medicaid policy can be used to support adopting health information technology among behavioral healthcare providers. The report highlighted that Medicaid programs play a critical role in financing behavioral health services and that those programs are focused on ways to provide behavioral health in more integrated settings. Therefore, the Commission recommended, “…that CMS issue guidance to help states use Medicaid authorities and other federal resources to promote behavioral health IT adoption, and that the Office of the National Coordinator for Health Information Technology and the Substance Abuse and Mental Health Services Administration work together to develop voluntary standards that would encourage health IT uptake appropriate for behavioral health.” See chapter 4 of the report, Encouraging Health Information Technology Adoption in Behavioral Health: Recommendations for Action, to learn more.

CDC Introduces Tool to Check Drinking and Create a Plan to Drink Less

The Centers for Disease Control and Prevention (CDC) has launched an alcohol-screening tool for adults to check their drinking, identify barriers to drinking less frequently, and create a personalized plan to make healthier drinking choices—all anonymously. The resource is part of the Atlanta-based agency’s new Drink Less, Be Your Best campaign that highlights the harmful effects of alcohol and provides resources to help adults drink less. CDC noted in its announcement that the tool is not intended for medical diagnosis or treatment.

‘Hiding in Plain Sight: Youth Mental Illness’ Documentary to Air June 27 and 28

Award-winning filmmaker Ken Burns presents Hiding in Plain Sight: Youth Mental Illness, a two-part documentary film by Erik Ewers and Christopher Loren Ewers on Monday and Tuesday, June 27 and 28 at 9 p.m. ET on PBS. Click here to see a preview of the film, which includes a brief introduction from Burns.

2022 Annual Meeting Presentations Available Online

Please visit our Annual Meeting homepage to view available slide presentations from this year’s Annual Meeting. NABH will post recorded presentations on a later date.   And if you attended the 2022 Annual Meeting in Washington, please take a few moments to complete this evaluation via Survey Monkey. Your feedback will help inform our future programs. Thank you.

Reminder: National Academies’ Forum on Mental Health and SUD to Host Summer Workshop on Early Intervention for Psychosis Next Month

The National Academies’ Forum on Mental Health and Substance Use Disorders will host a public workshop this summer that focuses on early intervention for psychosis, current data on the epidemiology and outcomes for people at high risk for psychosis and those who have experienced a first psychosis, and ways to improve care for these patients. Sessions will provide an overview of the epidemiology for people with psychosis, discuss what services are available and highlight successful models of care, and examine policy solutions and strategies that are the most effective for coordinated specialty services. The workshop will be held on Monday, July 11 from 11 a.m. to 5 p.m. ET. Click here to register.

Save the Date for the 2023 Annual Meeting!

Please save the date for NABH’s next Annual Meeting: June 12-14, 2023 at the Mandarin Oriental Washington, DC.

Fact of the Week

In 2019, nearly a billion people – including 14% of the world’s adolescents – were living with a mental disorder, the World Health Organization reports. For questions or comments about this CEO Update, please contact Jessica Zigmond

NABH Annual Meeting Kicks Off on Monday!

We’re pleased to devote this week’s edition of CEO Update to details about our Annual Meeting that starts on Monday, June 13! Our theme this year is Shaping the Future of Behavioral Healthcare, and our speakers—including HHS Secretary Xavier Becerra— will address topics that affect our industry today and in the years ahead. From parity and access to care, to the Biden’s administration’s behavioral health and drug control strategies, to the 2022 midterm elections, to workforce challenges and solutions, to the upcoming 988 behavioral health crisis hotline, this year’s program is one you won’t want to miss. On Monday, please be sure to look for an Annual Meeting Alert, which will include a link to our mobile app that contains important details about sessions, events, committee meeting room assignments, exhibitors and sponsors, our priorities for the 117^th Congress, restaurant recommendations in the Washington area, and more. We’ll open our meeting on Monday with two dynamic speakers: Ben Nemtin will discuss his personal battle with clinical depression and how to thrive personally and professionally, and journalist Sam Quinones will share his experiences writing his most recent book, The Least of Us: True Tales of America and Hope in the Time of Fentanyl and Meth. Sam will sign copies of his book after his presentation. As with previous Annual Meetings, we will post presentations on our website after the meeting ends. Registration opens on Monday at noon, and our first session kicks off in the Mandarin Oriental’s Grand Ballroom at 2:30 p.m. I hope to see you there! -Shawn Coughlin, President and CEO

HHS Secretary Becerra to Address Attendees on Tuesday, June 14

HHS Secretary Xavier Becerra, the 25^th secretary of the U.S. Health and Human Services Department and the first Latino to hold that office, will address Annual Meeting attendees on Tuesday, June 14 at 8:30 a.m. in the Grand Ballroom. Secretary Becerra will offer brief remarks and then engage in a question-and-answer session with NABH President and CEO Shawn Coughlin. Previously Secretary Becerra was California’s attorney general and before that served for 12 terms in the U.S. House of Representatives, where he was the first Latino to serve as a member of the powerful House Ways and Means Committee. He also served as chairman of his party’s caucus and as the ranking member of both the Ways and Means Subcommittee on Health and Ways and Means Subcommittee on Social Security. Secretary Becerra will discuss the Biden administration’s comprehensive strategy to address America’s mental health crisis, which includes promoting the well-being of the nation’s frontline healthcare workforce, piloting new approaches to training behavioral health paraprofessionals, strengthening the country’s crisis care and suicide prevention infrastructure, integrating mental health and substance use treatment into primary care, expanding and strengthening parity, and more.

ONDCP Director Rahul Gupta, M.D., M.B.A., FACP to Present on Tuesday, June 14

Following Secretary Becerra’s presentation on Tuesday, Office of National Drug Control Policy (ONDCP) Director Rahul Gupta, M.D., M.B.A., FACP will provide a presentation at 9:30 a.m. in the Grand Ballroom. Dr. Gupta is the first medical doctor to serve as director and lead ONDCP, a component of the Executive Office of the President. ONDCP coordinates the nation’s $40 billion drug budget and federal policies, including prevention, harm reduction, treatment, recovery support, and supply reduction. Through his work as a physician, a state and local leader, an educator, and a senior leader of a national nonprofit organization, Dr. Gupta has dedicated his career to improving public health and public safety. He is also a buprenorphine-waivered practitioner, who has provided medication-assisted treatment for people with opioid use disorder. The son of an Indian diplomat, Dr. Gupta was born in India and grew up in the suburbs of Washington, D.C. At age 21, he completed medical school at the University of Delhi and later completed subspecialty training in pulmonary medicine. Dr. Gupta earned a master’s degree in public health from the University of Alabama-Birmingham and a global master’s of business administration degree from the London School of Business and Finance.

Panel to Examine Ways to Address Behavioral Healthcare Workforce Challenges

Workforce shortages have challenged NABH members for years before the pandemic worsened the problem. For this year’s Annual Meeting, NABH has developed a panel to discuss potential solutions. Please join us in the Grand Ballroom on Tuesday, June 14 at 11 a.m. to learn from panelists Megan Baird of the Office of Apprenticeship in the U.S. Labor Department’s Employment and Training Administration; Malissa Lewis, LL.M of the Health Resources and Services Administration; and David Long of Pinnacle Treatment Centers, an NABH member organization. NABH Director of Quality and Addiction Services Sarah Wattenberg, L.C.S.W. will moderate a discussion that will highlight apprenticeships, loan repayment programs, and more.

Political Commentator Amy Walter to Discuss 2022 Midterm Elections

Be sure to attend this year’s Annual Meeting Luncheon at noon on Tuesday, June 14 in the Oriental Ballroom to learn from political commentator Amy Walter, who will preview this fall’s midterm election season. Walter, editor in chief of the Cook Political Report with Amy Walter and a political commentator for the PBS NewsHour, provides analysis of the issues, trends, and events that shape the political environment. She is also a regular Sunday panelist on NBC’s Meet the Press and CNN’s Inside Politics and appears frequently on Special Report with Bret Baier on Fox News Channel. From 2017 until early 2021, Walter was the host of the weekly nationally syndicated program “Politics with Amy Walter” on The Takeaway from WNYC and PRX. She’s also the former political director of ABC News.

Learn Details about the Wit v. UBH Case During Wednesday’s Policy Breakfast

Join us on Wednesday morning, June 15 to hear from Meiram Bendat, J.D., founder and president of Psych Appeal and consultant to NABH, who will discuss details of the Wit v. UBH case.   The policy breakfast will begin at 8 a.m. on Wednesday and the Annual Meeting will adjourn at 10 a.m.     The NABH team wishes everyone a safe trip to Washington, and we look forward to seeing you soon! For questions or comments about this CEO Update, please contact Jessica Zigmond

White House Releases Fact Sheet on Strategy to Address Nation’s Mental Health Crisis

The Biden Administration concluded Mental Health Month this week by announcing new actions to advance President Biden’s mental health strategy in three previously announced objectives: strengthening system capacity, connecting more Americans to care services, and creating a continuum of support. The White House noted that America’s mental health crisis is unprecedented, as two in five American adults report symptoms of anxiety and depression, and more than half of U.S. parents express concern about their children’s mental well-being. Meanwhile, the announcement continued, more than 40% of teenagers report they struggle with persistent feelings of sadness and hopelessness. “These growing demands have exposed longstanding cracks in our care infrastructure while compounding many other challenges, from criminal justice to homelessness to the labor shortage,” the White House announcement said. In a new fact sheet, the Biden Administration outlined applicable action steps to address the crisis, such as promoting the well-being of the healthcare workforce, piloting new approaches to training behavioral health paraprofessionals, bolstering the nation’s crisis care and suicide prevention infrastructure, building capacity for long-term care facilities to deliver behavioral health services, making care affordable across all types of health insurance coverage, integrating mental health services in ways that reduce stigma and access barriers, and more.

HHS’ Office on Women’s Health Announces Grant Program to Reduce Maternal Deaths Due to SUD

HHS’ Office on Women’s Health is accepting applications for projects designed to strengthen the perinatal (from conception to birth) and postnatal (up to 12 months after birth) to support structures for patients with substance use disorder (SUD) and reduce deaths during those two time periods. Applicants who receive funding will be expected to partner with hospital and community-based organizations to implement evidence-based interventions that strengthen perinatal and postnatal support structures for patients with SUD; create a technologically innovative education and outreach products to provide support accessible to perinatal and postpartum patients with SUD at home and on the go to reduce triggers, decrease stress, and increase feelings of support; and improve health outcomes and reduce deaths among perinatal and postpartum patients associated with SUD. Both for-profit and not-for-profit organizations are eligible to apply. Click here to learn more and apply.

National Academies’ Forum on Mental Health and SUD to Host Summer Workshop on Early Intervention for Psychosis

The National Academies’ Forum on Mental Health and Substance Use Disorders will host a public workshop this summer that focuses on early intervention for psychosis, current data on the epidemiology and outcomes for people at high risk for psychosis and those who have experienced a first psychosis, and ways to improve care for these patients. Sessions will provide an overview of the epidemiology for people with psychosis, discuss what services are available and highlight successful models of care, and examine policy solutions and strategies that are most effective for coordinated specialty services. The workshop will be held on Monday, July 11 from 11 a.m. to 5 p.m. ET. Click here to register.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. NABH developed the portal so members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will inform members when the updated portal is ready to use.

Learn About Our 2022 Annual Meeting Speakers!

The NABH 2022 Annual Meeting is fewer than two weeks away. Please be sure to learn more about this year’s speakers here on our Annual Meeting homepage. And please be sure to register for the meeting, if you have not done so yet. We look forward to seeing you soon in Washington!

Fact of the Week

A new study in JAMA Psychiatry found that after sustaining a mild traumatic brain injury (mTBI), some individuals—on the basis of education, race/ethnicity, history of mental health problems and cause of injury—were at substantially increased risk of post-traumatic stress disorder (PTSD) and/or major depressive disorder (MDD). For questions or comments about this CEO Update, please contact Jessica Zigmond

HHS Leaders Encourage States to Prioritize Efforts to Support Children’s Mental Health   Following Tuesday’s shooting at Robb Elementary School in Uvalde, Texas—the deadliest U.S. school shooting in 10 years in which a gunman killed 19 children and two teachers—U.S. Health and Human Services Department (HHS) agency leaders sent a joint letter to states, tribes, and jurisdictions urging them to maximize and prioritize their efforts to strengthen children’s mental health and well-being. According to the National Survey of Children’s Health, the number of children ages 3-17 years diagnosed with anxiety grew by 29% and those with depression by 27% between 2016 and 2020. Meanwhile, there was a 21% increase in children diagnosed with behavioral or conduct problems between 2019-2020. The letter provided a list of existing opportunities, partnerships, grants, and programs that states, tribes, and jurisdictions can access to support children’s mental health. Including HHS Secretary Xavier Becerra, leaders from the Administration for Children and Families, Administration for Community Living, Centers for Disease Control and Prevention, Centers for Medicare & Medicaid Services, Health Resources and Services Administration, and the Substance Abuse and Mental Health Services Administration (SAMHSA) signed the letter on May 25.

U.S. Surgeon General Releases Advisory on Health Worker Burnout

U.S. Surgeon General Vivek Murthy, M.D., M.B.A. this week released Addressing Health Worker Burnout, a 76-page advisory intended to draw the American people’s attention to an urgent public health issue and provide recommendations about how to manage it. In a video accompanying the advisory, Murthy noted that 54% of the nation’s physicians and nurses were experiencing burnout before the pandemic began, eight out of 10 health workers have experienced workplace violence, and 66% of U.S. nurses have considered resigning. “Healthcare systems, health insurance companies, and government must prioritize health worker well-being,” Murthy said in his recorded message. “This means increasing access to mental health services; reducing workplace burdens to prioritize time with patients; and protecting the health and safety of all health workers.” The advisory includes separate categories describing what healthcare organizations, federal, state, local, and tribal governments, insurers and payers, healthcare technology companies, academic institutions, clinical training programs, and accreditation bodies can do to help address health worker burnout.

George Washington University & Health Landscape Create Mental Health-SUD Workforce Database

With support from a SAMHSA grant, the George Washington University Fitzhugh Mullan Institute for Health Workforce Equity and data research firm Health Landscape have developed a national database on the country’s mental health and substance use disorder workforce to provide evidence-based support for creating policy and targeting resources appropriately. The new Behavioral Health Workforce Tracker is a comprehensive national database that identifies almost 1.2 million behavioral health providers, including more than 600,000 behavioral health specialists, including psychiatric and addiction medicine specialists, psychologists, counselors, and therapists; about 400,000 primary care physicians and advanced practice providers who provided 11 more behavioral health medications, and an additional 173,556 physician specialists who also wrote more than 11 behavioral health medications. Click here to learn more about the database.

National Academies’ Forum on Mental Health and SUD to Host Workshop on Early Intervention for Psychosis

The National Academies’ Forum on Mental Health and Substance Use Disorders will host a public workshop this summer that focuses on early intervention for psychosis, current data on the epidemiology and outcomes for people at high risk for psychosis and those who have experienced a first psychosis, and ways to improve care for these patients. Sessions will provide an overview of the epidemiology for people with psychosis, discuss what services are available and highlight successful models of care, and examine policy solutions and strategies that are most effective for coordinated specialty services. The workshop will be held on Monday, July 11 from 11 a.m. to 5 p.m. ET. Click here to register.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. NABH developed the portal so members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will keep members apprised of when the updated portal is ready to use.

NABH 2022 Annual Meeting Hotel Reservation Cutoff Date is Wednesday, June 1

The Mandarin Oriental Washington, DC has extended the hotel reservation cutoff date for the 2022 NABH Annual Meeting this coming Wednesday, June 1, 2022. Please be sure to reserve your hotel room today! And please visit our Annual Meeting webpage to register for the meeting, if you have not done so yet. We look forward to seeing you in Washington!

Fact of the Week 

There has been a 213% increase in the death rate of Black men from drug overdoses from 2015 to 2020, the American Psychological Association reports. Before 2015, Black men were considerably less likely than both White men and American Indian or Alaska Native men to die from drug overdoses. Since then, the death rate among Black men has more than tripled.   For questions or comments about this CEO Update, please contact Jessica Zigmond

NABH and Other Healthcare Groups Request Review of Three-Judge Panel’s Ruling in Wit v. UBH

NABH last week requested that the full 9^th U.S. Circuit Court of Appeals review a recent ruling from a three-judge panel that erroneously reversed a trial court’s landmark decision last year in the mental health class action, Wit v. United Behavioral Health.   NABH filed an amicus brief to request a “rehearing en banc.” If granted, a rehearing could vacate the appellate panel’s deeply flawed ruling. The American Hospital Association, American Psychological Association, American Association for the Treatment of Opioid Dependence, California Hospital Association, Federation of American Hospitals, National Association of Addiction Treatment Providers, National Council for Mental Wellbeing, and REDC added their organization names to the amicus brief. “Unfortunately, the likely consequence of the panel decision is that the gains achieved as a result of the district court’s rulings will be wiped out as even further restrictions are placed on the care patients receive for treatment of mental illness,” the amicus brief states. “Instead of medical necessity determinations based on GASC developed by non-profit expert bodies, the decision-making power will be left to the discretion of for-profit insurers such as UBH.”   Click here to read the news release that NABH distributed on Monday, May 16.

SAMHSA Introduces First ‘Behavioral Health Recovery Innovation Challenge’

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week introduced its first “Behavioral Health Recovery Challenge” to identify innovations that peer-run or community-based organizations—and entities that partner with them, including hospitals and health systems—have developed to advance recovery. SAMHSA defines recovery as “a process of change through which individuals improve their health and wellness, live self-directed lives, and strive to reach their full potential.” SAMHSA’s announcement noted that the agency encourages participants to share details about the practices they use to advance recovery and also demonstrate how these practices have: 1) expanded on SAMHSA’s definition of recovery, or 2) helped them overcome challenges in incorporating recovery into their behavioral health services or systems. “By using this vehicle, we hope to gain a better understanding of effective and innovative recovery practices from a very diverse field,” HHS Assistant Secretary for Mental Health and Substance Use Miriam E. Delphin-Rittmon, Ph.D., said in an announcement. Delphin-Rittmon also leads SAMHSA. “We aim to take what works for a small group and scale up to a larger population.” Click here to learn more from SAMHSA’s Recovery Innovation Challenge webpage.

SAMHSA Announces Funding Opportunity to Establish Center of Excellence on Social Media and Wellbeing

SAMHSA this week announced a funding opportunity that will award $2 million per year up to five years to establish a national Center of Excellence (CoE) that will develop and disseminate information, guidance, and training on the effects of children and youth’s social media use, including both its risks and benefits. SAMHSA’s grant announcement noted that the new CoE will pay particular attention to the potential risks social media platforms pose to the mental health of children and youth, as well as the clinical and societal interventions that could be used to address those risks. Eligible applicants include states, political divisions of states, Indian tribes or tribal organizations, health facilities, programs operated by or in accordance with a grant contract with the Indian Health Service, or other public of private, not-for-profit entities. The deadline to apply is Monday, July 18. Click here to learn more.

SAMHSA Announces $1.5 billion for State Opioid Response Program

SAMHSA this week said the agency’s State Opioid Response Program grant will fund up to $1,439,500,000 in fiscal year 2022 to 59 states and territories, including a set-aside for states with the highest opioid use disorder-related mortality rates. Grant funds may be used on contingency management to treat stimulant use disorder.   In announcement about the grant funding, Office of National Drug Control Policy Director Rahul Gupta, M.D., M.P.H., M.B.A., FACP said that fewer than one out of 10 people in the United States who need addiction care receive it.   “That is why President Biden released a National Drug Control Strategy to beat the overdose epidemic by going after its drivers: untreated addiction and drug trafficking,” Gupta said in the announcement. “Today we are delivering on key parts of our Strategy through this new funding, which will expand access to treatment for substance use disorder and prevent overdoses, while we also work to reduce the supply of illicit drugs in our communities and dismantle drug trafficking.” The use of contingency management for the treatment off stimulant use disorder is a permitted use of grant funds. The application process opened on Thursday, May 19 and will remain open through Monday, July 18. Click here to learn more.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. NABH developed the portal so members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will keep members apprised of when the updated portal is ready to use.

NABH 2022 Annual Meeting Hotel Reservation Cutoff Date Extended Until June 1

The Mandarin Oriental Washington, DC has extended the hotel reservation cutoff date for the 2022 NABH Annual Meeting to Wednesday, June 1, 2022. Please be sure to reserve your hotel room today! And please visit our Annual Meeting webpage to register for the meeting, if you have not done so yet. We look forward to seeing you in Washington!

Fact of the Week

In a recent Cigna survey of 1,000 parents, 80% said their children are struggling with mental health, and nearly one-fifth (18%) say their child’s needs are negatively affecting their job performance and productivity. For questions or comments about this CEO Update, please contact Jessica Zigmond

CDC Predicts U.S. Overdose Deaths Surpassed 107,000 in 2021

More than 107,000 Americans died of drug overdoses in 2021, according to provisional data from the Centers for Disease Control and Prevention (CDC) released this week. The troubling statistic—the CDC predicts the total to be 107,622 lives lost— hit a new record, as the number of predicted overdose deaths in 2021 reflects a 15-percent increase in the previous record set in 2020. “It is unacceptable that we are losing a life to overdose every five minutes around the clock,” the Office of National Drug Control Policy Director Rahul Gupta, M.D., M.P.H., M.B.A., FACP, said in a White House statement. “That is why President Biden’s new National Drug Control Strategy signals a new era of drug policy centered on individuals and communities, focusing specifically on the actions we must take right now to reduce overdoses and save lives.” Separately this week, the United States Drug Enforcement Administration (DEA) recognized the first Fentanyl Awareness Day on Monday, May 9. The DEA reports that the synthetic opioid fentanyl is about 50 times more potent than heroin and 100 times more potent than morphine. It is also inexpensive, widely available, and highly addictive. DEA Administrator Anne Milgram released a video announcement about the dangers of fentanyl and the need for urgent action.

HRSA Extends Deadline to Submit for Extenuating Circumstances Request to May 18

HHS’ Health Resources and Services Administration (HRSA) this week announced it has extended the deadline for providers to request to submit a late Provider Relief Fund (PRF) Reporting Period 2 (RP2) report to Wednesday, May 18 at 11:59 p.m. ET. According to HRSA, providers may submit a request if certain extenuating circumstances prevented them from submitting their RP2 report by the initial deadline of March31. All requests must be completed through the PRF Reporting Portal.

Center for Connected Health Policy Releases Bi-Annual Summary of State Telehealth Policy Changes

The Center for Connected Health Policy (CCHP) this week released a summary of state telehealth policy changes for Spring 2022. Covering state telehealth policy updates between January and April 2022, the 11-page summary examines state laws and reimbursement policies, private payors, online prescribing, and more. The resource also includes a state summary chart and an infographic of CCHP’s essential findings.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. The portal was developed so NABH members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will keep members apprised of when the updated portal is ready to use.

NABH 2022 Annual Meeting Preliminary Program Now Available!

The NABH 2022 Annual Meeting online preliminary program is now available. 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 next month in Washington!

Fact of the Week

Adolescent female youth who attempted suicide had an elevated risk of substance use disorders up to three decades later, according to a new study in JAMA Psychiatry.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

ASPE Report Studies Pandemic’s Effects on Hospital and Clinician Workforce

A comprehensive report from HHS’ Assistant Secretary for Planning and Evaluation (ASPE) examines the Covid-19 pandemic’s effects on the nation’s healthcare workforce and offers several recommendations, including removing barriers to practicing to the top of one’s license/certification, retaining Covid-19 flexibilities as appropriate, funding for scholarships, and more.   The nearly 30-page report, Impact of the COVID-19 Pandemic on the Hospital and Outpatient Clinician Workforce, found that total employment in the healthcare industry declined during the early months of the pandemic but gradually recovered during the summer of 2020. Many hospitals reported critical staffing shortages during the course of the pandemic—especially when Covid case numbers were high—and during the recent Omicron surge in January and February 2022, the seven-day average of hospitals reporting critical staffing shortages peaked at 22% during mid-January 2022, the report noted. The report acknowledged that several provider types, including behavioral health providers, experienced staffing shortages before the pandemic began. “Even after the pandemic, many of the effects the pandemic has had on the health care workforce will likely persist,” the report noted. “Addressing these impacts as well as the underlying challenges that pre-dated the pandemic can help build a stronger and more resilient health care system for the future.”

Joint Commission’s Covid-19 Staff Vaccination Standard Takes Effect July 1

The Joint Commission said it has approved its new Infection Prevention and Control standard and its elements of performance as a response to the interim final rule from the Centers for Medicare & Medicaid Services (CMS) late last year. According to the Joint Commission, the accrediting organization began surveying to the Omnibus Covid-19 Health Care Staff Vaccination interim final rule—which was released on Nov. 5, 2021—on Jan. 27 this year. “While changes to Joint Commission standards requirements were under review by CMS, findings related to the COVID-19 staff vaccination regulatory requirements have been scored at Leadership (LD) Standard LD.04.01.01, EP 2, along with the applicable Medicare Conditions of Participation/Conditions for Coverage for each of the deemed programs,” the Joint Commission said in an announcement. “This scoring process will continue until June 30, 2022. Click here to learn more.

SAMHSA Senior Medical Advisor John Palmieri, M.D., M.H.A. to Address Attendees at Annual Meeting 

NABH will welcome John Palmieri, M.D., M.H.A., senior medical advisor at the Substance Abuse and Mental Health Services Administration (SAMHSA) and acting director for the 988 behavioral health crisis hotline and Behavioral Health Crisis Coordinating Office, at the 2022 Annual Meeting in Washington on Tuesday, June 14. Prior to his arrival at SAMHSA, Dr. Palmieri was the division chief for behavioral healthcare at the Arlington County (Virginia) Department of Human Services. Dr. Palmieri is a licensed physician in Virginia and is board certified in adult psychiatry. He graduated from Brown University Medical School and completed his adult psychiatry residency at Massachusetts General Hospital. Please click here to learn about our 2022 Annual Meeting speakers.

National Prevention Week is May 8-14

SAMHSA’s National Prevention Week starts Sunday, May 8, and the agency will commemorate the 18^th annual National Prevention Day on Monday, May 9. Click here for an agenda of the day’s events. The week-long commemoration is part of Mental Health Awareness Month, which kicked off on Sunday, May 1. The White House issued a proclamation honoring Mental Health Awareness Month, and Mental Health America (MHA)—which established the monthly observance in 1949—is recognizing the 2022 observance with the theme “Back to Basics.” The campaign is intended to provide what MHA has referred to as “foundational knowledge” about mental health, mental health conditions, and information about what people can do if their mental health is cause for concern. Please remember to follow NABH on Twitter @NABHbehavioral and on LinkedIn at the National Association for Behavioral Healthcare throughout the month to learn what NABH members, federal agencies, and advocacy organizations are doing to promote Mental Health Month.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. The portal was developed so NABH members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will keep members apprised about the updated portal is ready to use.

Please Visit the NABH 2022 Annual Meeting Exhibitors & Sponsors Page!

 NABH appreciates the generous support from its exhibitors and sponsors each year at the association’s Annual Meeting. To learn who is exhibiting and sponsoring NABH in 2022, please visit the Exhibitors & Sponsors page on our Annual Meeting homepage. The page also includes general information, tips for exhibitors, and details about shipping materials to the Mandarin Oriental Washington, DC. And 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 next month in Washington!

Fact of the Week

Audio-only visits were the leading telehealth modality for primary care and behavioral health throughout the full pandemic study period of February 2019 through August 2021, according to a new research report from RAND. At the end of the study period, however, audio-only visits were eclipsed by in-person visits for primary care, but not for behavioral health, the study showed.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Behavioral Health Strategy Aims to Strengthen Equity, Improve Quality, and Provide Outreach to Beneficiaries

The Centers for Medicare & Medicaid Services (CMS) recently released The CMS Behavioral Health Strategy, a five-goal plan that aims to remove barriers to care and services and also adopt a data-informed approach to evaluate the agency’s behavioral health programs and policies. Noting that the strategy “will strive to support a person’s whole emotional and mental well-being and promotes person-centered behavioral healthcare,” CMS set the following five goals: 1) strengthen equity and quality in behavioral healthcare, 2) improve access to substance use disorders treatment, prevention, and recovery services, 3) ensure effective pain treatment and management, 4) improve access and quality of mental healthcare and services, and 5) utilize data for effective actions and impact on behavioral health. Click here to learn about the objectives in each of those goals.

SAMHSA Announces New Director of the Center for Substance Abuse Treatment

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week named Yngvild Olsen, M.D., M.P.H. as the new director of the agency’s Center for Substance Abuse Treatment. An addiction medicine specialist and general internist, Olsen began her career as the medical director for the outpatient substance use treatment services while serving as a full-time assistant professor in the department of medicine at the Johns Hopkins School of Medicine. From 2011 to 2021, Olsen served as medical director for the Institutes for Behavior Resources/REACH Health Services, a comprehensive outpatient substance use disorder treatment program in Baltimore City.

ONDCP Director Rahul Gupta to Address Attendees at NABH Annual Meeting

NABH is pleased to announce that Director of National Drug Control Policy Rahul Gupta, M.D., M.P.H., M.B.A., FACP will address attendees at the 2022 Annual Meeting on Tuesday, June 14. Dr. Gupta is the first medical doctor to serve as director and lead the Office of National Drug Control Policy (ONDCP), a component of the Executive Office of the President. ONDCP coordinates the nation’s $40 billion drug budget and federal policies, including prevention, harm reduction, treatment, recovery support, and supply reduction. Through his work as a physician, a state and local leader, an educator, and a senior leader of a national nonprofit organization, Dr. Gupta has dedicated his career to improving public health and public safety. He is also a buprenorphine-waivered practitioner, who has provided medication-assisted treatment for people with opioid use disorder. The son of an Indian diplomat, Dr. Gupta was born in India and grew up in the suburbs of Washington, D.C. At age 21, he completed medical school at the University of Delhi and later completed subspecialty training in pulmonary medicine. Dr. Gupta earned a master’s degree in public health from the University of Alabama-Birmingham and a global master’s of business administration degree from the London School of Business and Finance. If you have not done so yet, please visit our Annual Meeting homepage and register today. We look forward to seeing you in Washington!

In Case You Missed It: Kennedy Forum Parity Webinar Recording Now Available

NABH President and CEO Shawn Coughlin participated in a webinar about mental health and substance use disorder treatment parity on Tuesday, April 26 with federal health officials and healthcare organization leaders. Coughlin joined fellow presenters HHS Secretary Xavier Becerra, Assistant Secretary for Mental Health and Substance Use Miriam Delphin-Rittmon, Ph.D., The Kennedy Forum founder and former U.S. Rep. Patrick J. Kennedy (D-R.I.), and American Medical Association President Patrice Harris, M.D. to discuss the Biden administration’s commitment to ensuring parity implementation, the recent Wit v. United Behavioral Health ruling, and ongoing problems with parity compliance. David Lloyd, senior policy advisor at The Kennedy Forum, moderated the event. During the webinar, Delphin-Rittmon, who serves as administrator of SAMHSA, discussed three parity resources that SAMHSA has developed to help patient families, providers, and policymakers understand parity: Know Your Rights, Understanding Parity: A Guide to Resources for Families and Caretakers, and The Essential Aspects of Parity: A Training Tool for Policymakers. NABH was the lead sponsor for this webinar and live Tweeted during the event. Click here to watch the recorded broadcast.

BPC to Host Webinar Monday on Combating the Opioid Crisis with Smarter Federal Spending

The Bipartisan Policy Center (BPC) will host a webinar on Monday, May 2 about new recommendations centered on enhancing federal spending and improving the federal response to America’s ongoing opioid crisis. Participants include Office of National Drug Control Policy Director Rahul Gupta, M.D., M.P.H., M.B.A., FACP; Sen. Joe Manchin (D-W.Va.); American Medical Association President Patrice Harris, M.D.; former U.S. Surgeon General Jerome Adams, M.D.; and former HHS Secretary Donna Shalala. The hour-long webinar will begin at 1 p.m. ET. Click here to register. 

Mental Health Awareness Month Starts Sunday!

Mental Health Month kicks off this Sunday, May 1 to raise awareness about mental health in America. Mental Health America (MHA), which established the monthly observance in 1949, will commemorate Mental Health 2022 with the theme “Back to Basics” to provide what MHA has referred to as “foundational knowledge” about mental health, mental health conditions, and information about what people can do if their mental health is cause for concern. SAMHSA’s National Prevention Week is May 8-14 and the agency will commemorate the 18^th annual National Prevention Day on Monday, May 9. Click here for an agenda of the day’s events. And please remember to follow NABH on Twitter @NABHbehavioral and on LinkedIn at the National Association for Behavioral Healthcare throughout the month to learn what NABH members, federal agencies, and advocacy organizations are doing to promote Mental Health Month.

NABH Working to Enhance Denial-of-Care Portal

NABH’s Denial-of-Care Portal is temporarily unavailable as the association works to enhance features of this member-only resource. The portal was developed so NABH members could submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation and is intended to help the association in its advocacy efforts with policymakers and regulators. NABH will keep members apprised when the updated portal is ready to use.

Fact of the Week

Mental health, developmental disorders, and substance use disorders collectively accounted for 48% of all telehealth claims, according to a new report from FAIR Health, a national, not-for-profit organization that produces data products and consumer resources about transparency in healthcare costs and health insurance.   For questions or comments about this CEO Update, please contact Jessica Zigmond.

President Biden Sends National Drug Control Policy to Congress

President Biden on Thursday sent his administration’s inaugural National Drug Control Policy to Congress with the goal of using a whole-of-government approach to combat the nation’s overdose crisis. The comprehensive strategy focuses on the main drivers of the crisis—untreated addiction and drug trafficking—as it directs federal agencies to take actions that will expand access to evidence-based prevention, harm reduction, treatment, and recovery services, while also reducing the supply of drugs. The plan comes as the nation continues to produce grim statistics: for the first time in America’s history, the country has passed the milestone of 100,000 deaths resulting from drug overdoses in a 12-month period. Meanwhile, since 1999, drug overdoses have killed approximately 1 million Americans. A message from President Bident to Congress at the beginning of the strategy explains the Office of National Drug Control Policy led the effort to produce the strategy in close collaboration with the 18 national drug control agencies. In addition, the Biden administration involved more than 2,000 leaders and stakeholders, including Congress, all 50 Governors, and advocates representing public safety, public health, community groups, local governments, and Tribal communities. An important component of the strategy is its emphasis on harm reduction, an approach that works with people who use drugs to prevent overdose and infectious disease transmission; improve the physical, mental, and social wellbeing of those served; and offer flexible options for accessing substance use disorder treatment and other health care services. “We are changing how we help people when it comes to drug use, by meeting them where they are with high-impact harm reduction services and removing barriers to effective treatment for addiction,” Rahul Gupta, M.D., M.P.H., M.B.A., director of National Drug Control Policy, said in the document, “while addressing the underlying factors that lead to substance use disorder head on.”

The Kennedy Forum to Host Parity Webinar on Tuesday, April 26

NABH President and CEO Shawn Coughlin will join HHS Secretary Xavier Becerra and other healthcare leaders in a webinar about expanding access to mental health and addiction treatment coverage on Tuesday, April 26. The webinar will also feature Assistant Secretary for Mental Health and Substance Use Miriam Delphin-Rittmon, Ph.D., former U.S. Rep. Patrick J. Kennedy, and American Medical Association President Patrice Harris, M.D. Click here to learn more and register for the hourlong webinar, which will start at 2 p.m. ET.

NABH Sends Comments to CMS About Access to Coverage in Medicaid & CHIP

NABH this week responded to a request for information from the Centers for Medicare & Medicaid Services (CMS) regarding access to coverage for Medicaid and the Children’s Health Insurance Program (CHIP). In the letter, NABH emphasized that inadequate access to acute care has led to a strong reliance on hospital emergency rooms to treat people with serious mental illness, even though these settings are not well-suited to address those particular patient needs. NABH also emphasized how the Covid-19 pandemic has heightened the already-increased need for mental health and addiction services. NABH outlined a series of recommendations, including strengthening network adequacy for the full continuum of mental health and addiction treatment; requiring Medicaid programs and plans to implement parity compliance documentation requirements in Medicaid and CHIP; improving Medicaid reimbursement for mental health and addiction treatment providers; and more.

CMS Opens Federal Independent Dispute Resolution Process for Providers

CMS late last week opened the Federal Independent Dispute Resolution (IDR) process for healthcare providers, facilities, health plans, and issuers to resolve payment disputes for certain out-of-network charges. According to CMS, an initiating party will need the following in order to start a dispute: information to identify the qualified IDR items or services; dates and location of items or services; type of items or services such as emergency services and post-stabilization services; codes for corresponding service and place-of-service; attestation that items or services are within the scope of the Federal IDR process; and the initiating party’s preferred certified IDR entity. A list of certified entities is available here. After the 30-business-day open negotiation period ends, initiating parties will have four business days to initiate a dispute via the portal.

BJA Accepting Applications for Variety of Behavioral Health-Related Grant Opportunities

The U.S. Justice Department’s Bureau of Justice Assistance (BJA) is accepting applications for a range of grant programs—eligible to both for-profit and not-for-profit organizations— that seek to improve outcomes for people with mental health and substance use disorders. BJA’s Residential Substance Abuse Treatment (RSAT) for State Prisoners Training and Technical Assistance Program offers funding to provide training and technical assistance (TTA) to grantees and practitioners to improve correctional substance use disorder treatment programming and post-release outcomes for individuals who are incarcerated. Of the four grant opportunities noted in this news item, this grant is the only one for which for-profit organizations other than small businesses are eligible. The Connect and Protect: Law Enforcement Behavioral Health Response Program is seeking applications for funding to support law enforcement-behavioral health cross-system collaboration to improve public health and safety responses and outcomes for people with mental health and substance use disorders. BJA is also accepting applications for its Improving Substance Use Disorder Treatment and Recovery Outcomes for Adults in Reentry for funding to establish, expand, and improve treatment and recovery support services for people with substance use disorders during their incarceration and upon reentry into the community. And the department is accepting applications for its Justice and Mental Health Collaboration Program to support cross-system collaboration to improve public safety responses and outcomes for individuals with mental health disorders or co-occurring mental health and substance use disorders who come into contact with the justice system. Please click on the hyperlinks above for more information and grant deadlines. Political Analyst Amy Walter to Address Attendees at 2022 Annual Meeting Luncheon NABH is pleased to welcome on-air political analyst Amy Walter as the association’s Annual Meeting Luncheon keynote speaker in Washington on Tuesday, June 14. For more than 20 years, Amy Walter has built a reputation as an accurate, objective, and insightful political analyst with unparalleled access to campaign insiders and decision-makers. Known as one of the best political journalists covering Washington, she is the publisher and editor-in-chief of the non-partisan Cook Political Report with Amy Walter, where she provides analysis of the issues, trends, and events that shape the political environment. As a contributor to the PBS NewsHour, Ms. Walter provides weekly political analysis for the popular “Politics Monday” segment. She is also a regular Sunday panelist on NBC’s Meet the Press and CNN’s Inside Politics and appears frequently on Special Report with Bret Baier on Fox News Channel. Please plan to join us for this year’s Annual Meeting luncheon. And if you haven’t done so yet, please remember to register for the meeting and reserve your hotel room today. We look forward to seeing you in Washington! Fact of the Week People with schizophrenia made up a lower proportion of telehealth encounters relative to in-person visits (1.7% versus 2.7%), while those with anxiety and fear-related disorders accounted for a higher proportion (27.5% versus 25.5%), according to a new study published in the April edition of Health Affairs. Researchers concluded the findings highlight the importance of broadening access to services through new modalities without supplanting necessary in-person care for certain groups. For questions or comments about this CEO Update, please contact Jessica Zigmond.

U.S. Preventive Services Task Force Issues Draft Recommendations on Screening for Anxiety, Depression, and Suicide Risk in Children and Adolescents

In a set of draft recommendations this week, the U.S. Preventive Services Task Force (USPTF) recommended screening children 12 and older for depression and children 8 and older for anxiety. “There is not enough evidence to recommend for or against screening for anxiety and depression in younger children and screening for suicide risk in all youth,” the USPTF announced in a bulletin on April 12. Both the American Academy of Pediatrics (AAP) and the American Foundation for Suicide Prevention (AFSP) expressed serious concerns about the panel’s conclusion that there is insufficient evidence to weigh the benefits and harms of screening asymptomatic children and adolescents for suicide risk. The AAP is urging clinicians to screen all adolescents for suicide risk despite the panel’s finding that more research is needed. “Youth may keep suicidal thoughts to themselves and will not bring up the topic unless directly asked,” May Lau, M.D., M.P.H., a member of the AAP Section on Adolescent Health Executive Committee and a lead author of the Blueprint for Youth Suicide Prevention from AAP/AFSP, said in an article in AAP News. “By screening all youth for suicide, we can identify those that are at risk and connect them with the services they need.” Meanwhile, Christine Moutier, M.D., chief medical officer at the AFSP, told the Associated Press this week that the report “may actually set the field back.” “We have grave concerns that the recommendation citing ‘insufficient evidence’ to implement routine screening for suicide risk for any age youth is 1) flawed due to the incomplete data sources included in their review, and 2) may confuse the field just as major steps are being taken,” Moutier wrote in an e-mail message to NABH. Moutier added that the Blueprint for Youth Suicide Prevention recommends screening for youth ages 12 and older and outlines evidence-based care steps to take for youth who screen positive. A public comment period for the USPTF’s draft recommendations is open until May 9. Click here for details.

HRSA Announces More Than $1.75 Billion in Provider Relief Fund Phase 4 Distribution Payments

HHS’ Health Resources and Services Administration (HRSA) said it is making available more than $1.75 billion in Provider Relief Fund (PRF) Phase 4 General Distribution payments to more than 3,680 providers nationwide this week. According to HRSA, on April 13 providers received an email notification if their application was among those processed in this latest round, and the agency is working to process all remaining applications as quickly as possible. Also this week, HHS Secretary Xavier Becerra extended the PHE for an additional 90 days after the current PHE expires on April 16.

HRSA Announces it Will Offer ‘Extenuating Circumstances’ Option to Providers for PRF Reporting Period 2

HRSA this week said healthcare providers will have the opportunity to submit a “Request to Report Late Due to Extenuating Circumstances for Reporting Period 2” if applicable. Last week, HRSA announced the “extenuating circumstances” option for Reporting Period 1, which lasts from April 11 through April 22. The agency said providers will receive a notification regarding the process to submit a request for Reporting Period 2 in the coming weeks. For more information, visit the Request to Report Late Due to Extenuating Circumstances webpage, or call the Provider Support Line at (866) 569-352 from 9 a.m. to 11 p.m. CT, Monday through Friday.

The Kennedy Forum to Host Parity Webinar Featuring Leaders from HHS, SAMHSA, NABH, & AMA

NABH President and CEO Shawn Coughlin will join HHS Secretary Xavier Becerra and other healthcare leaders in a webinar about expanding access to mental health and addiction treatment coverage later this month. The webinar on Tuesday, April 26 will also feature Assistant Secretary for Mental Health and Substance Use Miriam Delphin-Rittmon, Ph.D., former U.S. Rep. Patrick J. Kennedy, and American Medical Association President Patrice Harris, M.D. Click here to learn more and register for the hour-long webinar, which will start at 2 p.m. ET.

AHA & IAHSS Release Toolkit to Help Mitigate Violence in Healthcare Settings

The American Hospital Association (AHA) and the International Association for Healthcare Security and Safety (IAHSS) have developed a toolkit for hospitals and health systems to establish procedures to prevent violence at all levels. Creating Safer Workplaces is an 11-page resource that provides a framework to build a safer workplace environment; outlines what leaders should consider to promote physical safety and teamwork; highlights how leaders can mitigate risk; describes the role of hospitals in violence intervention; and more.

NPR Story Reports Most State Medicaid Programs Won’t Text Enrollees Despite Urgency to Renew Coverage

A National Public Radio (NPR) story this week cited a recent Kaiser Family Foundation report that found just 11 states said they would use text messaging to alert Medicaid recipients about the end of the Covid public health emergency, while 33 states will use the U.S. Postal Service and at least 20 will rely on individual or automated phone calls. “It’s frustrating that texting is a means to meet people where they are and that this has not been picked up more by states,” Jennifer Wagner, director of Medicaid eligibility and enrollment for research group the Center on Budget and Policy Priorities, said in the story. NPR also noted that officials at the Centers for Medicare & Medicaid Services (CMS) have told states they should consider texting—along with other methods of communication—when trying to contact enrollees about the end of the public health emergency (PHE), but many states don’t have the technology or information about enrollees to do so.

Reminder: NABH Denial-of-Care Portal is Open to Members 

NABH’s Denial-of-Care Portal is available for members to provide information about their experiences with managed care organizations that impose barriers to care through insurance-claim denials. This NABH member-only, survey-like tool allows users to add the name of a managed care organization, type of plan, level of care, type of care (mental health or substance use disorder), duration of approved treatment, duration of unapproved treatment, criteria used to deny a claim, and more. The portal allows members to submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation. In time, the tool could be a valuable resource for the NABH team’s advocacy efforts. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal. Deadline for 2022 NABH Exhibitor & Sponsor Guide Ads is Next Week The deadline to submit an ad in NABH’s 2022 Exhibitor and Sponsor Guide is Tuesday, April 19. Be sure your organization is included in this year’s edition! Please click here for details about advertising options, requirements, payment, and more. We hope to see you in Washington in June!

Fact of the Week 

A recent National Institute of Mental Health-funded study showed that Stepped Care Trauma-Focused (TF) Cognitive Behavioral Therapy (CBT)—in which step one is a parent-led therapist-assisted treatment and step two provides therapist-led TF-CBT for children who did not benefit from step one and require more intensive treatment—can reduce costs by nearly 54%. For questions or comments about this CEO Update, please contact Jessica Zigmond.

HRSA Announces ‘Extenuating Circumstances’ Option for Provider Relief Fund Reporting

HHS’ Health Resources and Services Administration (HRSA) this week said it will allow healthcare providers to submit a Request to Report Late Due to Extenuating Circumstances for the Provider Relief Fund (PRF) Reporting Period 1 if one or more certain extenuating circumstances apply to their situations. Starting Monday, April 11 and continuing through Friday, April 22 at 11:59 p.m. ET, providers who did not submit their PRF Period 1 report by the required deadline may request to submit a late Reporting Period 1 report, via a DocuSign form, if the following extenuating circumstances exist:

• Severe illness or death: if a severe medical condition or death of a provider or key staff member responsible for reporting hindered the organization’s ability to complete the report during the reporting period

• Impacted by natural disaster: if a natural disaster occurred during or in proximity to the end of the reporting period and damaged the organization’s records or information technology

• Lack of receipt of reporting communications: if an incorrect email or mailing address on file with HRSA prevented the organization from receiving instructions prior to the reporting period deadline

• Failure to click “submit”: if the organization registered and prepared a report in the PRF Reporting Portal, but failed to take the final step to click “submit” prior to deadline

• Internal miscommunication or error: if an internal miscommunication or error regarding the individual who was authorized and expected to submit the report on behalf of the organization and/or the registered point of contact in the PRF Reporting Portal

• Incomplete Targeted Distribution payments: if the organization’s parent entity completed all General Distribution payments, but a Targeted Distribution(s) was not reported on by the subsidiary

According to HRSA, requests to report late due to extenuating circumstances must indicate and attest to a clear and concise explanation, although the agency will not require supporting documents. If HRSA approves an organization’s request, the organization will receive a notification to proceed with completing the Reporting Period 1 report. Providers will have 10 days from the date they receive the notification to submit a report in the PRF Reporting Portal. Click here to learn more about reporting requirements, or call the Provider Support Line at (866) 569-3522 between 9 a.m. to 11 p.m. ET for additional information.

CMS Releases Two Sets of FAQ About ‘No Surprises Act’ Requirements

The Centers for Medicare & Medicaid Services (CMS) this week released two sets of frequently asked questions (FAQ) regarding requirements enacted in the No Surprises Act. CMS issued an FAQ on April 6 that provides additional explanation about the law’s requirements and prohibitions, as well as clarification regarding the independent dispute resolution process and associated fees. A day earlier, CMS released an FAQ with additional information about developing good-faith estimates for uninsured or self-pay patients.

Thorn Run Partners Memo Highlights Medicare & Medicaid Flexibilities During the PHE

Thorn Run Partners, a bipartisan lobbying firm that works with NABH, recently highlighted a host of flexibilities in the Medicare and Medicaid programs during the ongoing Covid-19 public health emergency (PHE). The 14-page memo includes information about recent guidance from CMS, PHE extensions, PHE-related policies in the $1.5 trillion omnibus spending package that President Biden recently signed into law, and more. Click here to read the memo.

NABH Supports ‘Behavioral Health Information Technology Now Act’

NABH is pleased to support the Behavioral Health Information Technology Now Act, a new bill that would offer financial incentives to behavioral healthcare providers for health information technology adoption. Reps. Doris Matsui (D-Calif.) and Markwayne Mullin (R-Okla.) introduced the bill in an effort to coordinate care between physical and mental healthcare—and also include behavioral healthcare providers from a key resource that they have been excluded from for years. “The National Association for Behavioral Healthcare applauds Reps. Matsui and Mullin for recognizing that for far too long, behavioral healthcare providers have not received health information technology funding that other providers have benefited from,” NABH President and CEO Shawn Coughlin said in a news release about the legislation on April 6. “Their legislation would enable behavioral healthcare providers to coordinate care across behavioral healthcare service systems, primary care facilities, and specialty medicine providers more efficiently.” Specifically, the bill would:

• Finance behavioral health information technology (IT) adoption at $250 million

• Condition funding allocations to providers based on: 1) acquisition of health IT systems that comply with 2015 certification standards, and 2) attestation of provider compliance with Trump Administration Interoperability and Data Blocking regulations

• Direct the Office of the National Coordinator for Health Information Technology and the Substance Abuse and Mental Health Services Administration to develop voluntary behavioral health IT standards.

Reminder: NABH Denial-of-Care Portal is Open to Members

NABH’s Denial-of-Care Portal is available for members to provide information about their experiences with managed care organizations that impose barriers to care through insurance-claim denials. This NABH member-only, survey-like tool allows users to add the name of a managed care organization, type of plan, level of care, type of care (mental health or substance use disorder), duration of approved treatment, duration of unapproved treatment, criteria used to deny a claim, and more. The portal allows members to submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation. In time, the tool could be a valuable resource for the NABH team’s advocacy efforts. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Register Today for the 2022 Annual Meeting!

NABH will host its 2022 Annual Meeting—Shaping the Future of Behavioral Healthcare—from June 13-15 at the Mandarin Oriental Washington, DC. Please remember to register for the meeting and reserve your hotel room today!

Fact of the Week

Veterans who take medications for opioid use disorder (OUD) for at least 15 days have more than a 50% decreased risk of dying by suicide compared with those not taking OUD medications, according to a study in the April issue of the American Journal of Psychiatry. For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Proposes 2.7% Increase to Inpatient Psychiatric Facilities in 2023

The Centers for Medicare & Medicaid Services (CMS) on Thursday proposed increasing payment rates to the nation’s inpatient psychiatric facilities by 2.7% in fiscal year (FY) 2023, reflecting a 1.5% increase in payments, or about $50 million, relative to FY 2022. According to the agency’s inpatient psychiatric facility prospective payment system (IPF PPS) proposed rule for FY 2023, the IPF PPS federal, per-diem base rate would increase to $856.80 from $832.94 and the electroconvulsive therapy payment rate would increase to $368.87 per treatment from $358.60 per treatment. CMS said the increase is based on the proposed IPF market basket update of 3.1% less a 0.4% percentage point productivity adjustment. For FY 2023 and subsequent years, CMS has proposed to apply a 5% cap on decreases in the IPF PPS wage index in order to mitigate instability in IPF PPS payments due to significant wage index decreases that may affect providers in any given year. CMS did not propose any changes for the IPF Quality Reporting Program for FY 2023. Meanwhile, the agency is seeking comments via a request for information (RFI) about what CMS should consider when advancing the use of measurement and stratification as tools to address healthcare disparities and advance healthcare equity. Specifically, CMS would like comments related to goals and approaches for measuring disparities and using measure stratification across CMS Quality Reporting Programs; guiding principles for selecting and prioritizing measures for disparity reporting; principles for social risk factor and democratic data selection and use; identification of meaning performance differences; guiding principles for reporting disparity measures; and measures related to health equity. CMS is considering and requesting comment about applying the following measures of health equity in the Inpatient Psychiatric Facility Quality Reporting Program: Health Equity Summary Score (HESS) and a structural measure assessing the degree of hospital leadership engagement in health equity performance data. Both of these measures are under consideration for the Medicare Inpatient Quality Reporting Program. Please send any comments that your organization may have to Kirsten Beronio, NABH’s director of policy and regulatory affairs.

President Biden’s 2023 Budget Seeks to Transform U.S. Behavioral Healthcare Delivery

President Biden proposed new, mandatory investments totaling $51.7 billion over 10 years to enhance behavioral healthcare in America in the fiscal year (FY) 2023 budget proposal that he released on March 28. Among the budget blueprint’s most notable behavioral health provisions is the president’s request of $697 million for the Substance Abuse and Mental Health Services Administration (SAMHSA) to ensure that 100% of contacts are answered for the new 988 behavioral health crisis hotline that will begin to operate in July. This is an increase of $590 million from what was enacted for fiscal year 2022. Another significant provision is the president’s proposal for a new, $7.5 billion Mental Health System Transformation Fund through Medicaid to increase access to mental health services through workforce development and service expansion, including the development of non-traditional health delivery sites, the integration of quality mental health and substance use care into primary care settings, and the dissemination of evidence-based practices. NABH is pleased to see President Biden’s 2023  budget proposal calls for improving compliance with behavioral health parity standards by requiring plans and issuers to use medical necessity criteria for behavioral health services that are consistent with the criteria developed by not-for-profit medical specialty associations. The proposal would also place limits on the consideration of profit in determinations of medical necessity. The president’s budget would authorize the secretaries of the U.S. Health and Human Services, Labor, and Treasury Departments to regulate behavioral health network adequacy, and to issue regulations on a standard for parity in reimbursement rates based on the results of comparative analyses submitted by plans and issuers at a cost of $720 million over 10 years. To learn more, please read the NABH Analysis that the association sent to members earlier this week.

Senate Finance Committee Releases ‘Mental Health Care in the United States: The Case for Federal Action’

In a bipartisan report released this week, the Senate Finance Committee concluded that “overwhelmingly, access to affordable, reliable, and high-quality behavioral health care escapes Americans when they need it most” and offered some potential solutions to address the nation’s myriad behavioral healthcare challenges. The 36-page report is divided into eight chapters and examines behavioral health definitions, prevalence, and spending; workforce; children, adolescents, and young adults; access, integration, and coordination; mental health and substance use disorder (SUD) parity; telehealth; and next steps. “As Chairman of the Senate Finance Committee, I am partnering with Ranking Member Mike Crapo on a major bipartisan effort to bring behavioral health care to the forefront of the U.S. health system by leveraging the programs under this Committee’s jurisdiction, including Medicare, Medicaid, and the Children’s Health Insurance Program,” Senate Finance Committee Chairman Ron Wyden (D-Ore.) said in a letter at the start of the report. Wyden added that 10 members of this committee, including five Democrats and five Republicans, are working on policy areas that Wyden deemed “vital for a path forward.”

The Center of Excellence for Protected Health Information Video Offers Guidance about SUD Personnel and 42 CFR Part 2

The Center of Excellence for Protected Health Information (CoE-PHI) has released a video that offers guidance about when identified SUD personnel within a general medical facility must follow the federal privacy protections for SUD treatment known as 42 CFR Part 2. The Substance Abuse and Mental Health Services Administration funds CoE-PHI to help people and organizations understand and apply federal health privacy laws and regulations at work that are specific to certain tasks and roles. CoE-PHI also works to help patients and families understand their rights when seeking treatment for SUD and mental health.

MHA, American Psychological Association, and American Psychiatric Association to Host Webinar on Digital Therapeutics in Mental Health and SUD

Mental Health America, the American Psychological Association, and the American Psychiatric Association will host a webinar next Wednesday, April 6 that examines the role digital therapeutics have in addressing America’s mental health and SUD crises. Participants will learn from Meena Seshamani, M.D., Ph.D., director of the Center for Medicare at CMS; Bakul Patel, director of the Digital Health Center of Excellence at the U.S. Food and Drug Administration; and other experts in the field. The hourlong webinar will begin at 2 p.m. ET. Click here to register.

Reminder: NABH Denial-of-Care Portal is Open to Members

NABH’s Denial-of-Care Portal is available for members to provide information about their experiences with managed care organizations that impose barriers to care through insurance-claim denials. This NABH member-only, survey-like tool allows users to add the name of a managed care organization, type of plan, level of care, type of care (mental health or substance use disorder), duration of approved treatment, duration of unapproved treatment, criteria used to deny a claim, and more. The portal allows members to submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation. In time, the tool could be a valuable resource for the NABH team’s advocacy efforts. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Register Today for the 2022 Annual Meeting!

NABH will host its 2022 Annual Meeting—Shaping the Future of Behavioral Healthcare—from June 13-15 at the Mandarin Oriental Washington, DC. Please remember to register for the meeting and reserve your hotel room today!

Fact of the Week 

Of the approximately 5.9 million adults living with severe bipolar disorder in the United States in 2020, about 51%, or 3 million adults, were untreated at any given time, the Treatment Advocacy Center reports. For questions or comments about this CEO Update, please contact Jessica Zigmond.

Three-Judge Panel in 9th U.S. Circuit Court of Appeals Overturns Wit v. United Behavioral Health

In a blow to parity, a three-judge panel of the 9^th U.S. Circuit Court of Appeals this week overturned a trial court’s Wit v. United Behavioral Health (UBH) decision, asserting that UBH’s interpretation that health insurance plans do not require consistency with generally accepted standards of care (GASC) “was not unreasonable.” On Thursday, NABH sent its members an NABH Issue Brief that highlighted the following main points of the earlier decision from the trial court and the three-judge panel’s reversal of that decision in its seven-page ruling:

• The original Witdecision determined that patients’ health and safety are protected when clinicians provide services consistent with GASC that are established by not-for-profit, professional associations, rather than insurance companies whose financial incentives often conflict with what is best for patients.

• The three-judge panel said it is “not unreasonable” for health insurers’ coverage determinations to be inconsistent with GASC; however, the trial court’s decision, including two 100-page decisions, described how UBH made medical coverage decisions based on financial interests.

• In its ruling, the appellate court’s three-judge panel did not cite one holding or one fact that the trial court concluded, despite the trial court’s exhaustive trial findings.

• The trial court’s decision explained UBH’s misrepresentation to regulators that UBH used American Society of Addiction Medicine (ASAM) criteria when, in fact, the company modified and ultimately undercut the actual ASAM criteria.

• The appellate court’s three-judge panel ruled that UBH is not obligated to cover treatment consistent with GASC if the treatment is not a covered benefit; however, the plaintiffs did not argue that UBH was obligated to cover all services consistent with GASC. Instead, the plaintiffs argued that if services—such as outpatient, intensive outpatient, and residential treatment—are covered benefits, UBH must make medical necessity determinations that are consistent with GASC.

This flawed ruling has the potential to worsen America’s mental health and addiction crises as the critical need for mental health and addiction treatment services continues to rise during the ongoing Covid-19 pandemic. NABH will continue to fight for true mental health addiction treatment parity and expanded access to care for all who need it.

DEA Expands Access to Medication-Assisted Treatment for People with SUD

The U.S. Drug Enforcement Administration (DEA) on Wednesday announced a new option intended to broaden access for medication-assisted treatment (MAT) for people suffering from substance use disorder (SUD). The new option applies to DEA-registered practitioners working in hospitals, clinics, or emergency rooms, and also for DEA-registered hospitals and clinics that allow practitioners to operate under their registration number. Under this new option, the DEA will grant requests for an exception to the one-day supply limitation in 21 CFR 1306.07(b) to allow for the dispensing of up to a three-day supply of narcotic drugs, including buprenorphine and methadone, “to a person for the purpose of relieving acute withdrawal symptoms when necessary while arrangements are being made for referral for treatment.” Adhering to The Further Continuing Appropriations Act of 2021 and Other Extensions Act, DEA will grant such exception requests while it works to amend 21 CFR 1306.07(b) that the law directs. As part of this effort to save lives in the opioid overdose crisis, the DEA also announced that it is working to make permanent its Covid-19 public health emergency temporary regulations that allow for the initiation of buprenorphine to treat opioid use disorder via telemedicine. Finally, the DEA said it is partnering with the U.S. Health and Human Services Department (HHS) to engage “in regular outreach with pharmacists and practitioners to express support for the use of medication-assisted treatment for those suffering from substance use disorder.”

Provider Relief Fund Reporting Period 2 Deadline is Next Week

The Health Resources and Services Administration’s (HRSA) Provider Relief Fund (PRF) reporting portal remains open for healthcare providers who need to report their use of PRF funds in Reporting Period 2 (RP2) by the deadline next Thursday, March 31. According to HRSA, providers who received one or more payments totaling greater than $10,000 in the aggregate during a Payment Received Period must use the funds by the deadline and report for each application reporting period. HRSA’s announcement also said that providers who received PRF payments exceeding $10,000 in the aggregate between July 1, 2020 and Dec. 2020 and who do not submit a report on use of the funds by 11:59 p.m. ET on March 31, 2022 will be required to return all funds. HRSA said it will not grant grace periods or extensions. Click here to read HRSA’s PRF Reporting Non-Compliance fact sheet. 

BJA Announces Adult Drug Court Discretionary Grant Program Funding Opportunity

The U.S. Justice Department’s Bureau of Justice Assistance (BJA) is seeking applications to plan, implement, and enhance drug court services, including service coordination, management of drug court participants, and recovery support services. Adult drug courts integrated evidence-based SUD treatment, mandatory drug testing, incentives, and sanctions, and transitional services in judicially supervised criminal court setting that have jurisdiction over persons with SUD treatment needs to reduce recidivism, increase access to treatment and support, and prevent overdoses. City or township governments, county governments, federally recognized Native American tribal governments, special district governments, and state governments, and others are eligible to apply for this grant opportunity. The deadline to apply is Friday, May 20. Click here to learn more and apply.

Commonwealth Fund Podcast Examines Closing the Mental Healthcare Gap for Black Teens

In its podcast The Dose, the Commonwealth Fund this week featured Boston Children’s Hospital psychiatrist Kevin Simon, M.D., who discussed how providers can work with families to help address the mental healthcare gap for Black and brown teenagers in America. The Commonwealth Fund notes that in the current overwhelming demand for behavioral health services, the unmet need for Black and brown teenagers stands out. One reason is they are not getting the care they need due to a shortage of child and adolescent mental health providers—especially providers of color—in the United States. Worsening the problem are the racial stereotypes that exist in how school officials, healthcare providers, and others perceive Black and brown teens. Simon suggests that the country diversify the mental healthcare provider workforce to correct the problem in the long term. In the short term, he adds, providers can work with families and teachers to strengthen the system and start by demonstrating “cultural humility” and a genuine curiosity about the lived experiences of Black and brown youth.

 Reminder: NABH Denial-of-Care Portal is Open to Members 

NABH’s Denial-of-Care Portal is available for members to provide information about their experiences with managed care organizations that impose barriers to care through insurance-claim denials. This NABH member-only, survey-like tool allows users to add the name of a managed care organization, type of plan, level of care, type of care (mental health or substance use disorder), duration of approved treatment, duration of unapproved treatment, criteria used to deny a claim, and more. The portal allows members to submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation. In time, the tool could be a valuable resource for the NABH team’s advocacy efforts. Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.

Register Today for the 2022 Annual Meeting!

NABH will host its 2022 Annual Meeting—Shaping the Future of Behavioral Healthcare—from June 13-15 at the Mandarin Oriental Washington, DC. Please remember to register for the meeting and reserve your hotel room today!

Fact of the Week

Only 20% of U.S. adults received mental health treatment since the start of the Covid-19 pandemic, but 80% of those agreed they benefited from this care, the America Psychological Association reports. For questions or comments about this CEO Update, please contact Jessica Zigmond.