NABH 2026 Board Election Ballots Due Wednesday, Dec. 31

NABH asks all system members to please elect new members to the 2026 Board of Trustees by the end of this month.
 
On Dec. 9, the association e-mailed NABH system members an attachment with NABH Board of Trustees candidate profiles and a ballot to elect new members to the 2026 Board.
 
If you haven’t yet, please vote for the open NABH Board Chair-Elect position and two available Board seats; sign the ballot; scan it; and send it to nabh@nabh.org or maria@nabh.org no later than Wednesday, Dec. 31, 2025.
 
Please note your ballot is not valid without a signature. New Board members and the Board Chair-elect will take office in January 2026.

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

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

Senate Rejects Competing Healthcare Bills

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

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

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

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

CMS Issues Preliminary Guidance on Medicaid Community Engagement Requirements

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

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

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

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

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

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

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

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar next week to explore how substance use trends affect child safety and family risk factors.
 
National experts will highlight insights from the National Opioid Environmental Scan, discuss the rise of fentanyl and other substances, and offer strategies to improve outcomes for families.
 
The hourlong webinar will begin at 2 p.m. ET on Wednesday, Dec. 17. Click here to register. 

Fact of the Week

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

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

2026 Annual Meeting Schedule At-A-Glance Now Available!

This month NABH will open registration for our 2026 Annual Meeting, Future-Forward Leadership: Imagination. Innovation. Transformation, which will take place at The Ritz Carlton-Washington, DC from March 2-4, 2026.

Before then, please take a moment to review our 2026 Annual Meeting Schedule At-A-Glance, which includes times for general sessions, committee meetings, time with exhibitors and sponsors, and new breakout sessions focused on new approaches to outpatient treatment, payor issues, policy, and quality. Please note we will not host Hill Day in conjunction with the 2026 Annual Meeting.

We hope you join us, and please look for Annual Meeting updates in member alerts and upcoming issues of CEO Update!

CMS Releases CY 2026 Hospital Outpatient Prospective Payment System Final Rule

Before Thanksgiving, the Centers for Medicare & Medicaid Services (CMS) published the calendar year (CY) 2026 Hospital Outpatient Prospective Payment System (OPPS) final rule, which finalizes hospital outpatient prospective payment rates and updates Medicare payment rates for intensive outpatient program (IOP) and partial hospitalizations program (PHP) services furnished in hospital outpatient departments and Community Mental Health Centers (CMHCs).
 
For both IOP and PHP services, CMS finalized its proposal to maintain the existing rate structures and use OPPS data to calculate costs for three services per day and for four or more services per day. In addition, CMS finalized its proposal to change the methodology for calculating the CMHC IOP and PHP costs based on 40% of the final hospital-based IOP and PHP costs. This change resolves a cost inversion in CMHC cost data that would otherwise result in higher payment for three-service days than for four-service days.. The below table shows the final CY 2026 PHP and IOP per diem costs compared with the CY 2025 costs.

The final rule also includes updates to the Overall Hospital Quality Star Rating; finalizes changes to the Hospital Outpatient Quality Reporting and Rural Emergency Hospital Quality Reporting Programs; and reviews responses to a Request for Information on future measure concepts related to well-being and nutrition.

NABH Will Recommend Medicaid Community Engagement Requirements to CMS

NABH is developing recommendations to advise CMS and states about how to best implement statutory exceptions to the community engagement requirements – commonly referred to as “work requirements” – for people with mental and substance use disorders.

Passed by Congress in July, H.R. 1 exempted people with substance use disorders and disabling mental health conditions, and NABH is urging CMS to promulgate guidance and regulations that minimize disruptions in Medicaid coverage and reduce burden on providers and patients.

NABH staff held a meeting with our members this week to discuss proposed recommendations, and the NABH team is preparing a letter to CMS for NABH members to review. We expect CMS will publish preliminary guidance very soon for states seeking to implement requirements sooner than Jan. 1, 2027, the date by which H.R. 1 mandates states comply. CMS will then publish an interim final rule with detailed, binding implementation requirements by June 1, 2026.

In related news, the Kaiser Family Foundation (KFF) this week launched an interactive tool with key data and policies that will affect how states implement Medicaid community engagement requirements. KFF plans to update the tracker as CMS releases additional guidance and states begin implementation.

While NABH is focused presently on advocating for good policy with CMS, our team believes this tool will be useful for our state-based advocacy to encourage states to implement community engagement requirements that protect Medicaid access for people with mental health and substance use conditions and reduce burden for providers and patients.

Senate Democrats Introduce Plan for Healthcare Vote Next Week

Senate Minority Leader Chuck Schumer (D-N.Y.) on Thursday unveiled Democrats’ plan for a healthcare vote next week on a clean, three-year extension of the Affordable Care Act (ACA) tax credits. The Democratic bill is unlikely to garner the 60 votes needed to pass.

The ACA’s Enhanced Premium Tax Credits (EPTC) for marketplace policies expire at the end of the year, leading to significant cost increases for exchange enrollees in 2026. Senate Democrats who supported ending the government shutdown last month secured a promise from Senate Majority Leader John Thune (R-S.D.) to hold a vote on the issue next week.

Meanwhile, Senate Republicans are still considering whether to present a healthcare counterproposal to vote on next week. If such legislation is proposed, it will likely include income caps and other new restrictions.

Most GOP lawmakers in the House and Senate remain opposed to the ACA and to renewing the enhanced tax credits, which President Joe Biden and the Democratic majority created as a COVID-19 relief measure in 2021. House Speaker Mike Johnson (R-La.) has not pledged to allow a vote in the lower chamber; however, House committee chairs are working to finalize a Republican healthcare plan that could be considered next week. It would likely include various GOP bills aimed at providing more healthcare coverage options outside of the ACA. President Trump has wavered about whether to let the enhanced subsidies lapse.

Although the EPTCs are scheduled to expire Dec. 31, some Members of Congress consider the Jan. 30, 2026 expiration of the current Continuing Resolution as the next deadline for a compromise ACA bill that would be coupled with the next government funding package.

NABH will send a letter to senators and is contacting their respective offices about the ACA’s EPTCs and its effect on expanding access to behavioral healthcare.

SAMHSA to Host Webinar This Month on How Substance Use Trends Affect Child Safety

SAMHSA’s National Center on Substance Abuse and Child Welfare will host a webinar later this month to explore how substance use trends affect child safety and family risk factors.

National experts will highlight insights from the National Opioid Environmental Scan, discuss the rise of fentanyl and other substances, and offer strategies to improve outcomes for families.

The hourlong webinar will begin at 2 p.m. ET on Wednesday, Dec. 17. Click here to register. 

WHO Release Mental Health Report  

The World Health Organization (WHO) recently released guidance on policy and strategic actions to protect and promote mental health and well-being across government sectors.

Based on the premise that every sector – health, culture, arts, sports, defense, veterans, education, environment, and workforce – has a role to play in protecting and promoting mental health, the 236-page document is intended as practical roadmap for action.

”The cost of neglect is high,” the WHO cautions in the guidance. “It undermines individual well-being, family stability, societal cohesion, and economic performance. By contrast, investing in mental health delivers wide-ranging benefits, boosting economic productivity, strengthening communities, improving well-being, and building more equitable and resilient societies.”

Fact of the Week

A recent JAMA Network study of 373 participants found that a one-week social media detox intervention significantly reduced symptoms of anxiety by 16.1%, depression by 24.8%, and insomnia by 14.5%

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

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

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

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

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

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

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

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

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

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

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

Please Submit Your Updates for NABH’s Online Membership Directory

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

Fact of the Week

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

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

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

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

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

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

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

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

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

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

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

Center for Connected Health Policy Releases 2025 State Telehealth Policy Summary

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

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

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

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

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

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

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

Many Thanks to All Veterans!

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

American Foundation for Suicide Prevention Launches New Collection of Resources

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

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

CMS Instructs Medicare Administrative Contractors to Lift Claims Holds

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

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

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

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

Please Submit Updates for the NABH’s Online Membership Directory

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

Fact of the Week

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

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

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

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

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

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

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

Thank you for your time and recommendations!

CMS Releases Additional Guidance on Medicare Telehealth Services

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

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

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

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

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

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

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

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

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

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

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

Please Submit Updates for the NABH’s Online Membership Directory

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

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

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

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

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

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

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

Fact of the Week

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

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

Please Help Us Identify New NABH Board Members

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

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

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

Thank you for your time and recommendations!

Please Submit Updates for the NABH’s Online Membership Directory

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

Uncertainty Remains After Oct. 1 Telehealth Changes Arrive

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

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

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

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

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

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

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

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

HHS OIG Recommends Changing Medicare OTP Funding Methodology to Lower Expenditures

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

Digital Medicine Society Releases Blueprint for Implementing AI in Healthcare

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

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

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

Fact of the Week

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

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

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

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

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

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

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

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

States Advance Applications for the Rural Health Transformation Program

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

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

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

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

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

Fact of the Week

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

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

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

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

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

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

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

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

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

Kaiser Family Foundation Report Examines CMS’ Rural Health Fund Announcement

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

Fact of the Week

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

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

House Passes Short-Term Funding Bill

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

Senate Passes SUPPORT Act Reauthorization

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

CMS Finalizes New Provide Directory Requirements for Medicare Advantage Organizations

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

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

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

CBO Estimates $350 Billion Cost to Permanently Extend EPTC

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

Senate Confirms EBSA Nominee

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

CMS Releases Rural Health Transformation Program Funding Opportunity

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

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

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

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

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

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

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

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

Fact of the Week

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

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

Congress Faces Host of Decisions as Federal Funding Deadline Looms

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

MACPAC to Webcast Public Meeting Next Week

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

Click here to register.

Fact of the Week

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

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

NABH and Partners Push Federal Lawmakers to Address Medicaid DSH Cuts

NABH and its partner associations representing America’s hospitals and health systems on Sept. 5 sent a letter to congressional leaders urging them to address impending Medicaid disproportionate share hospital (DSH) program reductions.
 
The letter reminds House and Senate leaders: “If Congress does not act, hospitals are facing $8 billion in cuts that would be detrimental to our facilities and communities they serve.”
 
Unless Congress delays program cuts, Medicaid DSH payment reductions will begin Oct. 1, 2025.

CMS Provides Details on H.R. 1’s Rural Health Transformation Program

The Centers for Medicare & Medicaid Services (CMS) has posted information about the Rural Health Transformation Program (RHT), for which H.R. 1 (the One Big Beautiful Bill Act) has provided $50 billion to be allocated to states over the next five fiscal years starting in 2026 and ending in 2030.
 
According to CMS, $10 billion in funding will be available each year, with 50% of it going to approved states. CMS will allocate the remaining 50% based on a variety of factors, including rural population, the proportion of rural health facilities in the state, the situation of certain hospitals in the states, and other factors that CMS said it will specify in the Notice of Funding Opportunity, or NOFO.
 
The CMS announcement said applications are due in “early November” and didn’t specify a date. The agency also said application instructions to apply for RHT funding will be included in the NOFO and released on www.grants.gov by mid-September. CMS will determine awards by Dec. 31, 2025.

CMS to Host Webinar on Medicaid & CHIP Policy for a Behavioral Health Coordinated System of Crisis Care

CMS will host a 90-minute webinar next week to discuss Medicaid and the Children’s Health Insurance Program (CHIP) policy related to a behavioral health coordinated system of crisis care.
 
The webinar is intended for state Medicaid staff and others involved in crisis-service initiatives in the states. Please share the information with anyone who might be interested.
 
Click here for registration information about the webinar on Wednesday, Sept. 10 starting at 2 p.m. ET.

KFF to Examine How States Will Implement Medicaid Work Requirements in Sept. 11 Webinar

The Kaiser Family Foundation next week will host a webinar to explore how states will implement the new Medicaid work requirements that this summer’s budget reconciliation package mandated.
 
The webinar will feature four panelists, including two state Medicaid directors, in an hourlong discussion that will address issues such as how much it will cost states and the federal government to implement work requirements; whether states will be able to meet the Dec. 31, 2026 implementation deadline; how states will use or improve “data matching” to automate verifying work activities, hours, and exemptions; and what states are looking for in forthcoming federal guidance.
 
Click here to register for the webinar that starts at Noon ET on Thursday, Sept. 11.

Reminder: Manatt to Host Webinar on Scaling Telehealth to Manage Healthcare Workforce Challenges

Research firm Manatt will host a webinar titled “Scaling Telehealth and Other Emerging Technologies to Mitigate the Health Care Workforce Crisis” next week.
 
The hourlong, interactive webinar will discuss developing a framework for considering how digital health can alleviate healthcare workforce challenges; how to adopt AI to enhance telehealth workflows; and why broader policy and industry changes are needed to attract, optimize, and retain healthcare professionals.
 
The webinar will take place on Wednesday, Sept. 10 starting at 2:30 p.m. ET. Click here to register and here to read a related white paper on the topic from Manatt and the Medical University of South Carolina.

ICYMI: NABH Welcomes Sarah Steverman, Ph.D., M.S.W. as Vice President of Regulatory Affairs, Quality, and Compliance

NABH on Aug. 25 welcomed Sarah M. Steverman, Ph.D., M.S.W. as the association’s new vice president of regulatory affairs, quality, and compliance.
 
Sarah comes to NABH from HHS’ Office of the Assistant Secretary for Planning and Evaluation (ASPE), where she supported behavioral health policy research and coordination as a social science research analyst. Before joining ASPE, Sarah served as a social behavioral scientist administrator at the National Institute on Drug Abuse’s Prevention Research Branch, where she focused on prevention research in healthcare settings and research on policies and environmental strategies to prevent substance misuse.
 
Prior to her work in government service, Sarah worked at Abt Associates, where she specialized in behavioral health policy, research, and dissemination of evidence-based interventions. She has also served as a public health analyst at the Substance Abuse and Mental Health Services Administration (SAMHSA) and led policy efforts at Mental Health America and the National Conference of State Legislatures.
 
Sarah began her career working in direct service with individuals with co-occurring substance use and mental health conditions. She earned both her master’s and doctoral degrees at Catholic University of America.
 
At NABH, Sarah is responsible for developing regulatory solutions and policy recommendations that support and promote quality behavioral healthcare services nationwide. She will monitor legislation and regulations that affect the behavioral healthcare industry and provide strategic direction about essential programs and initiatives in the federal regulatory environment and will focus on advancing the association’s public policy priorities. Sarah will also manage the association’s Quality Committee and Behavioral Health Services within General Healthcare Systems Committee.

Fact of the Week

A new study published in Health Affairs show that fewer than one in three adolescents with past-year opioid use disorder received substance use treatment in 2022-2023.

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

NABH Welcomes Sarah Steverman, Ph.D., M.S.W. as Vice President of Regulatory Affairs, Quality, and Compliance

This week NABH welcomed Sarah M. Steverman, Ph.D., M.S.W. as the association’s new vice president of regulatory affairs, quality, and compliance.
 
Sarah comes to NABH from HHS’ Office of the Assistant Secretary for Planning and Evaluation (ASPE), where she supported behavioral health policy research and coordination as a social science research analyst. Before joining ASPE, Sarah served as a social behavioral scientist administrator at the National Institute on Drug Abuse’s Prevention Research Branch, where she focused on prevention research in healthcare settings and research on policies and environmental strategies to prevent substance misuse.
 
Prior to her work in government service, Sarah worked at Abt Associates, where she specialized in behavioral health policy, research, and dissemination of evidence-based interventions. She has also served as a public health analyst at the Substance Abuse and Mental Health Services Administration (SAMHSA) and led policy efforts at Mental Health America and the National Conference of State Legislatures.
 
Sarah began her career working in direct service with individuals with co-occurring substance use and mental health conditions. She earned both her master’s and doctoral degrees at Catholic University of America.
 
At NABH, Sarah is responsible for developing regulatory solutions and policy recommendations that support and promote quality behavioral healthcare services nationwide. She will monitor legislation and regulations that affect the behavioral healthcare industry and provide strategic direction about essential programs and initiatives in the federal regulatory environment and will focus on advancing the association’s public policy priorities. Sarah will also manage the association’s Quality Committee and Behavioral Health Services within General Healthcare Systems Committee.

CMS Releases 2022 T-MSIS Behavioral Health Data Book

The Centers for Medicare & Medicaid Services (CMS) has released its 2022 Transformed Medicaid Statistical Information System (T-MSIS) Behavioral Health (BH) Data Book and accompanying static tables pursuant to Section 202 of the Consolidated Appropriations Act (CAA), 2024 (CAA, 2024; P.L. 118-42).
 
The resource is a publicly available compendium of the number of Medicaid and Children’s Health Insurance Program beneficiaries with a substance use disorder (SUD) or a mental health (MH) condition and the services they received. The report catalogs the treatment of SUD and MH in the Medicaid and CHIP beneficiary population and services provided for the treatment of SUD and MH under Medicaid and CHIP. 

SAMHSA Announces $19 Million to Improve Housing Capacity for Homeless Persons with SMI

SAMHSA this week announced $19 million in supplemental funding through the Community Mental Health Services Block Grant to strengthen the nation’s housing capacity for homeless persons with serious mental illness (SMI).
 
“Addressing homelessness for people with serious mental illnesses requires improved coordination and partnerships nationwide,” SAMHSA Principal Deputy Assistant Secretary Art Kleinschmidt, Ph.D., M.B.A., said in an announcement about the funding. “This investment will help build data-driven capacity at the state and local level and is critical to make our communities safer and healthier.”
 
According to SAMHSA, this supplemental funding provides an opportunity for states to align public health, housing, and justice systems in order to reduce homelessness and improve outcomes for individuals with SMI. The funding will help states build capacity and promote collaboration across systems, with a particular focus on addressing the intersection of homelessness and SMI.

NYC Health & Hospitals to Launch Contingency Management Pilot in 2026

NYC Health & Hospitals will launch a pilot Contingency Management (CM) program next year to patients who are treated for substance use disorder, Politico reported this week.
 
According to the story, the pilot will test CM at Lincoln, Elmhurst, and Bellevue Hospitals, where officials expect to reach hundreds of patients each year. The program is expected to expand citywide to serve about 1,000 patients annually, the story said.
 
Please remember to read and share NABH’s CM fact sheet.

Manatt to Host Webinar on Scaling Telehealth to Manage Healthcare Workforce Challenges

Research firm Manatt will host a webinar titled “Scaling Telehealth and Other Emerging Technologies to Mitigate the Health Care Workforce Crisis” next month.
 
The hourlong, interactive webinar will discuss developing a framework for considering how digital health can alleviate healthcare workforce challenges; how to adopt AI to enhance telehealth workflows; and why broader policy and industry changes are needed to attract, optimize, and retain healthcare professionals.
 
The webinar will take place on Wednesday, Sept. 10 starting at 2:30 p.m. ET. Click here to register and here to read a related white paper on the topic from Manatt and the Medical University of South Carolina.

Fact of the Week

Three major AI chatbots — ChatGPT, Claude, and Gemini — generally respond appropriately to questions about suicide when those queries are especially benign or dangerous; however, there is still some fine-tuning needed, especially when it comes to questions that lay somewhere in the middle, according to a new RAND study.  For more information about this topic, please see this article from The Wall Street Journal and this story from The New York Times.

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

New JAMA Study Shows ED Boarding is a ‘Considerable Issue’ for Medicaid-Enrolled Youth

A new study published in JAMA shows that emergency department (ED) boarding is a “considerable issue” for Medicaid-enrolled youth, with more than one in 10 mental health-related ED visits lasting more than two days. The findings also showed that in five states, boarding occurred in more than one in five in such visits.
 
Medicaid covers more than 35 million children and youth – nearly half of all youth in the United States – and this study investigated prevalence and variations in boarding for youth ED visits in 2022.
 
“Boarding poses a substantial emotional toll on patients, families, and staff; it also may result in challenges related to patient and staff safety and restraint use, and it suggests an inability to find timely and appropriate care for youths in crisis,” the study noted. “The high levels of boarding observed in our study and the substantial state-level variation should warrant concern, particularly given evidence that boarding can lead to care delays, clinical deterioration, and increased costs— outcomes that may disproportionately affect low-income children who face systemic barriers to timely and coordinated behavioral healthcare.”

GAO Report Shows HHS Tops Federal Agencies for Most AI Use

A recent study from the Government Accountability Office (GAO) analyzed 11 selected federal agencies with artificial intelligence (AI) inventories and found the total number of reported AI use cases nearly doubled to 1,110 in 2024 from 571 in 2023. At the same time, generative AI use cases increased about nine-fold, to 282 from 32.
 
HHS led the pack with 116 different ways the federal health agency used AI for generating content and responses in 2024, up from seven ways in 2023.
 
On a related note, the think tank The Bipartisan Policy Center published a report last week that shows how three HHS agencies have implemented AI and that they’re mostly using chatbots to help them work more efficiently.

SAMHSA to Host Eating Disorders & Suicide Webinar Next Week

The Substance Abuse and Mental Health Services Administration’s (SAMHSA) Eating Disorder Center of Excellence will host an hourlong webinar to discuss the relationship between eating disorders and suicide next Thursday, Aug. 28 starting at 1 p.m. ET.
 
Jean Doak, Ph.D., a licensed psychologist and clinical director of the UNC Center of Excellence for Eating Disorders, and Jeff Greenberg, director of SAMHSA’s Eating Disorder Center of Excellence, will host the webinar that will emphasize the importance of early identification and intervention. The webinar will also outline risk factors, warning signs, and co-occurring conditions such as mood disorders that heighten suicide vulnerability in patients with anorexia, bulimia, and binge eating.
 
Click here to register.

SAMHSA’s National Recovery Month Toolkit Available Now

SAMHSA has released its annual toolkit for National Recovery Month that begins on Sept. 1.
 
Started in 1989, National Recovery Month is observed every September to promote and support new evidence-based treatment and recovery practices. This year’s theme is Recovery is REAL (Restoring Every Aspect of Life).
 
Click here for the toolkit, which includes social media messages, graphics, and promotional materials for various audiences. Remember to include #RecoveryMonth when sharing any Recovery Month-related content.

Reminder: HHS Announces Funding Opportunity for Behavioral Health IT Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due next Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

Nearly two-thirds (65%) of college students with autism suffer from anxiety, compared with just more than 9% of their peers without autism, according to a new study in the Journal of Autism and Developmental Disorders. The findings also show that nearly half (48%) report depression, compared with 8% of their peers.

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

Manhattan Institute Publishes Report on Psychiatric Hospitals and the IMD Exclusion

The Manhattan Institute released a report yesterday assessing the current landscape of freestanding psychiatric hospitals amidst Medicaid’s Institution for Mental Diseases (IMD) exclusion and identifying opportunities for policy reform, including repeal of the exclusion.
 
NABH provided information to the author to inform the report’s content, and NABH publications were cited.
 
The report emphasizes that modifying the IMD exclusion is needed to ensure the financial sustainability of psychiatric hospitals and address the significant unmet need for care among Medicaid beneficiaries with serious mental illness. “Prohibiting reimbursement for treatment in psychiatric hospitals—without any clinical justification—exposes hospitals to financial losses from uncompensated care, a risk that becomes unavoidable as hospitals grow beyond 16 beds.”

District Court Issues Order Favorable to Beneficiaries in Wit vs. United Behavioral Health

On Aug. 5, a judge in the U.S. District Court for the Northern District of California issued an order favorable to the plaintiffs, health insurance beneficiaries who sued United Behaioral Health (UBH) alleging that the company improperly denied coverage for behavioral healthcare services.
 
In a landmark ruling in 2019, the District Court found that UBH violated its responsibilities to beneficiaries by imposing medical necessity criteria that misaligned with generally accepted standards to protect its own interests.
 
However, upon appeal by UBH, the U.S. Ninth Circuit Court of Appeals partially reversed the initial decision and sent the case back to the District Court for further consideration of whether plaintiffs’ breach of fiduciary duty claims are distinct from denial of benefits claims, the latter of which the Appeals Court ruled in favor of UBH.
 
The latest order affirms that they are distinct, specifically with respect to breaches of the fiduciary duties of loyalty and due care.
 
The case will now proceed to remedies and final judgment.

Sen. Grassley Introduces Bill to Disclose IPF Accreditation Survey Information

Sen. Chuck Grassley introduced the Psychiatric Hospital Inspection Transparency Act of 2025, which would require the U.S. Department of Health and Human Services (HHS) to make public information from psychiatric hospitals’ accreditation surveys that helps “health care consumers to make informed decisions regarding where to receive health care.”
 
The bill directs HHS to work with accreditation organizations and psychiatric hospitals to determine the type of information that is appropriate to disclose and how this information is presented to the public.
 
The bill also provides HHS the authority to publicly disclose full accreditation surveys of psychiatric hospitals.
 
NABH has conveyed significant concerns with disclosure of accreditation surveys to Sen. Grassley’s staff, underscoring the importance of confidentiality to facilitate quality improvement activities between facilities and accreditors, and the potential for this information to mislead consumers.

HHS Releases Report on Youth Psychiatric Medication Prescribing

HHS issued a report describing national trends in psychiatric medication dispensing to youth aged 3-17 between 2006 and 2023.
 
The largest change in proportion of youth receiving a medication was for selective serotonin reuptake inhibitors, which rose from 1.5% to 3.6%. Meanwhile, gradual reductions occurred for antipsychotics (1.3% to 1.1%) and mood stabilizers (1% to 0.8%), and there was a slight increase for stimulants (5% to 5.3%).
 
The trends for antipsychotics and mood stabilizers are opposite to adults, who experienced a steady increase during this period.

GAINS Center to Host Webinar Next Week on Supporting Service Members & Veterans in Criminal Justice Settings

The GAINS Center at the Substance Abuse and Mental Health Services Administration (SAMHSA) and SAMHSA’s Service Members, Veterans, and Their Families Technical Assistance Center will host a national webinar titled Supporting Justice-Involved Service Members and Veterans Through Early Interventions in Criminal Justice Settings on Tuesday, Aug. 19 from 1 p.m. to 2:30 p.m. ET.
 
The webinar will explore the Sequential Intercept Model, focusing on Intercepts 0 and 1, and its application to justice-involved service members, including active duty, Guard/Reserve, and retired military populations. Identifying and engaging individuals early at their intersection with behavioral health or criminal justice systems plays a critical role in achieving successful outcomes.
 
Click here to register.

Reminder: HHS Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

The U.S. Food and Drug Administration (FDA) has asked the U.S. Justice Department to classify 7-OH, a compound from the kratom plant with opioid-like effects found in unregulated tablets, gummies, and drink mixes sold in gas stations and convenience stores, as an illicit substance.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

RFK Jr. Says HHS Will Move Forward with HHS Reorganization

The publication Inside Health Policy this week reported that U.S. Health and Human Services Department (HHS) Secretary Robert F. Kennedy, Jr. said HHS will move forward with its plan to reorganize its agencies even though Senate appropriators omitted the proposed reorganization from the Senate Appropriations Committee’s funding bill.
 
According to the story, the bipartisan HHS funding bill that advanced last week does not include any language to create a new “Administration for a Healthy America,” or AHA, as HHS did not submit a formal reorganization plan to Congress and allow for six months of consideration, a spokesperson for Senate Appropriations Committee Chair Susan Collins (R-ME) told Inside Health Policy. AHA would combine multiple current agencies, including the Agency for Toxic Substances and Disease Registry, Health Resources and Services Administration, National Institute for Occupational Safety and Health, Office of the Assistant Secretary for Health, and Substance Abuse and Mental Health Services Administration (SAMHSA).
 
HHS has said the reorganization centralizes functions including human resources, information technology, procurement, external affairs and policy in single offices, as well as reduces the number of regional offices from 10 to five.

In addition to AHA, the planned reorganization would merge the Administration for Strategic Preparedness and Response into the Centers for Disease Control and Prevention (CDC); merge the office of Assistant Secretary for Planning and Evaluation with the Agency for Healthcare Research and Quality as a new Office of Strategy; and move to the functions of the Administration for Community Living to other agencies, including the Centers for Medicare & Medicaid Services (CMS).

SAMHSA Releases Behavioral Health Workforce Self-Care Fact Sheet

SAMHSA this week released Taking Care: Promoting Well-being for Recovery and Behavioral Health Care Providers, which includes resources and tips for the nation’s behavioral health workforce.
 
“Recent definitions suggest that self-care is inherently community-centered,” the resource notes. “There is a growing shift toward regarding self-care as a workplace focus that amplifies the need for collective practices and workplace well-being,” it continued. “Varying definitions of self-care emphasize the importance of valuing individualized approaches that are historically rooted, healing-centered, trauma-informed, holistic, ecological, and culturally nurtured.”
 
SAMHSA’s new fact sheet emphasizes that wellness involves purpose in life, active involvement in satisfying work and play, joyful relationships, a healthy body and living environment, and happiness.

ICYMI: CMS Finalizes 2.4% Payment Increase to IPFs in FY 2026

CMS will apply a 2.4% payment increase to inpatient psychiatric facilities in 2026, according to the Fiscal Year (FY) 2026 Inpatient Psychiatric Facility (IPF) Prospective Payment System final rule the agency released Aug. 1 in the Federal Register.

The final rule also includes a slight increase in the outlier threshold as well as increases to the teaching and rural facility adjustments.

For the IPF Quality Reporting program, CMS will remove four quality measures: Facility Commitment to Health Equity, COVID-19 Vaccination Coverage Among Healthcare Personnel, Screening for Social Drivers of Health, and Screen Positive Rate for Social Drivers of Health.

The rule also noted CMS will modify the reporting period from one to two years for the 30-day Risk-Standardized All Cause Emergency Department Visit Following an IPF Discharge measure and will delay its initial use to the FY 2029 payment determination.

These changes align with the agency’s proposed rule. Click here for a summary of provisions that take effect on Oct. 1, 2025.

Reminder: CMS Seeking Participants for Hospital Price Transparency Virtual Listening Session: Monday, Aug. 11

CMS is seeking hospital and health system representatives to attend a Hospital Price Transparency (HPT) consumer-friendly display listening session with CMS staff to help the agency better understand how to empower consumers with accessible and actionable pricing information and make more meaningful price comparisons.
 
This session will focus solely on the HPT program’s consumer-friend display requirement, and staff from the federal contractor MITRE will ask several questions about the consumer-friendly format functionality, including required standard data elements to enhance comparability, number and type of services of most interest, patient interaction with the consumer-friendly display, and the intersection with other programs, such as the Transparency in Coverage and No Surprises Act.
 
The listening session will be held on Monday, Aug. 11 from 12:30 p.m. to 2 p.m. ET. Please contact MITRE_HPT@mitre.org if you want to participate.

Reminder: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

CDC has launched Free Mind, a national campaign that provides youth ages 12-17 and their parents and caregivers with information and resources about substance use, mental health, and the connection between the two.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Congress Advances Legislation for Veterans’ Healthcare Services

Congress this week continued to focus on the Veterans Affairs (VA) Community Care Network by advancing several Community Care-focused bills and the Senate FY 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act to increase funding levels for the Community Care Network.
 
Both the House and Senate committees that oversee veterans’ care advanced bills that would expand access to community care for veterans while standardizing and improving VA mental health programs.
 
The Veterans’ Assuring Critical Care Expansions to Support Servicemembers Act of 2025 (ACCESS)(S. 275 | H.R. 740), introduced in the Senate by Senate VA Committee Chairman Jerry Moran (R-Kan.) and in the House by House VA Committee Chairman Mike Bost (R-Ill.), would codify standards for veterans to receive community-based care that cannot be provided by the VA with a primary care, mental health care, or extended care appointment within a 30-minute drive or within 20 days or Veterans with a specialty care appointment within an hour’s drive or within 28 or fewer days.
 
The bill also requires the VA Department to create a “standardized screening process” for veterans to participate in mental health treatment programs; develop a three-year pilot program allowing veterans to access mental health and/or substance use disorder programs in the community without a referral; and establish tracking on wait times and care availability for mental health programs, among other improvements. Both bills are pending full consideration on the House and Senate floors.
 
In addition to The ACCESS Act, the Senate Veterans Affairs Committee passed 24 pieces of legislation to improve the lives of veterans, caregivers, and survivors nationwide. These bills include the Veterans Mental Health and Addiction Therapy Quality of Care Act and External Provider Scheduling Program Act.

S.702, Sen. John Cornyn’s (R-Texas) The Veterans Mental Health and Addiction Therapy Quality of Care Act, requires the VA Department to seek to enter into an agreement with an independent and objective organization outside the VA to conduct a study on the quality-of-care differences between mental health and addiction therapy care that VA healthcare providers offer compared with non-VA providers across various modalities, such as telehealth, in-patient, intensive out-patient treatment, and residential treatment.

And S. 654, The External Provider Scheduling Program Act – also from Sen. Jerry Moran (R-Kan.) – amends title 38 of the United States Code to establish an external provider scheduling program that would assist the VA Department in scheduling appointments for care and services under the Veterans Community Care Program. The program must consist of technology that allows VA schedulers to view the schedules of healthcare providers participating in the program and schedule, in real-time, appointments for such care.
 
Also last week the Senate Appropriations Committee also passed the FY 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act, which included a notable 50% increase compared with the FY2024 enacted level for community care. This increase elevates community care funding to $33 billion, up from $22 billion in FY2024. This is similar to levels the House Appropriations Committee passed in July. Senate leaders and appropriators are now trying to agree on a three-or-four bill package deal of FY2026 government funding bills, including for military construction and VA, with the goal of voting on the measure when lawmakers return from their August recess.

SAMHSA Releases 2024 National Survey on Drug Use

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released the results of its 2024 National Survey on Drug Use and Health (NSDUH), which offers a national view of behavioral health based on self-reported responses from nearly 70,000 people
 
2024 marks the first year since 2020 in which there are at least four years of comparable data for key NSDUH outcomes, adjusting for survey design changes since 2020 and enabling trend reporting for the first time since 2019.
 
The results showed that among adults 18 and older, the percentage who had any mental illness (AMI) or serious mental illness (SMI) in the past year showed no change from 2021 to 2024. Among U.S. adolescents aged 12 to 17, the percentage who had serious thoughts of suicide in the past year declined to 10.1% in 2024 from 12.9% in 2021.
 
Meanwhile, the survey showed mixed results on substance use outcomes, as prescription opioid misuse among people 12 or older declined to 2.6% in 2024 from 3.0% in 2021 and marijuana use in that same age group increased to 22.3% in 2024 from 19.0% in 2021.

CMS Seeking Participants for Hospital Price Transparency Virtual Listening Session: Aug. 11

The Centers for Medicare & Medicaid Services (CMS) is seeking hospital and health system representatives to attend a Hospital Price Transparency (HPT) consumer-friendly display listening session with CMS staff to help the agency better understand how to empower consumers with accessible and actionable pricing information and make more meaningful price comparisons.
 
This session will focus solely on the HPT program’s consumer-friend display requirement, and staff from the federal contractor MITRE will ask several questions about the consumer-friendly format functionality, including required standard data elements to enhance comparability, number and type of services of most interest, patient interaction with the consumer-friendly display, and the intersection with other programs, such as the Transparency in Coverage and No Surprises Act.
 
The listening session will be held on Monday, Aug. 11 from 12:30 p.m. to 2 p.m. ET. Please contact MITRE_HPT@mitre.org if you want to participate.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

Among adolescents aged 12 to 17, the percentage who had a major depressive episode in the past year declined to 15.4% in 2024 from 20.8% in 2021, according to SAMHSA’s latest annual survey on drug use and health.

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

Reps. Tonko & Huizenga Introduce Legislation to Remove Medicare’s 190-day Lifetime Limit

Reps. Paul D. Tonko (D-N.Y.) and Bill Huizenga (R-Mich.) this week reintroduced H.R. 4619, the Medicare Mental Health Inpatient Equity Act, bipartisan legislation that would repeal permanently the Medicare program’s 190-day lifetime limit for inpatient psychiatric care.
 
Despite the enactment of the landmark Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act in 2008, Medicare continues to discriminate against seniors with mental illnesses through this provision. The 190-day lifetime limit in care disproportionately harms individuals who receive Medicare coverage earlier in life due to disability.
 
In its March 2025 report, the Medicare Payment Advisory Commission (MedPAC), the independent agency that advises Congress about the Medicare program, recommended that lawmakers eliminate Medicare’s 190-day lifetime limit.
 
More than three dozen organizations, including NABH, support this critical legislation, which has been referred to the House Ways and Means Committee.
 
“The National Association for Behavioral Healthcare applauds Reps. Paul Tonko (D-N.Y.) and Bill Huizenga (R-Mich.) for reintroducing the Medicare Mental Health Inpatient Equity Act,” NABH President and CEO Shawn Coughlin said in a statement. “We also thank the bill’s original cosponsors Reps. Lloyd Doggett (D-Texas) and Brian Fitzpatrick (R-Pa.). This bipartisan legislation will bring us closer to mental health parity by eliminating Medicare’s 190-day lifetime limit for inpatient psychiatric hospital services, regardless of a patients’ needs,” Coughlin continued. “Experts agree that demand for inpatient care for individuals with the most difficult-to-treat behavioral health conditions far outstrips supply, and denying care can lead to many adverse consequences if those conditions are not addressed. Congress should align with the Medicare Payment Advisory Commission’s unanimous recommendation to eliminate Medicare’s 190-day lifetime limit,” he added. “NABH looks forward to working with the bill’s sponsors to pass this legislation.”
 
NABH applauds Reps. Tonko, Huizenga, Doggett and Fitzpatrick for supporting legislation that would remove a lifetime limit on care that does not exist for any other inpatient healthcare service that Medicare covers, and our team is asking Members of Congress to cosponsor H.R. 4619.
 
We will also issue an Action Alert to you, our members, asking that you contact your congressional representatives and request that they cosponsor this bill. Thank you for your help!

Lawmakers Reintroduce ‘Medicaid Bump Act’ to Increase Reimbursement Rate for Behavioral Healthcare Services

Also this week, Reps. Tonko and Fitzpatrick in the House and Sen. Tina Smith (D-Minn.) in the Senate reintroduced the Medicaid Bump Act, companion legislation that would increase Medicaid’s federal reimbursement rate for mental and behavioral healthcare services.
 
Traditionally, states receive federal reimbursement rates between 50% and 75%. Under the Medicaid Bump Act, Medicaid would reimburse states for 90% of the cost of providing new mental and behavioral healthcare services.
 
In addition, the bill would direct the HHS secretary to define which services qualify as eligible behavioral healthcare services for the enhanced FMAP and require HHS to provide annual reports about the effects of increased federal Medicaid reimbursement on the use of behavioral healthcare services in each state.
NABH is one of 34 organizations that supports the Medicaid Bump Act.
 
Bill numbers have not been assigned to the Medicaid Bump Act; however, the legislation has been referred to the House Energy and Commerce and Senate HELP Committees.

Trump Signs Executive Order to Push Cities to Move Homeless Persons from Streets to Treatment Centers

President Trump on Thursday signed an executive order to push cities and states to remove homeless people from the streets and into treatment centers.
 
The order, “Ending Crime and Disorder on America’s Streets,” directs U.S. Attorney General Pam Bondi to reverse precedents that limit state and local governments’ ability to commit people on the streets who are at risk to themselves or others, according to a fact sheet that The Hill newspaper obtained.
 
USA Today first reported on the order, which also requires interagency work on grants for states to enforce prohibitions on open, illicit drug use, urban camping, loitering and squatting, and to track sex offenders. It also requires redirecting funds to ensure people sleeping on streets and causing public disorder – and suffering from serious mental illness or substance use disorder – are moved to treatment centers, although it’s unclear how much federal funding will be allocated for it.
 
It is part of Trump’s commitment to ending homelessness, according to the fact sheet, and follows a March order that directed the National Park Service to clear homeless encampments and graffiti on federal lands.

Blue Cross Blue Shield Provider Settlement Claim Deadline is Next Tuesday, July 29

A landmark class action antitrust settlement addressing claims that Blue Cross Blue Shield (BCBS) suppressed competition and underpaid providers through its BlueCard Program, according to a BCBS notice.
 
The notice states that those who provided healthcare services, equipment, or supplies to BCBS-insured patients between July 24, 2008, and Oct 4, 2024 may be eligible to receive a portion of this historic settlement.
 
Most U.S. providers who treated BCBS-insured patients during the settlement period qualify, unless employed/owned by BCBS or exclusively by government entities, or limited to specific services (e.g., prescription drugs, standalone dental/vision). Compensation will be based on your BCBS reimbursement amounts, adjusted for estimated antitrust impact.
 
The deadline to submit a claim is Tuesday, July 29. Click here for more information.

Senate Confirms Terry Cole as DEA Administrator

In a party-line vote of 50-47, the Senate this week confirmed Terry Cole to lead the U.S. Drug Enforcement Administration (DEA).
 
Cole’s job will include enforcing the Trump administration’s approach to marijuana rescheduling, which started during the Biden administration and is now uncertain. Advocates for marijuana rescheduling argue it would allow for more research into cannabis and its health effects.
 
Most recently Cole served as Virginia’s secretary of public safety from 2023-2025. Previously he spent 22 years at DEA, which included service in various states and on foreign missions in Colombia, Afghanistan, Mexico and the Middle East.
 
Cole earned his bachelor’s degree from the Rochester Institute of Technology and certificates in leadership from the University of Virginia and the Medoza College of Business at the University of Notre Dame.

Provider Resource: ‘After Your Child’s Suicide Attempt’ Video

The Education Development Center’s Zero Suicide Institute and Parents to Parents, a not-for-profit organization that offers resources to caregivers whose child is struggling with mental health illness, have created After Your Child’s Suicide Attempt, an hourlong movie that addresses the questions parents have and describes best practices in suicide care.
 
The two organizations urge healthcare professionals, school, and community leaders to share the video and accompanying resources with parents.   

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Fact of the Week

The 988 Lifeline stopped specialized services for LGBTQ+ youth this week. Since 988 launched three years ago, it has fielded more than 16 million calls, texts and chats, with nearly 10% of those contacts from gay and transgender young people, according to government data. Meanwhile, data from the Centers for Disease Control and Prevention’s Youth Behavior Risk Survey show that LGBTQ+ youth are more likely to experience persistent feelings of sadness and hopelessness compared with their peers, and they are more likely to attempt suicide.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

CMS Releases CY 2026 Outpatient Prospective Payment System Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) on Tuesday, July 15 released its Calendar Year 2026 Outpatient Prospective Payment System (OPPS) proposed rule along with an accompanying fact sheet.

In it, CMS proposed to increase payment rates by 2.4%, reflecting an inpatient market basket increase of 3.2% minus a productivity adjustment of 0.8 percentage point.
 
The agency also proposed collecting hospitals’ median negotiated payer-specific charges with Medicare Advantage organizations by Medicare Severity Diagnosis Related Groups (MS-DRGs), which would be used to inform changes to the Inpatient Prospective Payment System MS-DRG relative weights beginning in Fiscal Year 2029.
 
Other changes specific to behavioral healthcare services are largely limited to partial hospitalization programs (PHPs) and intensive outpatient programs (IOPs) delivered by community mental health centers, for which CMS proposes modifying the payment rate methodology to be 40% of the corresponding hospital-based rates to promote payment accuracy and stability. Meanwhile, the payment rate methodology for hospital-based PHPs and IOPs would remain the same.
 
NABH continues to review the OPPS proposed rule. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.

CMS Proposes Broader Medicare Coverage of Select Behavioral Health Services in CY 2026 Physician Fee Schedule

CMS also released its CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule and accompanying fact sheet earlier this week.
 
The agency CMS estimates that the proposed policy changes would, on average, affect allowed charges for behavioral health specialists as follows:

• Psychiatrists: +6% (non-facility), -9% (facility)
• Clinical psychologists: +5% (non-facility), -3% (facility)
• Clinical social workers: +6% (non-facility), -2% (facility)

These changes can be attributed to broader modifications to reimbursement calculation, such as practice expense methodology changes to capture increased indirect costs of non-facility practitioners, and a higher conversion factor for practitioners participating in a qualifying alternative payment model (+3.83%) compared with those who are not (+3.62%).

NABH is pleased to see the proposed rule aims to improve coverage of certain behavioral healthcare services in various ways, such as creating three optional add-on codes to advanced primary care management that would better enable the provision of behavioral health integration and collaborative care model services; expanding coverage of digital therapeutics to include those to treat attention-deficit/hyperactivity disorder; and permitting clinical social workers, marriage and family therapists, and mental health counselors to bill for community health integration services.
 
CMS is also seeking public comment on the possible expansion of coverage of motivational interviewing; and potential changes to the query of prescription drug monitoring program quality measure, including transitioning the measure from attestation- to performance-based, and expanding the scope of the measure to include Schedule II non-opioids.
 
NABH continues to review the PFS proposed rule and will solicit feedback from members soon. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.

MedPAC Releases 2025 Data Book on Medicare Spending

The Medicare Payment Advisory Commission (MedPAC) has released its 2025 data book, which provides data on Medicare spending, demographics of the Medicare population, beneficiaries’ access to care, and quality of care in the program, among other information.
 
Click here to see the book’s section about acute inpatient services, which includes data about inpatient psychiatric facilities.

ICYMI: CHCS Webinar on Medicaid Innovation to Improve Behavioral Healthcare Access

The Center for Health Care Strategies this week hosted Medicaid Innovation in Improving Access to Behavioral Health Care, 75-minute webinar featuring state leaders from Colorado, Massachusetts, and Wyoming who discussed how they are tackling behavioral healthcare challenges and using Medicaid policy to improve access to high-quality care in their states.
 
Panelists explored how states can expand access, improve coordination, and modernize behavioral healthcare through cross-sector partnerships, workforce development, cross-agency data sharing, and integrated approaches to care.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
 
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
 
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT) compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.
 
The deadline to respond to the RFI is Monday, July 21.

Fact of the Week

Psychiatric recommendations from four large language models (LLMs) – AI programs designed to understand and generate human language – changed when a patient’s record noted they were African American, researchers recently reported in the journal NPJ Digital Medicine.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

Senate Faces Additional Obstacles to Passing its Reconciliation Bill

The pathway for the Senate to pass its budget reconciliation bill became more precarious this week, following increased opposition to Medicaid cuts by a growing number of senators and the Senate parliamentarian’s determinations that several key provisions violate the Byrd rule, meaning they require 60 votes to pass the Senate instead of a simple majority.
 
Provisions deemed to violate the Byrd rule include the proposed reduction in the permissible state provider tax threshold from 6% to 3.5%, limits to federal financial participation in Medicaid for states that offer coverage to non-citizens, and others. Republicans will now have to rewrite or remove these sections of the bill, which were estimated to collectively save hundreds of billions of dollars.
 
The parliamentarian’s determinations come as Senate Republican leaders and President Trump are trying to win over wavering GOP senators to support the Senate bill. Various senators are also proposing a $15 billion stabilization fund to mitigate the bill’s impacts on rural hospitals.
 
Majority Leader Thune is still holding out hope for an initial procedural vote today, followed by an overnight vote-a-rama rolling into a final vote on Saturday. The bill would then go to the House for a vote, though many Republicans there have concerns with the extent of Medicaid cuts.
 
The goal of Congressional Leadership remains for President Trump to sign the bill by July 4.
 
The NABH Government Affairs team is contacting senate offices to oppose the current Senate bill. NABH has also sent several Action Alerts to NABH members with information to support outreach to senators. We urge you to respond to these alerts and encourage your colleagues to do the same.

Insurers Announce Plan to Reform Prior Authorization

A group of health insurance executives joined HHS Secretary Robert F. Kennedy, Jr. and Centers for Medicare & Medicaid Services Administrator Mehmet Oz on Monday to announce plans to change prior authorization practices with the aim to reduce administrative burden and improve patient care. Participating insures pledged to:

• Standardize electronic prior authorization by 2027;
• Reduce the scope of claims subject to prior authorization by 2026;
• Ensure continuity of care when patients change plans by 2026;
• Enhance communication and transparency on determinations by 2026;
• Expand real-time responses to 80% by 2027; and
• Ensure medical review of non-approved requests (in effect now).

Key questions remain about how insurers will implement some of these changes, and how their performance on these commitments will be monitored. Insurers’ approach to implementation could be controversial, such as if they rely further on artificial intelligence to improve response time.

Reminder: Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards Today, June 27!

NABH has released two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest is Wednesday, July 2 and full applications are due Wednesday, Aug. 27.
 
An HHS representative offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline. Please reach out to Dan Schwartz if you are interested in attending such a meeting. If there is a sufficient interest, we will proceed with scheduling.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT) compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

Fact of the Week

A new editorial in JAMA suggests addictive screen use is more strongly linked to negative mental health outcomes than screen time alone. The results emphasize the importance of addressing not just screen time, but also addictive behaviors in adolescents. “Moving forward, targeted policies and interventions, including stronger parental involvement and better age verification measures on social media, are crucial for mitigating the risks associated with screen addiction,” the editorial said.

Happy Independence Day from NABH!

NABH will not publish CEO Update on Friday, July 4 and will resume on Friday, July 11. 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.

Senate Finance Committee’s Budget Reconciliation Bill Includes Unsustainable Medicaid Cuts

The Senate Finance Committee’s recently passed budget reconciliation package includes significant and burdensome changes to the House-passed budget reconciliation bill and contains unsustainable cuts to Medicaid programs for behavioral healthcare providers.

Notable Medicaid program changes include restricting provider taxes, reducing state-directed payments, mandating work requirements that contain a complex behavioral healthcare treatment carve out, and eliminating the enhanced premium tax credit for Marketplace plans.

The biggest changes include a moratorium on new or increased provider taxes, which propose a significantly deeper cut to states’ ability to use provider taxes to finance Medicaid. As in the House bill, section 71120 of the Senate Finance bill would prohibit states from receiving federal Medicaid matching funds for any new or increased provider taxes enacted after the bill passes unless authorized already.  Notably, the moratorium would apply to increases in the amount of tax on a per-unit basis or the rate of tax imposed with respect to a class of healthcare items or services or increases in the base of the current provider tax. This effectively places a moratorium on using newly enacted or expanded provider taxes to finance the non-federal share of the Medicaid program.

The Senate bill would also modify the “hold harmless” standard for healthcare-related provider taxes under Medicaid, which limits how much states can tax providers without triggering federal penalties. Currently capped at 6%, the Senate bill phases down the threshold for expansion states beginning Oct. 1, 2026, to 3.5% by fiscal year 2031, while preserving the 6% cap for non-expansion states.

Meanwhile, the Senate bill would not affect the “hold harmless” threshold for provider taxes that states impose for nursing facility or intermediate care facility services as long as the tax is effective as of Oct. 1, 2026, within the hold harmless threshold as of May 1, 2025, and the provider tax is not modified or otherwise changed unless to come into compliance with these provisions. The Senate bill clarifies that these provisions only apply to the 50 States and Washington, D.C. (it does not apply to U.S. territories). The bill provides $6 million to HHS for implementation.

The Senate bill also includes modest – and meaningful – changes for the treatment of certain state- directed payments when no published Medicare rate exists. The bill directs HHS to revise Medicaid managed care regulations so that state-directed payments to providers in Medicaid expansion states cannot exceed 100% of the published Medicare payment rate for a given service, while non-expansion states would be permitted to go up to 110%. Rather than directing HHS to use an “equivalent Medicare payment rate” when no published rate exists — as the House bill does — the Senate version instead calls for an equivalent payment under the Medicaid State Plan.

The Senate bill also applies a stricter approach to grandfathered payments. While the House bill would allow grandfathered payments to continue at existing levels, the Senate version phases them down by 10 percentage points annually starting in 2027 until they meet the applicable cap. It also broadens eligibility for grandfathering to include cases where states made a good faith effort to secure prior approval.

The Senate version also includes a notable addition to the Uniform Medicaid Provider Tax Requirement that would allow states to revise existing provider taxes to comply with the new standards without being penalized. Under the bill, states’ ability to obtain waivers from the uniform tax requirement for Medicaid provider taxes would be limited.

Specifically, the bill would prohibit waivers for tax structures that impose lower rates on providers with less Medicaid volume, or higher rates to those with more. The section includes definitions for “Medicaid taxable unit,” “non-Medicaid taxable unit,” and “tax rate group” to help identify impermissible structures and makes clear that attempts to achieve the same effect through indirect language is also prohibited, effectively closing any loopholes to the restriction. These changes would take effect immediately upon the bill’s enactment, with a transition period of up to three fiscal years at the HHS secretary’s discretion. The Senate bill adds that states will not be considered in violation if they are changing their taxes to comply with the new requirements and clarifies that these provisions only apply to the 50 States and Washington, D.C. (again excluding the U.S. territories in this provision).

Other provisions, including work requirements and cost sharing, have behavioral health-focused exemptions that align with the House bill. However, NABH continues to have concerns with the work requirement exemption for people with a “disabling mental disorder,” because this language could imply the need for a formal disability determination. We are also concerned that the Senate bill excludes a provision to extend premium tax credits for Marketplace plans.  

The NABH Government Affairs team is contacting senate offices to oppose the current draft and sent an Action Alert to NABH members urging them to contact their U.S. senators. We hope you will respond to the alert and encourage colleagues to do the same.  NABH is asking senators to:

• Eliminate provisions that (1) create restrictions on the use of provider taxes that states rely on to pay for their share of the Medicaid program, and (2) tie state-directed payments the Medicare payment rate, which is substantially lower than what many providers currently receive. These provisions would inhibit efforts to address systematic underpayment of behavioral healthcare providers and therefore perpetuate access challenges.
• Replace the existing exemption for people with “disabling mental disorders” to people with “serious mental illness.” The term “disabling” could suggest that people must receive a formal disability determination, a complex and potentially yearslong process that often does not capture those with even the most debilitating mental disorders. Using “serious mental illness,” a term more commonly used in both clinical practice and policy to describe disorders that substantially interfere with major life functions, would align with the intent of the existing exemption while eliminating unnecessary red tape.
• Extend the enhanced premium tax credit. If the enhanced tax credits expire, nearly 4 million people could discontinue receiving coverage through the Marketplace by 2026.

The Senate will not mark up its bill before a Senate floor vote and may vote on the legislation next week before it adjourns for the Independence Day recess.

HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot

HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
 
HHS anticipates distributing $5 million across six to 10 participants, which include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
 
The deadline for the expression of interest is Wednesday, July 2 and full applications are due Wednesday, Aug. 27.

JAMA Study Finds Addiction to Social Media, Mobile Phones & Video Games Linked to Higher Risk of Suicidal Thoughts

A study published in JAMA on Wednesday found that addiction to social media, mobile phones, and video games is linked to a higher risk of suicidal thoughts and behaviors.

Researchers examined data on more than 4,000 kids from an ongoing longitudinal study following them for years, starting at ages 9 to 10. It found that by age 14, about a third of the kids had become increasingly addicted to social media, about a quarter had become increasingly addicted to their mobile phone, and more than 40% showed signs of addiction to video games.

“It’s an important study and raising awareness about screen addiction,” Jason Nagata, M.D., a pediatrician specializing in adolescent screen use at the University of California, San Francisco, said in an announcement about the study. “It shows that elements of addiction related to screen use are more strongly predictive of poorer mental health and even suicide risk compared to just screen time. So, I think that it provides more nuance.

NIDA Director Nora Volkow Likens ‘the Addicted Brain to a House on Fire’ in Recent Blog

National Institute on Drug Abuse Director Nora Volkow, M.D. this week penned a blog post about her recent commentary in The New England Journal of Medicine that likened “the addicted brain to a house on fire—a crisis requiring urgent efforts to contain the damage and preserve life.”
 
Volkow authored the article with John Kelly, Ph.D. and Howard Koh, M.D. and noted that America’s drug crisis has demanded a sustained focus to extinguish those fires by expanding treatment access and overdose prevention and reversal strategies—and added that data show such efforts have helped overdose fatalities decline since 2023.
 
“However, a house that has had its addiction fire extinguished still smolders and can readily burst into flames again,” Volkow wrote. “After an initial remission of substance use disorder symptoms, it can take as much as 8 years and 4-5 engagements in treatment or mutual support groups to achieve sustained remission, and risk for meeting SUD criteria can remain elevated for several more years after that.”
 
Click here to read the full post.

Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards by Next Friday, June 27!

NABH is releasing two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT)compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

Fact of the Week

Lawmakers are considering changes to the Medicaid program that could lead to at least 8,241 and as many as 24,604 preventable deaths, according to a new study published in the Annals of Internal Medicine.   

NABH Submits FY 2026 IPF PPS Proposed Rule Comments to CMS

NABH on Tuesday submitted comments about the fiscal year 2026 inpatient psychiatric facility prospective payment system (IPF PPS) proposed rule, which includes several payment and quality reporting changes (for more information about the proposed rule, check out our NABH Analysis).
 
NABH’s comments included a recommendation for a greater rate increase to account for forecasting errors over the past few years, support for increases to rural and teaching facility adjustments, information on the need for increased health information technology investment, and feedback on various components of the inpatient psychiatric facility quality reporting program, among other topics.
 
“Generally, IPFs operate on thin margins, and Medicare rates that have failed to account for actual cost increases put an additional strain on these facilities,” the letter said. “Any financial shortfalls mean IPFs are struggling to invest in wage and benefit increases necessary to retain their existing workforce or hire additional staff, particularly considering the burnout among clinical and non-clinical personnel.”

House Committee Advances Military Construction, VA, and Related Agencies Appropriations Act

The House Appropriations Committee on Wednesday approved the Fiscal Year 2026 Military Construction, Veterans Affairs, and Related Agencies Appropriations Act in a near party-line vote of 36 to 27.
 
The bill would provide about $453 billion for the Veterans Affairs Department (VA), an increase of more than $50 billion from the 2025 level. It would spend $37 billion on non-VA community care, which is $3 billion more than the VA requested for fiscal 2026. In 2025, the amount was $22.5 billion.
 
The legislation now moves to the House floor for consideration and eventually will be reconciled with the Senate VA Appropriations bill. The Senate will not begin its appropriations process until after the budget reconciliation process concludes.
 
The VA has also announced that veterans enrolled in the VA and who have been referred to Community Care no longer need a second review from a VA clinician to seek treatment. The provision implements language from the Senator Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act. VA officials hope this change will accelerate access to community care.
 
In addition, the Dole Act prohibits VA administrators from overriding a VA physician’s referral for a patient to receive outside the VA. According to the law, the ban on administrative review will remain in place for two years, after which the VA must report on its effects to Congress.
 
The VA announced it would begin training employees to ensure the community care referral process is followed in compliance with the Dole Act, meaning implementation may vary by region. 

SAMHSA Publishes Resources on Medications for Opioid Use Disorder

On Wednesday, SAMHSA released three resources focused on delivering medications for opioid use disorder (MOUD) in nontraditional settings:

• Advisory: Expanding Access to Methadone Treatment in Hospital Settings, which focuses on how hospitals can improve care for patients with opioid use disorder (OUD) by leveraging an existing regulatory flexibility permitting them to provide methadone to patients with OUD who present to the hospital for a different medical condition without registering as an Opioid Treatment Program.
• Guidelines for Implementing Medications for Opioid Use Disorder Treatment in State Prisons, which discusses each MOUD, service delivery approaches, regulatory standards, implementation considerations, and methods to prevent care disruptions when individuals are released from incarceration.
• Advisory: Clinical Considerations for Methadone Treatment of Opioid Use Disorder in Correctional Facilities, which provides information on different models for delivering methadone to patients with OUD in carceral settings and factors for successful implementation.

MACPAC Releases June 2025 Report to Congress

The Medicaid and CHIP Payment and Access Commission (MACPAC) has released its June 2025 Report to Congress on Medicaid and CHIP, which addresses appropriate access to residential behavioral health treatment services for children with Medicaid coverage in Chapter 2 and access to medications for opioid use disorder (MOUD) in Medicaid in Chapter 3.
 
“States are required to provide treatment for individuals with disabilities, including serious mental illness and serious emotional disturbance, in community-based settings if appropriate,” the report noted. “However, for children who need more intense care or pose a safety risk to themselves or their families, it is important that they can access residential treatment when necessary.”
 
Meanwhile, the report’s third chapter highlights recent federal policies and funding that have affected access to MOUD, an overview of MOUD coverage and estimates of use, and barriers to MOUD. The Commission said it plans to investigate further the use of utilization management practices and how they affect Medicaid beneficiaries’ receipt of timely and effective care.

We Want to Hear from You! Please Submit Surveys on EMTALA Implementation in Psychiatric Hospitals and Patient Safety Standards

NABH is releasing two surveys to members:

• EMTALA Implementation in Psychiatric Hospitals, which is focused on how EMTALA compliance affects operational and clinical practices, such as staffing, workflow, documentation, processes (e.g., patient transfers), and resource allocation.
• Patient Safety Standards, which is focused on standards for preventing and responding to incidents of patient violence and abuse (i.e., violence and abuse toward patients perpetrated by facility staff or other patients), particularly for inpatient and residential settings.

Please submit your responses by Friday, June 27. If you have any questions, please contact Dan Schwartz.

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

NABH 2025 Annual Meeting Photos Are Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month. NABH requests that you please credit photographer Chris Ferenzi if you use or share a photo.
 
And remember to mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A recent research letter published in JAMA Network reported the 988 lifeline was contacted 16,333,707 times between July 1, 2022 and Dec. 31, 2024. Of those contacts, 70% were calls, 18% were texts, and 11.9% were chats. Meanwhile, 11% of the contacts were re-routed to the Veterans Crisis Line.

House Passes SUPPORT Act; Legislation Moves to Senate for Consideration

The House on Wednesday passed H.R. 2483, the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) in a 366-57 vote to reauthorize bipartisan legislation that would prevent and treat illicit opioid use.
 
Thirty Democrats – many of whom serve on the House Energy and Commerce Committee and are upset with the administration’s cuts for federal addiction treatment programs – and 27 Republicans, mainly fiscal hawks in the House Freedom Caucus, voted against the House bill.
 
Congress reauthorized parts of the SUPPORT Act in a 2024 spending package, including making permanent the state Medicaid requirement to cover medication-assisted treatment for opioid use disorder. Lawmakers also expanded HHS’ state-by-state data collection efforts on behavioral health services and made permanent the state option to circumvent for certain patients the ban on using Medicaid funds for institutions of mental diseases. However, some parts of the 2018 SUPPORT Act remain unauthorized.
 
The legislation would reauthorize billions of dollars in funding for tackling the opioid crisis, which killed nearly 50,000 people last year, according to federal estimates. It would build on the original legislation Congress passed in 2018, which lawmakers have continued to fund even though it lapsed nearly two years ago.
 
Before moving the bill to the Senate, the House approved several amendments and narrowly rejected one amendment. An amendment from Rep. Jen Kiggans (R-Va.) would require the Office of the National Coordinator to convene a public roundtable to examine how the expanded use of electronic health records (EHR) among mental health and substance use disorder service providers can improve outcomes for patients in mental health and substance use disorder settings, and how best to increase EHR adoption among such providers, passed favorably.
 
Rep. Brittany Pettersen’s (D-Colo.) amendment would have codified Biden-era budget neutrality requirements for Section 1115 waivers. The vote failed 213-213, with two Republicans voting to support the amendment.
 
The legislation now heads to the Senate, where the Health, Education, Labor and Pensions Committee in 2023 advanced a version of the bill in a 19-1 vote.

Senate Considers Budget Reconciliation Bill

Following the House’s passage of the budget reconciliation bill, the Senate is now considering the “One Big Beautiful Bill” with the goal of passing the legislation by Congress’ July 4 recess.
 
Senate committees are reviewing their respective portions of the legislation and will soon release potentially amended versions of the House bill which must be reconciled.
 
Also this week, the Congressional Budget Office (CBO) estimated the House-passed bill will add $2.4 trillion to the federal debt over the next decade. The agency estimated the proposed tax cuts in the plan would decrease revenues by more than $3.6 trillion during that period.

CBO estimates Medicaid would be cut $863 billion over 10 years under the last-minute changes to the House reconciliation bill and 10.9 million people would be without health insurance in 2034, about a $75 billion increase from its initial Medicaid savings calculation and 2.3 million more people predicted to become uninsured.
 
CBO also estimates a total of 16 million people could lose health insurance if a House-passed budget bill becomes law, a number Republicans dispute. Other effects of the budget reconciliation bill’s policies that CBO analyzed include:
 
Work requirements: Requirements that recipients work, volunteer or go to school, the largest source of savings in the bill at $344 billion, and would lead to 4.8 million people losing health insurance.
 
Provider tax moratorium: The bill would place a moratorium on any new taxes that states levy on their hospitals. States can use revenue from the taxes to draw down more federal money for Medicaid and make hospitals whole by charging higher payment rates. The moratorium would likely lead states to reduce available resources for their Medicaid programs and change enrollment policies to “make enrollment more challenging to navigate,” the report said. It is anticipated that 400,000 people would lose insurance through 2034.
 
Return of Affordable Care Act (ACA) payments: A last-minute change to the bill returns payments to insurers to reimburse them for covering reduced cost-sharing for low-income customers. However, it would likely end a loophole that plans and states have used to recoup the cost of cost-sharing reductions by inflating the value of income-based tax credits. CBO estimates that 300,000 people would lose their coverage by 2034.
 
Changes to ACA eligibility: The bill includes several other ACA changes, such as ending a special enrollment period for people who earn 150% or less of the federal poverty level, erasing a 2024 rule that enabled them to enroll at any point in the year. This provision would lead to 200,000 losing insurance through 2034. The bill would also prohibit some immigrants from getting income-based subsidies on the exchanges. This would lead to 1 million people losing coverage. Stricter verification requirements for ACA customers to qualify for subsidies would also cause 700,000 people to drop off coverage through 2034.
 
Last month NABH sent a letter to congressional leaders that outlines our concerns about the measure’s healthcare provisions and provides other feedback about the budget reconciliation bill. NABH will continue to focus on members of the influential Senate Finance Committee and other senators who have expressed publicly their concern to make these changes.
 
And NABH will continue to use our grassroots platform to contact members of the Senate Finance Committee to request these legislative changes. We encourage you to act and to engage other colleagues in this effort!

CMS Releases RFI to Gather Information on Improving Hospital Price Transparency

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT)compliance and enforcement processes.
 
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.

FTC Wants to Use Enforcement Authority to Hold Social Media Companies Accountable

The Federal Trade Commission’s (FTC) three commissioners want to use the agency’s enforcement authority to hold social media companies accountable for how their platforms affect children’s mental health, Politico and other news outlets reported this week.
 
“As President Trump has emphasized, it’s to our benefit that the United States continue to be the global leader in this kind of innovation. And the President is correct,” FTC Chair Andrew Ferguson said at a policy workshop Wednesday in Washington, according to Politico.
 
The FTC hosted the all-day workshop, The Attention Economy: How Big Tech Firms Exploit Children and Hurt Families, which featured remarks from other commissioners as well as Sens. Marsha Blackburn (R-Tenn.) and Katie Britt (R-Ala.).

SAMHSA Publishes Guidance on Adult Benzodiazepine Use

The Substance Abuse and Mental Health Services Administration (SAMHSA) has released a “Dear Colleague” letter offering guidance on benzodiazepine (BZD) use in older adults.
 
Benzodiazepines are commonly prescribed for anxiety and insomnia; however, older adults face higher risks of adverse events from long-term use, including falls, cognitive decline, and drug interactions. The letter highlights the public health importance of reducing long-term benzodiazepine use among older adults and promotes patient-centered, evidence-informed strategies for evaluating ongoing BZD use.

Federation of American Hospitals President and CEO Chip Kahn to Retire at Year’s End

Chip Kahn, president and CEO of the Federation of American Hospitals for the past 24 years, announced Friday he will retire at the end of 2025.
 
Kahn is the third Federation CEO since the association was established in 1966 and led his organization through five presidential administrations and 13 Congresses. Modern Healthcare selected Kahn to the publication’s “100 Most Influential” list each year since the list was first published 23 years ago.
 
“What an honor to have an opportunity for a quarter century – and during a consequential period of health policy making – to be the play caller for this important hospital sector,” Kahn said in his announcement. “Much has been accomplished,” said Kahn. “Now it is time for a career turn to work on policy from another vantage point. I look forward to engaging in efforts to foster health care affordability, coverage, and quality improvement.”

USC Seeking Mental Healthcare Providers for New Research Study

The University of Southern California is seeking mental healthcare providers who working with bisexual+ (bi+) adult clients—including those identifying as pansexual, queer, or attracted to multiple genders for a new research study.
 
The study will explore how social and structural inequities contribute to disproportionately high unmet need for mental health care among bi+ people.

Eligible participants may be invited to share their insights in a focus group discussion and receive $50 compensation. Your input will support efforts to close the health gap and promote equal opportunity and justice for bi+ people. Click here to learn more.

NABH 2025 Annual Meeting Photos Now Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month. NABH requests that you please credit photographer Chris Ferenzi if you use or share a photo.
 
And remember to mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

In a cross-sectional study of 198,417 female parents of children aged 0 to 17 years, researchers observed large declines in self-reported mental health and small declines in self-reported physical health from 2016 to 2023, according to a new report in JAMA Internal Medicine. Mental health declines occurred across all socioeconomic subgroups; however, mental and physical health status was significantly lower for single female parents, those with lower educational attainment, and those with publicly insured children. The study concluded investments are needed to investigate and address the underlying causes of mental health decline among U.S. mothers, particularly for those of low socioeconomic status.

NABH Sends Comments to DOJ About Anticompetitive Regulations

NABH this week sent a letter to U.S. Attorney General Pamela Bondi suggesting opportunities to
to remove, modify, or clarify applying burdensome regulatory requirements that impede behavioral healthcare services to millions of Americans with mental and substance use disorders.
 
The letter covered a variety of topics, including Medicare requirements for inpatient psychiatric facilities, applying the Emergency Medical Treatment and Labor Act to psychiatric hospitals, the Drug Enforcement Administration’s requirements for mobile components to narcotic treatment programs, and other NABH priority issues.
 
Click here to read the full letter.

GAO Study: CMS Oversight of Prior Authorization Criteria Should Target Behavioral Health Services

The Government Accountability Office (GAO) this week released a report recommending the Centers for Medicare & Medicaid Services’ (CMS) target behavioral health services in its program audit prior authorization denial reviews and planned reviews of internal coverage criteria.
 
“According to CMS, processes like prior authorization are designed to help MA (Medicare Advantage) organizations minimize unnecessary services, thereby helping to protect beneficiaries and contain costs,” the report noted. “However, studies have indicated that prior authorization and use of internal coverage criteria may hinder MA beneficiaries’ access to care,” it continued. “CMS is responsible for ensuring that MA beneficiaries generally receive at least the same coverage of benefits as beneficiaries enrolled in traditional fee-for-service Medicare, which does not currently require prior authorization for any behavioral health services.”
 
Click here to access the full report, its highlights, and the GAO’s recommendations.

JAMA Examines VA-Purchased Community Care for U.S. Veterans with Mental Health Conditions

A new JAMA study concluded that among U.S. veterans using Community Care (CC), those with mental health conditions may be less satisfied with CC, emphasizing a need for targeted efforts to improve CC for this subpopulation.
 
Researchers from the University of Pennsylvania examined data from 231,869 veterans surveyed from 2016 to 2021 and found that those with versus those without mental health conditions reported significantly lower ratings of experiences with CC in nine domains, including a 1.8-point lower overall satisfaction rating.
 
“Although ratings of CC improved over time, differences in experiences persisted between veterans with and without MHC,” the study said.

NABH 2025 Annual Meeting Photos Now Available!

Please click here to see or use photos from the NABH 2025 Annual Meeting in Washington earlier this month.
 
Please be sure to credit photographer Chris Ferenzi if you use or share a photo.

ICYMI: NABH Annual Meeting Presentations Are Available

NABH has posted all 2025 Annual Meeting speaker presentations for which we received permission on our Speakers & Presentations page. We will send a link to our Annual Meeting photos at a later date.
 
Please mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A new study published in Health Affairs found that overall, 6.4% of Medicaid Emergency Department visits were associated with a claim for MOUD within 30 days, based on Medicaid claims data from 2016-2020. This rate was highest among non-Hispanic White (7.3) patient%) s and lowest among non-Hispanic Black (4.3%) and Hispanic (4.9%). 

House Passes Reconciliation Bill That Includes Significant Medicaid Changes

The House early Thursday passed President Trump’s sweeping budget reconciliation bill in a 215-214 vote after the House Rules Committee passed a 42-page amendment to the legislation. Notably, the bill includes several significant restrictions on Medicaid eligibility and financing.
 
The Senate will now consider the legislation and is expected to make changes to it.
 
Meanwhile, the Congressional Budget Office (CBO) has yet to provide information about the effects of the House bill, although the CBO’s latest estimate notes that changes in the House Energy and Commerce Committee’s jurisdiction – which includes Medicaid and Marketplace plans – would produce more than $900 billion in savings during the next decade. An earlier analysis estimated that 8.6 million people could become uninsured by 2034.
 
NABH has several major concerns about the bill, including the:

• Moratorium on creating new provider taxes;
• Limits to future state-directed payments;
• Problematic language in behavioral health exemptions to community engagement requirements; and
• Lack of extension to enhanced premium tax credits for Marketplace plans.

NABH sent a letter to Senate leaders today, May 23, that articulates these concerns. We are watching this legislative process closely as the Senate considers the bill, and we will continue to provide updates as the situation evolves.

White House Releases Report on Childhood Chronic Diseases

Also on Thursday, the White House released Make Our Children Healthy Again, a 73-page report from President Trump’s Make America Healthy Again Commission that examines four areas: (1) poor diet, (2) aggregation of environmental chemicals, (3) childhood behavior in the digital age, and (4) overmedicalization.
 
The report covers various topics that impact mental health, such as technology and social media use, poor sleep, chronic stress, family dynamics, and nature exposure. It also asserts various ways in which children are over-diagnosed with mental disorders, including attention-deficit/hyperactivity disorder, depression, and anxiety, as well as over-treated with stimulants, antidepressants, and antipsychotics.
 
Finally, the report mentions a controversial theory that some interventions and approaches, including therapy, social-emotional learning, and trauma-informed care, could over-pathologize emotional experiences, leading to increases in anxiety and depression.

CMS Resource Updates Improper Payment Rate and Denial Reasons for 2023 Reporting Period

The Centers for Medicare & Medicaid Services’ (CMS) Medicare Provider Compliance Tips – a resource from the Medicare Learning Network – reports that the improper payment rate for outpatient psychiatry services was 13.5% with a projected improper payment amount of $186.1 million in 2023, according to the 2023 Medicare Fee-for-Service Supplemental Improper Payment Data.
 
The resource – which includes tips for a host of specialty providers – outlines more information and policy requirements for physicians and non-physician practitioners who bill for outpatient psychiatry services.

Help NABH Develop a Behavioral Health Tech Apprenticeship!

The NABH Education and Research Foundation thanks all who attended last week’s NABH Annual Meeting workforce panel about NABH’s new project to develop and sponsor a behavioral health technician registered apprenticeship program with the U.S. Labor Department.

If you didn’t attend the panel discussion – or if you attended and didn’t participate in the panel’s live poll – please take a moment to submit this four-question survey by Wednesday, May 28 to let us know 1) if you would like to help NABH with this new initiative, and 2) if so, how you would like to participate.

For more information, click here to learn why NABH urges its members to support this model and here to learn NABH’s ten steps to apprenticeship. As always, thank you for your time!

ICYMI: NABH Annual Meeting Presentations Are Available

Last week NABH posted all 2025 Annual Meeting speaker presentations for which we received permission on our Speakers & Presentations page. We will send a link to our Annual Meeting photos at a later date.
 
Please mark your calendars for March 2-4, 2026 when we will host the NABH 2026 Annual Meeting at our new location: The Ritz-Carlton Washington, DC!

Fact of the Week

A new study from Avalere Health found opioid use disorder costs businesses, governments, and households almost $1 trillion per year and that treatment with medications can lower costs.

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

2025 NABH Annual Meeting Starts Monday!

We’re pleased to devote this week’s edition of CEO Update to details about the 2025 Annual Meeting that starts Monday, May 12 in Washington, D.C.
 
This year’s Annual Meeting focuses on Behavioral Health is Everyone’s Concern: Constant Care, Changing Times, and our presenters will explore the federal government’s behavioral health strategy, the connection between behavioral health and chronic conditions, practical ways to improve your workforce, how states are advancing behavioral health, the current telehealth landscape, NABH’s new initiatives, 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.  

Be Sure to Access the 2025 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 a link to the app that includes information about sessions, speakers, meeting room locations, registrants, exhibitors and sponsors, Hill Day resources, and more. Attendees can also access the link through a QR code near the Registration Desk at the Annual Meeting.

There’s Still Time to Register for Hill Day 2025!

It’s not too late to register for Hill Day 2025 on Wednesday, May 14 from 10:00 a.m. – 2:30 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.
 
How it Works:

After you register and indicate that you will participate in Hill Day, you will receive an email  from the NABH government relations team to better tailor your experience. They will match you with legislators who represent your facility’s footprint. Please email Emily Wilkins with any questions.

CMS Deputy Chief Medical Officer Shari Ling, M.D. to Kick Off 2025 Annual Meeting on Monday

The Centers for Medicare & Medicaid Services (CMS) Deputy Chief Medical Officer Shari M. Ling, M.D. will kick off this year’s Annual Meeting on Monday, May 12.

Dr. Ling serves in the Center for Clinical Standards and Quality, where she is responsible for assisting the agency’s chief medical officer to pursue higher quality healthcare, healthier populations, and lower cost through quality improvement. Dr. Ling’s long-standing focus has been to achieve meaningful health outcomes through delivery of high quality, beneficiary-centered care across all care settings, with a special interest in the care of persons with multiple chronic conditions and functional limitations and reducing health disparities.

At the U.S. Health and Human Services Department (HHS), Dr. Ling represents CMS on the HHS Multiple Chronic Conditions Workgroup and serves as the clinical sub-group lead for the HHS National Alzheimer’s Project Act.

At the Annual Meeting, Dr. Ling will discuss the connection between behavioral health within the context of preventive care and chronic conditions. Please help us welcome her in the Salamander Washington, DC’s Grand Ballroom on May 12 at 3 p.m. ET.

Learn About NABH’s New Project to Sponsor a Behavioral Health Technician Apprenticeship

Immediately following Dr. Ling’s presentation at 3:45 p.m., NABH Immediate Past Board Chair Frank A. Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers Health University Behavioral Health Care and senior vice president of the Behavioral Health and Addictions Service Line at RWJBarnabas Health, will moderate a panel discussion about NABH’s new project to sponsor a behavioral health technician Registered Apprenticeship Program (RAP) with the U.S. Labor Department (DOL).
 
The RAP panel will feature 2025 NABH Board Chair Jim Shaheen, CEO of New Season/Colonial Management Group; John Pallasch, former assistant secretary for employment and training at DOL and founder and CEO of workforce consultancy One Workforce Solutions; and independent consultant Kristen Weeden, who began her career as a child protective case worker. The panelists will explain this new program, how your system will benefit from it, and ways you can help NABH in this process. 

Learn How to Strengthen Supervisor Competencies with Yale Behavioral Health’s Scott Migdole

Day 2 of the Annual Meeting will start on Tuesday, May 13 at 9 a.m. with Yale Behavioral Health & Yale Program on Supervision COO Scott Migdole, M.S.W., LCSW, who will share Yale’s model for strengthening supervisor competencies and shaping supervision practice in health and human service organizations, including hospitals. Migdole’s presentation will cover topics such as the basics of a supervision model, phases and functions of supervision, and managing from the middle.

Explore Behavioral Healthcare Advancements and Challenges in the States with the National Academy for State Health Policy’s Hemi Tewarson

Immediately following Migdole’s presentation, NABH Vice President of Policy Dan Schwartz will engage in a fireside chat with Hemi Tewarson, J.D., M.P.H., executive director at the National Academy for State Health Policy (NASHP). They’ll discuss how NASHP’s work can help NABH members, the effects of potential Medicaid cuts on states, behavioral healthcare advancements at the state level, how states are addressing the nation’s ongoing opioid crisis, the recent shift in states’ top behavioral health priority away from the opioid crisis to mental health, and more. 

Examine Today’s Telemedicine & Telehealth Landscape with the American Telemedicine Association’s Kyle Zebley

At 4 p.m. on Tuesday, the American Telemedicine Association’s Kyle Zebley will offer a presentation that will highlight the present telehealth landscape, the congressional perspective on telehealth services, the U.S. Drug Enforcement Administration and remote prescribing of controlled substances, Medicare telehealth flexibilities, and more.  

Learn About NABH’s New Advocacy Tool with the NABH Government Relations Team

After Zebley’s presentation, NABH Vice President of Government Relations Andrew Dodson and Director of Government Relations Emily Wilkins will conclude Tuesday’s presentations with a discussion about NABH’s new advocacy tool SparkInfluence and help members prepare for Hill Day on Wednesday, May 14.

Fact of the Week

2025 marks the last year NABH will host its Annual Meeting at the Salamander Washington, DC, previously the Mandarin Oriental Washington, DC. Please mark your calendars and join us next
March 2-4 at The Ritz-Carlton Washington, DC for the NABH 2026 Annual Meeting!
 
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 23.
For questions or comments about this CEO Update, please contact Jessica Zigmond.

House Energy & Commerce Committee Expected to Start FY 2026 Budget Bill Mark-Up on May 12

Continuing – and contentious – negotiations have caused the House Energy and Commerce Committee to postpone its planned markup of the fiscal year (FY) 2026 reconciliation package to Monday, May 12.
 
The Energy & Commerce Committee is considering multiple, significant proposals that would result in reduced federal funding for Medicaid. NABH has focused its advocacy efforts on members of the Energy & Commerce Committee, which must find $880 billion in savings, according to the recently passed FY 2026 budget resolution.
 
These savings will likely result in Medicaid cuts that would have a devastating effect on behavioral healthcare providers, and, most importantly, patients.
 
NABH’s message to Members of Congress urges them to oppose:

• Reducing provider taxes,
• Reducing state-directed payments,
• Capping Medicaid expansion, and
• Mandating work requirements.

Medicaid cuts would directly or indirectly limit or eliminate access to behavioral healthcare services for current beneficiaries in states that must reduce the size of their Medicaid programs due to some combination of these cuts.
 
In addition to government relations team outreach, NABH is also using a new grassroots platform that allows NABH members located in the congressional districts of Energy & Commerce Committee members to quickly and easily e-mail their congressional representative with a prepared letter that opposes Medicaid cuts. NABH members also have the option to personalize their correspondence.
 
NABH will make the same request of all NABH members next week in another action alert.
 
Medicaid cuts and the effects those cuts would have on our patient population will also be the main topic for discussion when NABH members head to Capitol Hill on our annual Hill Day, Wednesday, May 14.

House Energy & Commerce Committee Passes SUPPORT Act

The House Energy & Commerce Committee this week passed H.R. 2483, the SUPPORT for Patients and Communities Reauthorization Act of 2025 which funds critical treatment and recovery programs for opioid abuse and expands access to addiction medicines such as buprenorphine.
 
What typically would have been a unanimous vote resulted this time in a nearly party line vote of 36 -13. The original law authorizing overdose-fighting programs expired more than 18 months ago and Congress has continued to fund it.
 
The Energy and Commerce Committee approved the same bill unanimously in July 2023; however, a majority of Democrats opposed it on April 29, underscoring their frustration that the Trump administration’s Department of Government Efficiency’s cost-cutting campaign is undermining the few areas of bipartisan agreement that still exist in Washington.

Last year, overdose deaths fell from highs that exceeded 110,000 a year during the COVID-19 pandemic, according to the Centers for Disease Control and Prevention. Still, more than 80,000 Americans died from an overdose during the 12 months ending last November.

The original SUPPORT Act authorized $20 billion in treatment, prevention and recovery funding. Its reauthorization was part of a major bipartisan, bicameral health care package during the first Trump Administration. The bill next goes to the House Floor, before consideration in the Senate.

CMS Considers Utilization-Management Changes

Modern Healthcare reported on Tuesday, April 29 that the Centers for Medicare & Medicaid Services (CMS) is considering options to reduce delays in care associated with utilization management controls across health plans.
 
In particular, the agency is exploring ways to limit the use of prior authorization, as well as automate coverage determinations. This effort aligns with statements made by Mehmet Oz, M.D. during his confirmation hearing for CMS administrator, where he suggested streamlining the prior authorization process.

CMS Deputy Chief Medical Officer Shari Ling, M.D. to Kick Off 2025 Annual Meeting

NABH is pleased to announce the CMS Deputy Chief Medical Officer Shari M. Ling, M.D. will kick off this year’s Annual Meeting on Monday, May 12!
 
Dr. Ling serves in the Center for Clinical Standards and Quality (CCSQ), where she is responsible for assisting the agency’s chief medical officer to pursue higher quality healthcare, healthier populations, and lower cost through quality improvement. Dr. Ling’s long-standing focus has been to achieve meaningful health outcomes through delivery of high quality, beneficiary-centered care across all care settings, with a special interest in the care of persons with multiple chronic conditions and functional limitations and reducing health disparities.

At the U.S. Health and Human Services Department (HHS), Dr. Ling represents CMS on the HHS Multiple Chronic Conditions Workgroup and serves as the clinical sub-group lead for the HHS National Alzheimer’s Project Act.

A gerontologist, Dr. Ling received her medical training at Georgetown University School of Medicine and her clinical training in Internal Medicine and Rheumatology at Georgetown University Medical Center. She also completed Geriatric Medicine studies at Johns Hopkins University and received her training in Direct Service from the Ethel Percy Andrus Gerontology Center at the University of Southern California and served as the co-director of the Andrus Older Adult Counseling Center. Dr. Ling volunteers at the Veterans Administration Medical Center in Baltimore.

At the NABH Annual Meeting, Dr. Ling will discuss the connection between behavioral health within the context of preventive care and chronic conditions. Please help us welcome her in the Salamander Washington, DC’s Grand Ballroom on May 12 at 3 p.m. ET.

View This Year’s Annual Meeting Exhibitors & Sponsors!

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.
 
New in 2025 is NABH’s Silver Sponsorship, which offers exhibitors and sponsors an opportunity to interact with NABH members during our association’s committee meetings for 30 minutes.
 
You can view a list of our exhibitors and sponsors on our Annual Meeting homepage, and please make time to visit with them at the Annual Meeting from May 12-14 at the Salamander Washington, DC.

Manatt to Host Webinar on Medicaid Cuts on Children and Youth Next Week

Research firm Manatt will host an hourlong webinar next week that will examine the effects of Medicaid cuts on the nation’s children.
 
As Manatt reports, Medicaid covers two in five children and nearly half of all children with special healthcare needs. Despite the extensive research that shows that Medicaid coverage of children contributes to better health outcomes and improved long-term effects on health and educational attainment in adulthood, Congress is actively considering large reductions in Medicaid through the budget reconciliation process.
 
Federal proposals continue to evolve; these include: imposing caps on federal Medicaid funding, eliminating the enhanced federal funding states receive to cover expansion adults (which includes parents), mandating work reporting requirements as a condition of eligibility for parents and childless adults, reducing states’ ability to rely on provider taxes to pay a portion of their share of Medicaid costs, and restricting the ability for states to direct managed care plans to boost provider payments to strengthen access to care.
 
The webinar is scheduled for Tuesday, May 6 from 3:30 p.m. to 4:30 p.m. ET. Click here to register.

Fact of the Week

The National Institutes of Health has funded six projects to develop, test, and validate outcome-focused quality measures for mental health to increase the accessibility and availability of evidence-based mental health treatments. Click here to learn about these projects.

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

The NABH Annual Meeting Hotel Reservation Cutoff Date is Today, Friday, April 25!

The Salamander Washington, DC cut-off date to reserve a room for our Annual Meeting is today, Friday, April 25.
 
This year NABH will welcome presenters who will discuss what you need to know about: the strides states are making in behavioral healthcare; the present telehealth landscape; today’s uncertain regulatory environment; how to better train supervisors at your systems; NABH’s apprenticeship project and how it can help with your system’s workforce needs; NABH’s new advocacy resource; and more.

Please be sure to reserve your hotel room and register for the meeting if you haven’t yet. We look forward to seeing you in Washington!

View This Year’s Annual Meeting Exhibitors & Sponsors!

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.
 
You can view a list of our exhibitors and sponsors on our Annual Meeting homepage, and please make time to visit with them at the Annual Meeting from May 12-14 at the Salamander Washington, DC.

Tomorrow is National Prescription Drug Take Back Day

The next National Prescription Drug Take Back Day is tomorrow, Saturday, April 26 from 10 a.m. – 2 p.m. local time at all locations nationwide.
 
This twice-yearly event is intended as a safe, convenient, and responsible way to dispose of unused or expired prescription drugs in communities throughout the United States.

Click here for additional information and here to find a location near you.

ICYMI: NABH’s Analysis on CMS’ 2026 IPF PPF Proposed Rule

NABH reported to members earlier this month that the Centers for Medicare & Medicaid Services (CMS) recommended a host of payment and quality program changes for fiscal year (FY) 2026 in the proposed inpatient psychiatric facility prospective payment system (IPF PPS) rule the agency released on Friday, April 11.
 
Click here to read our NABH Analysis about the proposed rule if you haven’t yet. NABH will gather feedback from members before submitting comments, which are due by Tuesday, June 10.

ICYMI: NABH Joins Modern Medicare Alliance

To push back on Medicaid cuts and educate lawmakers, NABH has joined the Modern Medicaid Alliance (MMA), a “partnership between Americans who value Medicaid and leading advocacy organizations.”
 
As part of this new effort, NABH recently joined more than 90 health organizations in a letter urging Congress to reject cuts to Medicaid.  MMA has also conducted media campaigns and polling to assess voters’ reactions to Medicaid cuts.
 
Learn more at MMA, where you can also sign up for email alerts, and click here to see state and congressional data that shows Medicaid’s positive effects on American communities.

Fact of the Week

The U.S. construction industry has one of the highest suicide rates among professions: an estimated 6,000 construction workers died by suicide in 2022, according to a new report from NBC News.

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

Energy & Commerce Committee Schedules Reconciliation Bill Markup for May 7

The House Energy and Commerce Committee has targeted May 7 for a markup of its portion of the Republican reconciliation bill to fund federal operations. Rep. Brett Guthrie (R-Ky.), who chairs the Energy and Commerce Committee, is instructed to find $880 billion in savings from its areas of jurisdiction, which includes Medicaid.
 
Although Congress is in recess for two weeks, several moderate House Republicans wrote a letter to Guthrie and House GOP leadership this week vowing to oppose steep cuts to Medicaid. Other items under consideration for cuts include spectrum sales, rolling back electric vehicle mandates and pharmacy benefit manager reform.
 
The GOP leadership has an ambitious timeline for House committees to consider their portions of the reconciliation package. The leadership wants many of the committees involved in the bill to hold markups during the first week after Spring recess.
 
The GOP leadership is trying to fuel momentum and force the reconciliation bill to the finish line, a strategy that has worked well so far. The vastly different instructions for House and Senate committees in the budget resolution are also a challenge for panels in writing their portions of the bill.
 
NABH staff members are meeting with Energy & Commerce member offices, sharing concerns about various potential Medicaid cuts including work requirements, provider taxes and state-directed payments, as well as sharing data on how these cuts would affect constituents.
 
NABH will soon contact our members with a targeted Action Alert to Members of the Energy & Commerce Committee. Please be on the lookout for this and encourage your colleagues to act.
 
Potential Medicaid cuts and what this means for NABH members will be a priority topic during NABH’s annual Hill Day on Wednesday, May 14.

NABH Joins Modern Medicare Alliance

To push back on Medicaid cuts and educate lawmakers, NABH has joined the Modern Medicaid Alliance (MMA), a “partnership between Americans who value Medicaid and leading advocacy organizations.”
 
As part of this new effort, NABH recently joined more than 90 health organizations in a letter urging Congress to reject cuts to Medicaid.  MMA has also conducted media campaigns and polling to assess voters’ reactions to Medicaid cuts.
 
Learn more at MMA, where you can also sign up for email alerts, and click here to see state and congressional data that shows Medicaid’s positive effects on American communities.

The NABH Annual Meeting Hotel Reservation Cutoff Date is Approaching!

The Salamander Washington, DC cut-off date to reserve a room for our Annual Meeting is next Friday, April 25!
 
This year NABH will welcome presenters who will discuss what you need to know about the present telemedicine and telehealth landscape; what’s critical to understand in today’s uncertain regulatory environment; how to better train supervisors at your systems; NABH’s work on apprenticeships to help members with their workforce needs; and more.

So please be sure to reserve your hotel room and register for the meeting if you haven’t yet.

We look forward to seeing you in Washington!

Learn How to Help Your System Attract Skilled Workers & Strengthen Supervisor Competencies!

Please join us for two NABH Annual Meeting sessions this year designed to help your system address its workforce recruitment and retention needs.
 
On Monday, May 12 at 3:45 p.m., NABH Immediate Past Board Chair Frank A. Ghinassi, Ph.D., A.B.P.P., president and CEO of Rutgers Health University Behavioral Health Care and senior vice president of the Behavioral Health and Addictions Service Line at RWJBarnabas Health, will moderate a panel discussion about NABH’s new project to sponsor a behavioral health technician Registered Apprenticeship Program (RAP) with the U.S. Labor Department (DOL).
 
The RAP panel will feature 2025 NABH Board Chair Jim Shaheen, CEO of New Season/Colonial Management Group; John Pallasch, former assistant secretary for employment and training at DOL and founder and CEO of workforce consultancy One Workforce Solutions; and independent consultant Kristen Weeden, who began her career as a child protective case worker. The panelists will explain this new program, how your system will benefit from it, and ways you can help NABH in this process. 
 
Then join us on Tuesday, May 13 at 9 a.m. to learn from Yale Behavioral Health & Yale Program on Supervision COO Scott Migdole, M.S.W., LCSW, who will share Yale’s model for strengthening supervisor competencies and shaping supervision practice in your facilities.
 
You won’t want to miss these workforce sessions in the Salamander Washington, DC’s Grand Ballroom that the NABH Education and Research Foundation has planned as part of the Foundation’s Mission to identify and develop best practices and improve NABH members’ ability to support the country’s behavioral health needs.
 
Please remember to register for the Annual Meeting, reserve your hotel room, and view our preliminary program if you haven’t yet.

ICYMI: CMS Proposes 2.4% Hike & Explores Star Ratings, Electronic Patient Assessments in FY 2026 IPF PPS Rule

The Centers for Medicare & Medicaid Services (CMS) recommended a host of payment and quality program changes for fiscal year (FY) 2026 in the proposed inpatient psychiatric facility prospective payment system (IPF PPS) rule the agency released on Friday, April 11.
 
As NABH reported to members in an April 11 NABH Alert, the proposed rule recommends increasing FY 2026 rates for inpatient psychiatric hospitals and units by 2.4% ($70 million), relative to FY 2025 levels, which accounts for a 3.2% market basket update that would be offset by 0.8 percentage point productivity adjustment.
 
Please click here to read an in-depth NABH Analysis about the proposed rule’s provisions that NABH sent to members on April 14.  
 
NABH will gather feedback from members before submitting comments, which are due by Tuesday, June 10.

Kaiser Family Foundation to Host Webinar on Medicaid Fraud and Abuse Next Week

The Kaiser Family Foundation will examine Medicaid fraud and abuse in an hourlong webinar that will discuss how state Medicaid programs ensure program integrity and what it takes to address fraud; how substantial is fraud relative to total Medicaid spending; and how fraud and abuse relate to improper payments.
 
Click here to register for the webinar, which starts at Noon ET on Thursday, April 24.

Fact of the Week

Health Affairs reports on a new dashboard that researchers created to identify and analyze reports of maternal mental health shortfalls. With funding from the National Institute of Minority Health and Health Disparities and the National Institute of Mental Health, the dashboard focuses on six maternal and two infant outcomes.

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

House Passes Budget Resolution, Clearing Path for Future Reconciliation Bill

House lawmakers on Thursday narrowly passed the Senate-amended budget resolution, clearing the way for a future reconciliation bill that would extend the Tax Cut and Jobs Act of 2017 that sunsets at the end of 2025, create some new tax cuts, and reduce the deficit.
 
The bill is also expected to include deep cuts to the Medicaid program, which has been a major point of contention for congressional Democrats, advocates and some Republicans.
 
Now that both chambers have officially agreed on a budget blueprint, House and Senate committees must begin drafting legislation to meet their assigned reconciliation targets. In addition to likely cutting back on Medicaid funding, GOP lawmakers could also address the expiring Patient Protection and Affordable Care Act (ACA) tax credits, Medicare Advantage overpayments, and other health care policies like implementing site-neutral payments in Medicare or finally reversing CMS’s 2.8% cut to the Medicare physician fee schedule.
 
Tax and spending bills considered under budget reconciliation rules are immune to Senate filibusters, which require 60 votes to end, and can pass both chambers on simple majority votes. The GOP has a 220-213 majority in the House and a 53-47 edge over Democrats and allied independents in the Senate. Under this measure, House committees must find at least $1.5 trillion in spending cuts while Senate committees have to meet a much smaller $4 billion minimum.
 
The budget instructs the House Energy and Commerce Committee, which has jurisdiction over Medicaid and Medicare, to slash spending by $880 billion. When it comes to healthcare, Medicaid is the most likely target for spending cuts. According to the Congressional Budget Office, the Energy and Commerce Committee has access only to $135 billion in spending it can eliminate if Medicare and Medicaid are excluded, and President Trump has ruled out Medicare cuts. However, the Senate Finance Committee, which oversees the same programs, is not subject to that order. When lawmakers in the two chambers draft the actual reconciliation bills, Congress will have to reconcile the differences.
 
The Majority must decide on which of the Medicaid financing reforms being discussed for months they should pursue. Work requirements appear to be the Majority’s most favored option, but other options being considered include lowering the minimum 50% Federal Medical Assistance Percentage (FMAP), reducing the enhanced match rate for Medicaid expansion, implementing per capita caps, and restricting states’ current ability to use provider taxes to help finance their share of Medicaid costs.
 
NABH and other advocates are strongly opposing these proposals, which would essentially strip coverage from millions of Americans. NABH is contacting House and Senate members with data on what cuts would mean for patients receiving care for severe mental illness and substance use disorders.
 
NABH is also asking its members to contact their Members of Congress, and opposing Medicaid cuts will be a priority topic when NABH members meet with House and Senate offices during our annual Hill Day on Wednesday, May 14.

CMS Finalizes Medicare Advantage Rates and Program Changes for 2026

The Centers for Medicare & Medicaid Services (CMS) recently released two rules that update Medicare Advantage (MA) payment rates and feature program improvements for 2026.
 
The agency updated plan requirements and other provisions in its rule published on April 4 and followed with a rate update in its rule published on April 7. The final update of 5.06 percentage points, relative to 2025, is a substantial increase of almost three percentage points over the update that the previous administration proposed.
 
NABH will compare this increase with Medicare fee-for-service rates for inpatient psychiatric hospitals and units, and other behavioral healthcare service providers, that CMS will propose in upcoming rules.
 
The final MA changes include improvements that NABH advocated for, including:

• Holding Plans to Approved Admission Decisions: MA plans will no longer be able to
  reopen and modify a previously approved inpatient hospital decision on the basis of information gathered after the approval. Such reopening only will be allowed in cases of obvious error or fraud.
• Closing MA Appeals Loopholes: The rule clarifies that MA appeals rules apply to denied claims, regardless of whether the decision is made before, after, or during the receipt of services. MA appeals process protocols also apply to decisions made concurrent to the enrollee’s receipt of services.
• Notifications: The rule codifies the requirement for plans to notify beneficiaries, as well as providers requesting on their behalf of coverage approvals and denials.
• Payment Liability: The rule also clarifies that an MA enrollee’s liability to pay for services only can be determined when a plan makes a coverage decision on a provider’s claim, which helps ensure enrollee appeal rights on ongoing treatment.

CMS noted its plan to consider future rulemaking related to the use of artificial intelligence by MA plans, as well as other MA policies, to ensure alignment with the White House deregulation executive order, including annual health equity analysis of MA plan utilization management policies and procedures; requirements to provide culturally and linguistically appropriate services; and quality improvement and health risk assessments focused on equity and social determinants of health.

ICYMI: NABH Joins Mental Health Partners in Statement About Recent HHS Job Cuts

NABH recently was one of 12 organizations that released a statement highlighting the effects that HHS’ recent staffing cuts will have on patients who require mental health (MH) and substance use disorder (SUD) treatment services.
 
Together with NAMI, Mental Health America, the American Psychiatric Association, the American Psychological Association, and other organizations, NABH expressed serious concerns about what comes next for the many MH and SUD programs that the Substance Abuse and Mental Health Services Administration, the Centers for Disease Control and Prevention, and the National Institutes of Mental Health oversee.
 
“Unfortunately, the immediate reduction in force means these agencies will lose staff with years of experience and expertise, and the pathway for the transition of their knowledge and the critical services they operate is unclear,” the letter said. “This has the potential to jeopardize years of work and recent progress, like reducing overdose deaths.”
 
NABH and our partners urged the Trump administration to reconsider the steep job cuts and ask HHS Secretary Robert F. Kennedy, Jr. to explain “the impact of these significant changes to HHS staffing for mental health, suicide prevention, and substance use programs and the expected impact on outcomes for the tens of millions of Americans with behavioral health conditions.”

Annual Meeting Hotel Cut-off Date is Next Friday, April 18!

The Salamander Washington, DC cut-off date to reserve a room for our Annual Meeting is one week from today, Friday, April 18.
 
This year NABH will welcome presenters who will discuss what you need to know about the present telemedicine and telehealth landscape; what’s critical to understand in today’s uncertain regulatory environment; how to better train supervisors at your systems; NABH’s work on apprenticeships to help members with their workforce needs; and more.
 
So please be sure to reserve your hotel room and register for the meeting if you haven’t yet.
We look forward to seeing you in Washington!

Fact of the Week

Compared with patients who received provider-initiated consultations, patients who received AI screening for opioid use disorder risk had 47% lower odds of being readmitted to the hospital within 30 days after their initial discharge, according to new findings from a National Institutes of Health (NIH)-supported clinical trial.

“Addiction care remains heavily underprioritized and can be easily overlooked, especially in overwhelmed hospital settings where it can be challenging to incorporate resource-intensive procedures such as screening,” Nora D. Volkow, M.D., director of NIH’s National Institute on Drug Abuse said in an announcement about the findings. “AI has the potential to strengthen implementation of addiction treatment while optimizing hospital workflow and reducing healthcare costs.”

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

Trump Administration Releases Drug Policy Priorities

The White House Office of National Drug Control Policy this week released the Trump administration’s Statement of Drug Policy Priorities, which the administration said “will evolve to keep pace with the changing landscape of illicit drug trafficking and ensure that our borders, communities, and schools are secure from the destructive influence of illicit drugs.”
 
The policy includes six priorities: 1) reduce the number of overdose fatalities, with a focus on fentanyl; 2) secure global supply chain against drug trafficking; 3) stop the flow of drugs across our borders and into our communities; 4) prevent drug use before it starts; 5) provide treatment that leads to long-term recovery; and 6) innovate in research and data to support drug control strategies.
 
The statement underscores the need to expand access to evidence-based treatments, including medications for opioid use disorder, and includes a focus on “improving integration of mental health treatment with clinical and recovery support services.”
 
In addition, the policy features plans to increase the availability of opioid overdose reversal medications (e.g., naloxone), divert people who use drugs away from the criminal justice system, and promote drug checking strips, among other activities.

Senate Confirms Mehmet Oz, M.D. to Lead CMS

The Senate on Thursday voted 53-45 along party lines to confirm Mehmet Oz, M.D., a cardiothoracic surgeon and TV celebrity, to oversee the Centers for Medicare & Medicaid Services (CMS).
 
Oz takes the helm of the influential federal agency that insures nearly half of all Americans through Medicare and Medicaid during a time of fierce scrutiny for HHS following news that the federal department had cut about 10,000 jobs.
 
According to news reports, Oz said during his Senate confirmation hearing to become CMS administrator that he plans to sell some of his investments, including his stakes in UnitedHealth Group, the nation’s largest provider of private Medicare plans; Inception Fertility Holdings, a privately held company that operates a chain of clinics; and Amazon, which now includes an online pharmacy and sells numerous medical devices and equipment.

NABH Sends Letter to House Lawmakers Urging Congress to Pass SUPPORT Act of 2025

NABH on Tuesday sent a letter to House Energy Commerce and Committee Chairman Brett Guthrie (R-Ky.) and Ranking Member Frank Pallone (D-N.J.), leaders of one of the House panels that oversees healthcare policy, to urge them and their peers to pass H.R. 2483, the SUPPORT Act for Patients and Communities Reauthorization Act of 2025.
 
“The original SUPPORT Act of 2018 provided the largest congressional investment in overdose prevention and this vital, must-pass legislation sustains those existing prevention efforts and improves the nation’s overall behavioral healthcare infrastructure,” NABH wrote in its letter. “We view the 2025 bill as long-overdue and critical legislation needed to sustain existing prevention efforts and improve the nation’s overall behavioral healthcare infrastructure.”
 
The letter outlined provisions in the legislation that align with NABH priorities, such as preventing overdoses with controlled substances and improving access to addiction medicine providers, as well as provisions for student loan repayment programs for substance use disorder treatment workforce and required training for prescribers of controlled substances.

NABH Joins Mental Health Partners in Statement About Recent HHS Job Cuts

NABH this week was one of 12 organizations that released a statement highlighting the effects that HHS’ recent staffing cuts will have on patients who require mental health (MH) and substance use disorder (SUD) treatment services.
 
Together with NAMI, Mental Health America, the American Psychiatric Association, the American Psychological Association, and other associations, NABH expressed serious concerns about what comes next for the many MH and SUD programs that the Substance Abuse and Mental Health Services Administration, the Centers for Disease Control and Prevention, and the National Institutes of Mental Health oversee.
 
“Unfortunately, the immediate reduction in force means these agencies will lose staff with years of experience and expertise, and the pathway for the transition of their knowledge and the critical services they operate is unclear,” the letter said. “This has the potential to jeopardize years of work and recent progress, like reducing overdose deaths.”
 
NABH and our partners urged the Trump administration to reconsider the steep job cuts and ask HHS Secretary Robert F. Kennedy, Jr. to explain “the impact of these significant changes to HHS staffing for mental health, suicide prevention, and substance use programs and the expected impact on outcomes for the tens of millions of Americans with behavioral health conditions.”

Register Today for Hill Day 2025!

NABH is eager to welcome its members and guests to Hill Day on Wednesday, May 14 from 10:30 a.m. – 2:30 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.
 
How it Works:
After you register for the 2025 Annual Meeting and indicate that you will participate in Hill Day, the NABH government relations team will e-mail you and work with your team to tailor your experience so you meet with representatives and senators in your facilities’ districts.

Closer to Hill Day, our team will send you a meeting schedule, materials, and talking points to guide your conversations with Members of Congress and their staff. Please email Emily Wilkins if you have questions.

And please remember to reserve your hotel room if you haven’t yet. The hotel cut-off date is two weeks from today: Friday, April 18.
 
We look forward to seeing you in Washington!

Fact of the Week

A national survey of 3,024 physicians across specialties between 2020 and 2021 found that 70.4% worked during vacation days. In addition, 59.6% reported taking 15 or fewer vacation days in the previous year. Physicians cited finding clinical coverage, financial impact, and electronic health record (EHR)  inbox volume as barriers to taking vacations, according to the findings published in JAMA Network Open last month.

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

Trump Administration Revokes Billions in Healthcare Program Funding & Announces HHS Restructuring

HHS has discontinued more than $11 billion in pandemic-era funding for the Centers for Disease Control and Prevention (CDC) programs and about $1 billion for Substance Abuse and Mental Health Services (SAMHSA) grants, news outlets reported this week.
 
“The COVID-19 pandemic is over, and HHS will no longer waste billions of taxpayer dollars responding to a non-existent pandemic that Americans moved on from years ago,” HHS said in a statement that appeared in multiple news stories, including The New York Times, AP, and NPR.
 
NBC first reported the news, and later The New York Times reported that SAMHSA grant funding had been scheduled to run through September 2025, while some CDC grants from the pandemic were expected to last through 2026 and 2027.
 
“The funds from SAMHSA were not earmarked for Covid programs, and they were intended to address mental health and substance use issues,” The New York Times reported on Wednesday. “The pandemic led to widespread loneliness, boredom and anxiety, factors that contributed to a surge in overdose deaths that reached just over 111,000 in 2022, up from about 70,000 in 2019.
 
Following that news, HHS on Thursday announced a major restructuring that will cut 10,000 jobs within the department and create a new agency that combines five existing HHS agencies into one, among other changes.
 
The new Administration for a Healthy America, or AHA, will combine the Office of the Assistant Secretary for Health (OASH), Health Resources and Services Administration (HRSA), SAMHSA, Agency for Toxic Substances and Disease Registry (ATSDR), and National Institute for Occupational Safety and Health (NIOSH) into a new, unified entity. 
 
“The restructuring will address this and serve multiple goals without impacting critical services,” the HHS announcement said. “First, it will save taxpayers $1.8 billion per year through a reduction in workforce of about 10,000 full-time employees who are part of this most recent transformation. When combined with HHS’ other efforts, including early retirement and Fork in the Road, the restructuring results in a total downsizing from 82,000 to 62,000 full-time employees,” it continued. “Secondly, it will streamline the functions of the department. Currently, the 28 divisions of the HHS contain many redundant units. The restructuring plan will consolidate them into 15 new divisions, including a new Administration for a Healthy America, or AHA, and will centralize core functions such as Human Resources, Information Technology, Procurement, External Affairs, and Policy. Regional offices will be reduced from 10 to 5.”

NABH Sends Statement to House Veterans’ Affairs Health Subcommittee

NABH this week submitted a written statement for the record to the House Veterans’ Affairs Health Subcommittee, which held an oversight hearing Tuesday to examine the U.S. Veterans Affairs Department’s (VA) practices for mental health policies.
 
In it, NABH noted that NABH staff has engaged with the House Veterans’ Affairs Committee and is pleased with the Committee’s continued focus and engagement with the Trump administration to ensure both the MISSION Act of 2018 and the Sen. Elizabeth Dole 21st Century Veterans Healthcare and Benefits Improvement Act (Dole Act), (P.L. 118-210) – which became law on Jan. 2, 2025 – are implemented fully.
 
NABH also strongly urged policymakers to pass the Veterans’ Assuring Critical Care Expansions to Support Servicemembers (ACCESS) Act of 2025, which will 1) codify current community care access standards as the minimum access standards; 2) expand them to include all extended care services, including mental health residential rehabilitation; and 3) require the VA to ensure that veterans are screened for mental health residential rehabilitation treatment programs within 48 hours of the time the veteran or his or her provider requests admittance, among numerous other important provisions.
 
NABH’s statement also discussed the Community Care Program and concerns we have received from our members.
 
“In early 2023, NABH members who provide care to veterans through the Community Care Program sounded the alarm to NABH staff that VA gatekeepers increasingly denied clinically appropriate and timely care to veterans receiving behavioral healthcare services,” NABH’s statement said. “Members noticed a pattern of delayed care that exceeded the amount of time the MISSION Act of 2018 promises them,” it continued. “Veterans who need residential treatment services have faced waiting times for services that far exceed the 28-day limit for specialty care, making them eligible to seek community care services. And while different VA VISNs and regions operate independently, this situation is not confined to any particular geographic region. VA referrals to providers in the CCN are down more than 80% – a fact multiple NABH members have corroborated. In fact, some markets appear to have ceased third-party referrals altogether.”
 
Click here to read the full statement.

Experts Issue Call to Action on Contingency Management

The American Journal of Psychiatry on Wednesday published a call to action that promotes making available evidence-based contingency management (CM), an effective substance use disorder treatment. The call to action highlights the significant toll of stimulant-involved overdose deaths and underscores the need for regulatory changes and stronger financing to facilitate the uptake of this intervention.
 
In January, SAMHSA published an advisory that raised the annual CM incentive limit to $750 per patient from $75 per patient for entities that implement CM using funds from the State Opioid Response and Tribal Opioid Response grant programs.
 
Several contingency management experts in academia, as well as Sarah Wattenberg, NABH’s former director of quality and addiction services, developed the call to action.

Court Approves Delay on Trump Administration Response to Parity Lawsuit

The United States District Court for the District of Columbia on Tuesday approved the Trump administration’s request for a delay in responding to the ERISA Industry Committee’s lawsuit regarding the updated rule implementing the Mental Health Parity and Addiction Equity Act in commercial insurance plans.
 
The deadline to respond was originally set for March 28, and is now set for May 12.

Reserve Your Hotel Room Today for the 2025 Annual Meeting!

Please remember to reserve your hotel room today at the Salamander Washington, DC for the 2025 NABH Annual Meeting from May 12-14, 2025! The Salamander, Washington DC’s reservation cut-off date is Friday, April 18.
 
And please remember to register for this year’s Annual Meeting, Behavioral Health is Everyone’s Concern: Constant Care, Changing Times, if you haven’t done so yet.
 
We look forward to seeing you in Washington!

Fact of the Week

Public restrooms continue to be used as drug-consumption sites for the privacy restrooms offer, especially in major cities such as Boston, Chicago, and New York. A recent Health Affairsstory examines a “promising yet underrecognized” harm-duction tool for restrooms: the anti-motion sensor, which is designed to detect when a person has been motionless for an extended period of time, signaling a potential overdose and the need for assistance.

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

NABH Sends Telemedicine Proposed Rule Comments to DEA

NABH this week sent a letter to the U.S. Drug Enforcement Administration (DEA) opposing various components of DEA’s proposed rule, Special Registrations for Telemedicine and Limited State Telemedicine Registrations, pertaining to clinical practitioners.
 
“In particular, we are concerned that several requirements misalign with medical practice and would ultimately disrupt access to schedule II-V controlled substances for people with attention deficit/hyperactivity disorder (ADHD), anxiety disorders, binge eating disorder (BED), and other behavioral health conditions,” NABH wrote in its letter to DEA Acting Administrator Derek Maltz. “NABH supports establishing a Special Registration that enables practitioners to prescribe Schedule II-V controlled substances via telemedicine without conducting an in-person medical evaluation.”
 
NABH’s other recommendations include, but are not limited to, streamlining processes,
permitting practitioners to accept patient-submitted documents with their identity information (e.g., photo of patient presenting their photo identification) prior to an initial telemedicine appointment, and removing the requirements for record keeping at a single location and annual data reporting by clinician special registrants because they would present a substantial burden for some behavioral healthcare practitioners who are likely to seek a Special Registration.

Axios Highlights Innovative New Season Clinic

NABH congratulates NABH Board Chair Jim Shaheen and his team at New Season for an innovative effort to expand opioid use disorder (OUD) treatment for people experiencing homelessness in Portland, Ore.
 
News website Axios reported this week that New Season last September launched a Mobile Medication Unit (MMU), a van-based extension of an Opioid Treatment Program that offers medication for OUD (e.g., methadone, buprenorphine), counseling, and other services. The MMU makes multiple stops across the city, which helps address transportation barriers and enables more convenient access to care.
 
Despite a regulatory change in 2021 that helped pave the way for MMUs, a variety of challenges inhibit broader implementation. As of September 2024, there were 54 MMUs across the United States.
 
NABH is eager to hear more stories about our members’ innovative practices. Please email Jessica Zigmond at NABH if you would like to share one.

DEA and HHS Further Delay Buprenorphine Telehealth Rule Implementation

In line with President Trump’s regulatory freeze, DEA and HHS are further delaying the implementation of a final rule issued in January that would allow providers to prescribe buprenorphine for opioid use disorder via telehealth (including audio-only) for up to six months before conducting an in-person medical evaluation.
 
This rule will partially make permanent the COVID-19 pandemic-era flexibilities for prescribing buprenorphine via telehealth without ever having conducted an in-person medical evaluation.

Originally the rule was scheduled to take effect on Feb.18, 2025 and then delayed until Mar. 21, 2025. The rule is now delayed until Dec. 31, 2025.

Purdue Pharma Proposes New Settlement Agreement

On Tuesday, Purdue Pharma – the manufacturer of OxyContin – proposed a new agreement in bankruptcy court to settle lawsuits related to the company’s role in the overdose crisis. This settlement agreement would involve payments of up to $7 billion.
 
A previous settlement agreement was ultimately blocked after the U.S. Supreme Court ruled an agreement component that held the company owners immune from future lawsuits was unlawful. The current proposed agreement does not include this immunity.
                               
Meanwhile, there has been controversy surrounding how current opioid settlement dollars are being used, including questionable activities and using them to supplant existing funding sources and fill budget gaps.

Kennedy Renews Nation’s Opioid Crisis as a Public Health Emergency

HHS Secretary Robert F. Kennedy, Jr. on Tuesday renewed the public health emergency (PHE) declaration to address America’s opioid crisis, which will allow sustained federal coordination efforts and preserve key flexibilities to help HHS respond to the crisis.
 
“Although overdose deaths are starting to decline, opioid-involved overdoses remain the leading cause of drug-related fatalities,” Kennedy said in an announcement. “This administration is going to treat this urgent crisis in American health as the national security emergency that it is,” he continued.
 
President Trump first declared the opioid crisis as a PHE during his first presidential term in 2017, and it was set to expire today, March 21, 2025. The renewed declaration extends the PHE for 90 days.

ICYMI: NABH Releases Quality Resources on Patient and Staff Health & Safety

NABH recently developed two quality-related resources to help members learn from their peers and inform policymakers, regulators, and the media about the innovative ways our members are working to protect their patients and staff.
 
Inpatient Psychiatric Hospitals and Units Implement Effective Violence-Prevention Measures highlights in bullet-list form how inpatient psychiatric hospital providers apply significant prevention protocols beyond existing workplace safety measures that state and federal laws require. Often inpatient psychiatric hospitals employ additional methods that protect staff who treat a range of patients treated in their hospitals, especially those who are admitted because of their violent behaviors.
 
Meanwhile, in The Right Place at the Right Time: Behavioral Healthcare Solutions to ED Boarding, NABH shares the methods and best practices that association members Avera Behavioral Health Services in South Dakota, Mass General Brigham (an integrated health system that includes NABH member McLean Hospital) in Massachusetts, Rutgers University Behavioral Health Care in New Jersey, and Sharp Mesa Vista in California have developed and implemented successful solutions to the persistent problem of “boarding,” the practice of holding patients with behavioral health conditions in a hospital’s Emergency Department (ED) after admission because no inpatient beds are available.
 
NABH has posted these factsheets in the Resources section of our homepage and will promote both on LinkedIn at the National Association for Behavioral Healthcare and @NABHBehavioral. Please share these tools with your teams and others who would find the information useful!
 
The association thanks members of the NABH Quality Committee for their ideas and their help developing these resources.

Register for the 2025 Annual Meeting and View Our Program At-a-Glance!

The 2025 NABH Annual Meeting — Behavioral Health is Everyone’s Concern: Constant Care, Changing Times – is an opportunity for our members to learn about these innovations and for companies to generate business development leads by networking with behavioral healthcare industry leaders.  
 
Please take a moment to view our 2025 Exhibitor and Sponsor Opportunities to learn about the sessions, events, meetings, and services that are available to exhibitors and sponsors at this year’s NABH Annual Meeting and share our 2025 Exhibitor and Sponsor Opportunities with those who might be interested. And many thanks to our exhibitors and sponsors who have committed to supporting this year’s Annual Meeting!
 
If you haven’t done so yet, please register for the meeting and reserve your hotel room at the Salamander Washington, DC before the hotel cut-off date on Friday, April 18!

Fact of the Week

New provisional data from CDC’s National Vital Statistics System predict a nearly 24% decline in drug overdose deaths in the United States for the 12 months ending in September 2024, compared with the previous year. This is the most recent national data available and shows a continued steep decline in overdose deaths.  

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

House and Senate Consider Stopgap Funding Bill to Avert Government Shutdown

The House of Representatives on Tuesday passed a seven-month funding patch aimed at averting a government shutdown by Friday night, March 14.
 
The stopgap Continuing Resolution (CR) would fund government operations through the remainder of this fiscal year while slashing non-defense funding by roughly $13 billion and increasing defense spending by about $6 billion more than current budgets.
 
The CR keeps federal agencies operating under last year’s budget constraints and maintains a 2% across-the-board sequestration cut to Medicare provider payments.
 
In addition, the bill extends $2.4 billion in funding for Community Health Centers (CHCs), the National Health Service Corps (NHSC) and Teaching Health Centers through Sept. 30 while also delaying $1.3 billion in Medicaid Disproportionate Share Hospital (DSH) cuts. Medicare telehealth flexibilities would remain in place through the end of the fiscal year at an estimated cost of $557 million, while hospital-at-home waivers would also be extended. The bill also extends $191 million in increased Medicare payments for low-volume hospitals, $63 million for Medicare-dependent hospitals, and $27 million in add-on payments for ambulance services.
 
Ultimately the House-passed CR didn’t include language to reverse the Centers for Medicare & Medicaid Services’ 2.83% Medicare physician pay cut, despite intense lobbying for its inclusion. However, the Republican congressional “Doc Caucus” received assurances from Republican congressional leaders that a Medicare “doc fix” would be in the upcoming reconciliation bill. According to the American Medical Association, medical practice costs are 3.5% higher this year alone and Medicare reimbursements are 33% lower than in 2001, adjusted for inflation.
 
The Senate now must accept or reject the House legislation to avert a government shutdown Friday night. The Republican Majority will need at least eight Democrats to cross the aisle to reach the 60-vote threshold. Initial actions by Senate Democrats indicate united opposition to the bill; however, it’s expected that enough Democrats will cross the aisle to pass the bill.

Reps. Norcross, Fitzpatrick and Courtney Reintroduce Parity Enforcement Act

House Reps. Donald Norcross (D-N.J.) Brian Fitzpatrick (R-Pa.) and Joe Courtney (D-Conn.) have reintroduced H.R. 957, The Parity Enforcement Act, legislation that would expand the U.S. Labor Department’s (DOL) authority to enforce the Mental Health Parity and Addiction Equity Act.
 
The much-needed legislation holds insurance companies accountable and provides DOL with the tools necessary to impose civil monetary penalties for violating mental health parity requirements.
 
The legislation was introduced with six cosponsors on Feb. 4 and referred to the House Education and Workforce Committee. NABH expects Sens. Chris Murphy (D-Conn.), Tina Smith (D-Minn.) and Ben Ray Lujan (D-N.M.) to introduce companion legislation. NABH is contacting congressional offices to ask lawmakers to co-sponsor the legislation and push for committee hearings.
 
NABH president and CEO Shawn Coughlin sent the sponsors a letter thanking the lawmakers for their efforts and highlighting the continued inequities of care. The letter cites the Wit v. United Behavioral Health case as an example of a major health plan using substandard mental health and substance use disorder treatment criteria to deny medically necessary care.

NABH Sends AI Action Plan Recommendations to National Science Foundation

NABH on Thursday sent the National Science Foundation (NSF) a letter with recommendations to help develop an artificial intelligence (AI) action plan as a response to the NSF’s request for information in late January. Specifically, we call for the NSF to consider the limited capacity of behavioral healthcare information technology and AI when developing the national plan. 
 
Our letter highlighted NABH member responses to NABH’s AI surveys, including that our members are focused presently on using AI to improve care quality by augmenting the role of diagnostic and other decision-making by clinical practitioners; raising the efficiency of business operations such as medical record documentation-related functions; and improving workforce retention through related reduction in administrative burden.
 
‘With regard to the scope of AI rollout, our AI survey results indicate that one-third or fewer of our members are using AI,” the letter continued. “In addition, we note the growing use of telephone apps and online services being used, in part with AI functions, to provide behavioral healthcare services that appear, at least in part, to fall outside of evidence-based care. These platforms can be purchased by individuals who want support related to actual and perceived depression, anxiety, PTSD, psychosis and ADHD. We note that some of these prescription digital therapeutics are subject to FDA review.”

ICYMI: NABH Releases Quality Resources on Patient and Staff Health & Safety

NABH recently developed two quality-related resources to help members learn from their peers and inform policymakers, regulators, and the media about the innovative ways our members are working to protect their patients and staff.
 
Inpatient Psychiatric Hospitals and Units Implement Effective Violence-Prevention Measures highlights in bullet-list form how inpatient psychiatric hospital providers apply significant prevention protocols beyond existing workplace safety measures that state and federal laws require. Often inpatient psychiatric hospitals employ additional methods that protect staff who treat a range of patients treated in their hospitals, especially those who are admitted because of their violent behaviors.
 
Meanwhile, in The Right Place at the Right Time: Behavioral Healthcare Solutions to ED Boarding, NABH shares the methods and best practices that association members Avera Behavioral Health Services in South Dakota, Mass General Brigham (an integrated health system that includes NABH member McLean Hospital) in Massachusetts, Rutgers University Behavioral Health Care in New Jersey, and Sharp Mesa Vista in California have developed and implemented successful solutions to the persistent problem of “boarding,” the practice of holding patients with behavioral health conditions in a hospital’s Emergency Department (ED) after admission because no inpatient beds are available.
 
NABH has posted these factsheets in the Resources section of our homepage and will promote both on LinkedIn at the National Association for Behavioral Healthcare and @NABHBehavioral. Please share these tools with your teams and others who would find the information useful!
 
The association thanks members of the NABH Quality Committee for their ideas and their help developing these resources.

ICYMI: Please Read and Share NABH’s 2025 Advocacy Priorities!

NABH urges you to share our 2025 Advocacy Priorities with your Government Relations teams and others who want to learn more about the behavioral healthcare field’s most pressing issues..
 
Leading NABH’s 2025 Advocacy Priorities are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.
 
NABH will continue to promote the 2025 Advocacy Priorities @NABHBehavioral and at the National Association for Behavioral Healthcare on LinkedIn. Please follow us on these platforms and help us promote your priorities!

Register for the 2025 Annual Meeting and View Our Program At-a-Glance!

Please take a moment to view our 2025 Annual Meeting At-a-Glance, which highlights a few program changes this year, such as hosting Hill Day on the Annual Meeting’s last day: Wednesday, May 14. NABH will share information about Hill Day and our Annual Meeting speakers, exhibitors, sponsors, and events in weekly Annual Meeting Alerts until the meeting kicks off on Monday, May 12.

Please be sure to register for the meeting and reserve your hotel room at the Salamander Washington, DC, before the hotel cut-off date on Friday, April 18!

Fact of the Week

Nearly one in 10 people in the United States will experience an eating disorder in their lifetime, according to the Substance Abuse and Mental Health Services Administration. Click here to read about some common eating disorder myths and related facts.

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

NABH Recommends a Distinct Cybersecurity Proposal for Behavioral Healthcare

NABH submitted comments to the U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) on a proposed rule to strengthen cybersecurity for protected health information. Our comments express strong caution that the proposed rule does not account for the limited health information technology (HIT) capacity in the behavioral healthcare field.
 
Despite the ongoing urgency of the behavioral healthcare crisis, too many behavioral healthcare providers continue to lag a generation behind the HIT capacity of our physical healthcare peers – largely due to the exclusion of many behavioral healthcare providers from the Health Information Technology for Economic and Clinical Health Act.
 
With these concerns in mind, NABH recommended that OCR conduct a review of behavioral healthcare providers’ HIT assets and capacity, relative to the specific technical components of the proposed rule.

NABH Welcomes VA Secretary Collins in Letter Emphasizing Attention to Veterans’ Behavioral Healthcare Needs

On Tuesday, NABH sent a letter to Doug Collins congratulating him on being confirmed as the Secretary of Veterans Affairs. The letter highlights the significant behavioral health conditions experienced by veterans, ranging from post-traumatic stress disorder to alcohol use disorder, as well as the high rate of suicide.
 
The letter also describes the importance of access to behavioral healthcare services offered by third-party providers to augment services delivered within the U.S. Department of Veterans Affairs (VA) system: “The VA’s Community Care Program offers critical flexibility, ensuring there is always capacity available when and where a veteran needs it – even when a wait list at a local VA is long.”
 
The letter continues by describing challenges that NABH members have encountered with VA gatekeepers for the Community Care Program, resulting in barriers for veterans to access third-party providers despite them facing lengthy wait times for care at VA facilities.

CMS Rescinds Guidance on Health-Related Social Needs

This week, the Centers for Medicare & Medicaid Services (CMS) rescinded guidance on coverage of services for health-related social needs (HRSN) – including housing and nutrition interventions – in Medicaid and the Children’s Health Insurance Program.
 
These guidance documents described the various pathways for states to offer coverage for HRSN services for populations in need, such as beneficiaries who have behavioral health conditions or are transitioning out of institutional care settings. As of November 2024, ten states had received approval from CMS to cover HRSN services through a Section 1115 demonstration, one of several pathways.
 
Going forward, CMS will assess states’ applications to cover HRSN services on a case-by-case basis.

Register Today for the 2025 NABH Annual Meeting!

Registration is now open for the 2025 NABH Annual Meeting, Behavioral Health is Everyone’s Concern: Constant Care, Changing Times, from May 12-14, 2025 at the Salamander Washington, DC!

2025 marks 60 years since President Lyndon Johnson passed The Social Security Amendments of 1965 that created the Medicare and Medicaid programs. Although much has changed in the U.S. behavioral healthcare system in six decades, one thing remains constant: our members’ devotion to delivering quality care and treatment. 

Please join us to network with your peers; learn from experts about critical topics such as parity, workforce, and information technology; visit your congressional leaders on Capitol Hill; and explore new products and resources from our exhibitors.

Click here to register and reserve your hotel room today. 

We look forward to seeing you in Washington!

ICYMI: NABH Releases Quality Resources on Patient and Staff Health & Safety

NABH recently developed two quality-related resources to help members learn from their peers and inform policymakers, regulators, and the media about the innovative ways our members are working to protect their patients and staff.
 
Inpatient Psychiatric Hospitals and Units Implement Effective Violence-Prevention Measures highlights in bullet-list form how inpatient psychiatric hospital providers apply significant prevention protocols beyond existing workplace safety measures that state and federal laws require. Often inpatient psychiatric hospitals employ additional methods that protect staff who treat a range of patients treated in their hospitals, especially those who are admitted because of their violent behaviors.
 
Meanwhile, in The Right Place at the Right Time: Behavioral Healthcare Solutions to ED Boarding, NABH shares the methods and best practices that association members Avera Behavioral Health Services in South Dakota, Mass General Brigham (an integrated health system that includes NABH member McLean Hospital) in Massachusetts, Rutgers University Behavioral Health Care in New Jersey, and Sharp Mesa Vista in California have developed and implemented successful solutions to the persistent problem of “boarding,” the practice of holding patients with behavioral health conditions in a hospital’s Emergency Department (ED) after admission because no inpatient beds are available.
 
NABH has posted these factsheets in the Resources section of our homepage and will promote both on LinkedIn at the National Association for Behavioral Healthcare and @NABHBehavioral. Please share these tools with your teams and others who would find the information useful!
 
The association thanks members of the NABH Quality Committee for their ideas and their help developing these resources.

ICYMI: Please Read and Share NABH’s 2025 Advocacy Priorities!

NABH recently released its 2025 Advocacy Priorities, which we urge you to read and share with your Government Relations teams and others.
 
Leading NABH’s 2025 Advocacy Priorities are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.
 
NABH will continue to promote the 2025 Advocacy Priorities @NABHBehavioral and at the National Association for Behavioral Healthcare on LinkedIn. Please follow us on these platforms and help us promote your priorities!

Fact of the Week

According to a recent study published in Health Affairs, Medicare enrollment at age 65 led to a 14% increase in visits to primary care providers and a 31% increase in visits to other providers, with the former more prominent among Medicare Advantage enrollees. However, visits to mental healthcare providers did not change.

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

House Passes Multitrillion-Dollar Budget Bill

The House on Tuesday narrowly passed its multitrillion-dollar budget resolution in a near party-line vote of 217-215, a key step toward advancing President Trump’s sweeping domestic policy agenda.
 
The Senate passed a competing plan last week, and the Republicans in the two chambers must now reconcile the significant differences between the two fiscal blueprints. Congressional leaders also must deal with a more immediate issue: the March 14 government shutdown deadline before moving to the next steps of reconciliation.
 
For its part, the Senate is looking to avert deep cuts to Medicaid, while the House is relying on those cuts for significant cost-shifting. Senate Republicans have insisted they will not support a final measure that extends Trump’s 2017 tax cuts only temporarily, which would require making significant changes to the House blueprint.
 
The House budget tasks the Energy & Commerce Committee, which has jurisdiction over Medicaid, to find $880 billion in funding cuts during the next decade. Advocates including NABH, hospitals, and patient groups have expressed concern to Congress that this will lead to deep cuts to the Medicaid program. A faction of the GOP conference – moderate Republicans, many of whom represent swing districts – also have qualms about the scale of the Medicaid cut the budget plan suggests. House leaders have indicated Medicaid savings would come from cutting “waste, fraud, and abuse;” however, many lawmakers remain skeptical that such large savings can be reached without affecting their constituents.
 
The most difficult part of the reconciliation process now begins. House and Senate leaders want to send a reconciliation package to President Trump by early May, although many expect the timeline to extend until Fall. It remains uncertain whether the House and Senate will hold a formal conference committee, or if the two chambers will engage in informal negotiations with Trump administration officials to reach a compromise.
 
NABH is contacting congressional offices to emphasize that behavioral health conditions such as major depressive disorder, schizophrenia, and opioid use disorder are highly prevalent among Medicaid beneficiaries. Decreasing provider payments, restricting benefits, and limiting eligibility – including new work requirements – could affect millions of Americans living with severe mental illness, putting vital mental health services and care at risk and leading to devastating consequences for individuals and families already struggling to access the support they need. 

FDA Discontinues the Clozapine REMS Program

The Food and Drug Administration (FDA) on Monday announced it will discontinue the risk evaluation and mitigation strategies (REMS) program for clozapine, an antipsychotic medication indicated for treatment-resistant schizophrenia and recurrent suicidal behavior among people with schizophrenia or schizoaffective disorder.
 
This REMS program was intended to reduce the risk of severe neutropenia, which clozapine can induce by lowering the number of neutrophils— a type of white blood cell involved in the immune response to infections. The REMS program required clinicians to conduct blood tests before initiating patients on clozapine and then every week, other week, or month, depending on how long the patient had been treated with clozapine and their neutrophil count. Clinicians then reported neutrophil counts to a centralized database that pharmacists checked before dispensing.
 
Given the significant undertreatment of schizophrenia, effectiveness of clozapine, and feedback FDA received on the burdens of the REMS program, the agency determined that “although the risk of severe neutropenia with clozapine still exists… the REMS program for clozapine is no longer necessary to ensure the benefits of the medicine outweigh that risk.”

White House Executive Order on Pricing Transparency

President Trump signed an executive order on Tuesday intended to make healthcare pricing more transparent by directing federal agencies to enforce an order he signed during his first term as president.
 
The order instructs the Health and Human Services, Labor, and Treasury Departments to develop a framework within 90 days to enforce Trump’s June 2019 executive order forcing health insurers and hospitals to disclose healthcare cost details.

ICYMI: NABH Releases Quality Resources on Patient and Staff Health & Safety

NABH recently developed two quality-related resources to help members learn from their peers and inform policymakers, regulators, and the media about the innovative ways our members are working to protect their patients and staff.
 
Inpatient Psychiatric Hospitals and Units Implement Effective Violence-Prevention Measures highlights in bullet-list form how inpatient psychiatric hospital providers apply significant prevention protocols beyond existing workplace safety measures that state and federal laws require. Often inpatient psychiatric hospitals employ additional methods that protect staff who treat a range of patients treated in their hospitals, especially those who are admitted because of their violent behaviors.
 
Meanwhile, in The Right Place at the Right Time: Behavioral Healthcare Solutions to ED Boarding, NABH shares the methods and best practices that association members Avera Behavioral Health Services in South Dakota, Mass General Brigham (an integrated health system that includes NABH member McLean Hospital) in Massachusetts, Rutgers University Behavioral Health Care in New Jersey, and Sharp Mesa Vista in California have developed and implemented successful solutions to the persistent problem of “boarding,” the practice of holding patients with behavioral health conditions in a hospital’s Emergency Department (ED) after admission because no inpatient beds are available.
 
NABH has posted these factsheets in the Resources section of our homepage and will promote both on LinkedIn at the National Association for Behavioral Healthcare and @NABHBehavioral. Please share these tools with your teams and others who would find the information useful!
 
The association thanks members of the NABH Quality Committee for their ideas and their help developing these resources.

ICYMI: Please Read and Share NABH’s 2025 Advocacy Priorities!

NABH recently released its 2025 Advocacy Priorities, which we urge you to read and share with your Government Relations teams and others.
 
Leading NABH’s 2025 Advocacy Priorities are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.
 
NABH will continue to promote the 2025 Advocacy Priorities @NABHBehavioral and at the National Association for Behavioral Healthcare on LinkedIn. Please follow us on these platforms and help us promote your priorities!

2025 NABH Annual Meeting Registration Opening Soon!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for this year’s NABH Annual Meeting: Behavioral Health is Everyone’s Concern: Constant Care, Changing Times.
 
Our thanks to this year’s Annual Meeting Program Committee, which approved this year’s theme. NABH Board Member Patricia Toole, M.A.S. from Hackensack Meridian Health Carrier Clinic chairs the Program Committee, which also includes NABH members Mary-Catherine Bohan, M.S.W. from Rutgers University Behavioral Health Care and Rhonda Ashley-Dixon, M.A. from Vanderbilt Psychiatric Hospital and Clinics.
 
Annual Meeting registration and a link to hotel reservations at the Salamander will open soon. We look forward to seeing you in Washington!

Fact of the Week

In a recent study of young adults, lifetime history of heavy cannabis use was associated with lower brain activation during a working memory task, according to a recent article in JAMA Network Open.  

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

NABH Releases Quality Resources on Patient and Staff Health & Safety

NABH has developed two quality-related resources to help members learn from their peers and inform policymakers, regulators, and the media about the innovative ways our members are working to protect their patients and staff.
 
Inpatient Psychiatric Hospitals and Units Implement Effective Violence-Prevention Measures highlights in bullet-list form how inpatient psychiatric hospital providers apply significant prevention protocols beyond existing workplace safety measures that state and federal laws require. Often inpatient psychiatric hospitals employ additional methods that protect staff who treat a range of patients treated in their hospitals, especially those who are admitted because of their violent behaviors.
 
Meanwhile, in The Right Place at the Right Time: Behavioral Healthcare Solutions to ED Boarding, NABH shares the methods and best practices that association members Avera Behavioral Health Services in South Dakota, Mass General Brigham (an integrated health system that includes NABH member McLean Hospital) in Massachusetts, Rutgers University Behavioral Health Care in New Jersey, and Sharp Mesa Vista in California have developed and implemented successful solutions to the persistent problem of “boarding,” the practice of holding patients with behavioral health conditions in a hospital’s Emergency Department (ED) after admission because no inpatient beds are available.
 
NABH has posted these factsheets in the Resources section of our homepage and will promote both on LinkedIn at the National Association for Behavioral Healthcare and @NABHBehavioral. Please share these tools with your teams and others who would find the information useful!
 
The association thanks members of the NABH Quality Committee for their ideas and their help developing these resources.

ERIC Requests Stay of Enforcement of September 2024 Final Parity Rule

In an announcement on its website Thursday, the ERISA Industry Committee (ERIC) said it has requested a stay of enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA) final parity rule released last September while the organization’s lawsuit against HHS, the U.S. Labor Department (DOL) and the U.S. Treasury Department challenging the rule’s validity is ongoing.
 
The announcement said former DOL Secretary Eugene Scalia, a partner with the firm Gibson, Dunn & Crutcher that represents ERIC, sent a letter to the three cabinet departments on Feb. 14 asking the agencies to postpone the final rule’s effective date while litigation is pending, which would effectively stay the rule’s enforcement.
 
“ERIC and stakeholders across the employer and behavioral health community long cautioned that the Biden administration’s mental health parity rule could create unintended and adverse consequences,” ERIC’s statement said. “Now that portions of the final rule have gone into effect, those consequences threaten to raise costs and jeopardize patients’ access to safe, effective, and medically necessary mental health support. Taking action to stay the mental health parity rule provides needed certainty to all parties as the suit works its way through the judicial process.”
 
NABH posted a statement about ERIC’s lawsuit in January.

ICYMI: NABH 2025 Advocacy Priorities Now Available!

NABH last week released its 2025 Advocacy Priorities, which we urge you to read and share with your Government Relations teams and others.
 
Leading NABH’s 2025 Advocacy Priorities are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.
 
NABH will continue to promote the 2025 Advocacy Priorities @NABHBehavioral and at the National Association for Behavioral Healthcare on LinkedIn. Please follow us on these platforms and help us promote your priorities!

ICYMI: NABH’s Safe Connections Campaign Highlights Cyber-aggression

NABH recently released and promoted two new resources about cyber-aggression as part of its Safe Connections campaign about healthy minds and social media habits for America’s youth.
 
Please visit our Youth Services page to access all of the Safe Connections resources and share our social media posts on LinkedIn and X.
 
NABH thanks Donald Grant, Ph.D., with Newport Healthcare, and the NABH Youth Services Committee for its work on this campaign.

Join Us in May for the 2025 NABH Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for this year’s NABH Annual Meeting: Behavioral Health is Everyone’s Concern: Constant Care, Changing Times.
 
Our thanks to this year’s Annual Meeting Program Committee, which approved this year’s theme. NABH Board Member Patricia Toole, M.A.S. from Hackensack Meridian Health Carrier Clinic chairs the Program Committee, which also includes NABH members Mary-Catherine Bohan, M.S.W. from Rutgers University Behavioral Health Care and Rhonda Ashley-Dixon, M.A. from Vanderbilt Psychiatric Hospital and Clinics.
 
Annual Meeting registration will open in late February. We look forward to seeing you in Washington!

Fact of the Week

More than 40% of physicians, medical school students, and residents cite the fear of disclosure requirements on licensure forms as a main reason they seek mental healthcare, according to the American Medical Association, which is advocating for legislative and regulatory changes.

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

NABH Releases 2025 Advocacy Priorities!

NABH is pleased to share its 2025 Advocacy Priorities, which we urge you to read and share with your Government Relations teams and others.
 
Leading NABH’s  2025 Advocacy Priorities are parity, workforce, behavioral healthcare information technology, America’s ongoing addiction crisis, and the Institutions for Mental Diseases (IMD) exclusion.
 
“Demand for our services across all age groups nationwide has never been higher, as the country continues to face intense access challenges for both MH and SUD patients,” NABH notes in the resource. “Looking ahead, behavioral healthcare providers are armed with new telehealth tools that were expanded during the national response to the COVID-19 pandemic, which optimize access to care and the reach of the often limited behavioral healthcare workforce that continued to decrease during the crisis. Securing continued telehealth services is an important NABH goal.”
 
NABH will promote the 2025 Advocacy Priorities @NABHBehavioral on X and at the National Association for Behavioral Healthcare on LinkedIn. Please follow us on these platforms and help us promote your priorities!

House and Senate Budgets Take Shape as Medicaid Remains Vulnerable

House and Senate Republican leaders this week diverged on a path forward to enact a budget and President Trump’s domestic agenda.
 
House Speaker Mike Johnson (R-La.), responsible for uniting all factions within his slim majority, has pushed for a one-budget resolution. Meanwhile Senate Majority Leader John Thune (R-S.D.) wants two separate bills that would allow lawmakers to pass easier aspects of government funding – such as energy and border security – while the second bill would tackle more complicated issues, such as healthcare and taxes. Both chambers of Congress made progress on their respective bills this week.
 
In party-line vote of 11-10, the Senate Budget Committee on Wednesday evening passed a budget resolution to approve the fiscal framework for a package of energy, border security, and defense policy through the partisan budget reconciliation process. Senate Budget Chair Lindsey Graham (R-S.C.) framed the two-track Senate strategy as a backup plan if House Republicans fail to move swiftly on their own one-bill proposal. The Senate is expected to take up the budget resolution in several weeks.
 
Meanwhile, House Republicans passed their one-bill budget resolution in the House Budget Committee on Thursday. The House GOP budget resolution includes a floor of $1.5 trillion in spending cuts, a $4.5 trillion cap on tax cuts, and a $4 trillion extension of the debt limit. House GOP leadership expects to move the resolution to the House floor in late February. The resolution itself is nonbinding; however, it would unlock Republicans’ ability to bypass the Senate filibuster to move a massive domestic policy bill with President Trump’s legislative priorities.
 
As a result of the House GOP’s budget blueprint – which relies on spending cuts to offset a reconciliation bill – House Energy and Commerce Chair Brett Guthrie (R-Ky.) needs to find at least $880 billion in savings, including from the Medicaid program, which currently insures more than 70 million Americans. Per-capita allotments for Medicaid, which would produce the most savings, likely do not have enough support to pass in the House; however, Medicaid work requirements remain a focus for savings and are considered among the most politically feasible choices for Republicans. The nonpartisan Congressional Budget Office has estimated work requirements could save more than $100 billion over a decade.
 
NABH is communicating with Congress that work requirements must incorporate sufficient exceptions to ensure that individuals whose mental or substance use disorders prevent them from satisfying the requirements remain eligible for Medicaid enrollment and are not terminated from the program. These exceptions should reflect the enormous challenges that people with behavioral health conditions face, many of whom need treatment and cannot access it. Medicaid cuts remain a concern for moderate Republicans who have been working to avert significant cuts to that program.
 
Republicans in both chambers will eventually need to unite around one budget blueprint to be able to vote on a bill that isn’t subject to the Senate filibuster and can pass with 51 votes.

DEA and HHS Delay Buprenorphine Telehealth Rule Implementation

In line with President Trump’s regulatory freeze, the U.S. Drug Enforcement Administration (DEA) and HHS are delaying the implementation of a final rule issued last month that would allow providers to prescribe buprenorphine for opioid use disorder via telehealth (including audio-only) for up to six months before conducting an in-person medical evaluation.
 
The rule was originally scheduled to take effect on Feb.18, 2025 and is now planned for March 21, 2025.
 
DEA and HHS are also accepting comments on whether the effective date should be further delayed, as well as any other concerns about the rule.
 
This rule will partially make permanent the COVID-19 pandemic-era flexibilities for prescribing buprenorphine via telehealth without ever having conducted an in-person medical evaluation.

Trump Signs Executive Order to Establish ‘Make America Healthy Again Commission’

President Donald Trump this week signed an executive order establishing a “Make America Healthy Again Commission” chaired by newly confirmed HHS Secretary Robert F. Kennedy Jr.

The commission is responsible for assessing and providing a strategy on a host of health issues, including a directive to “identify and describe childhood chronic disease in America compared to other countries; assess the threat that potential over-utilization of medication, certain food ingredients, certain chemicals, and certain other exposures pose to children with respect to chronic inflammation or other established mechanisms of disease, using rigorous and transparent data, including international comparisons; assess the prevalence of and threat posed by the prescription of selective serotonin reuptake inhibitors, antipsychotics, mood stabilizers, stimulants, and weight-loss drugs; and more.

ICYMI: NABH’s Safe Connections Campaign Highlights Cyberaggression 

NABH recently released and promoted two new resources about cyber-aggression as part of its Safe Connections campaign about healthy minds and social media habits for America’s youth.

Please visit our Youth Services page to access all of the Safe Connections resources and share our social media posts on LinkedIn and X.

NABH thanks Donald Grant, Ph.D., with Newport Healthcare, and the NABH Youth Services Committee for its work on this campaign.

ICYMI: NABH Analysis on How Medicaid Could Disrupt Behavioral Healthcare Access  

Recently NABH sent all members an analysis explaining how several proposals could lower federal financial participation (FFP) in Medicaid.

These proposals include changing the current formula for Federal Medical Assistance Percentages, instituting caps to FFP at the state- or enrollee-levels (such as by transitioning Medicaid to a block grant), or limiting the existing safe harbor preventing a portion of state taxes on providers’ net patient revenue from being considered when calculating FFP.

Other recommendations have been made to institute work requirements for Medicaid beneficiaries. Click here to read the NABH Analysis from Dan Schwarz, NABH’s director of quality and addiction services.

Join Us in May for the 2025 Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for this year’s NABH Annual Meeting: Behavioral Health is Everyone’s Concern: Constant Care, Changing Times.

Our thanks to this year’s Annual Meeting Program Committee, which approved this year’s theme. NABH Board Member Patricia Toole, M.A.S. from Hackensack Meridian Health Carrier Clinic chairs the Program Committee, which also includes NABH members Mary-Catherine Bohan, M.S.W. from Rutgers University Behavioral Health Care and Rhonda Ashley-Dixon, M.A. from Vanderbilt Psychiatric Hospital and Clinics.

Annual Meeting registration will open in late February. We look forward to seeing you in Washington!

Fact of the Week

A recent study published in JAMA Network Open found that every $100 invested in an employer-sponsored behavioral health program with fast access to psychotherapy and medication management was associated with a reduction in medical claims costs by $190. These findings suggest that expanding access to behavioral health care may be a financially viable cost-reduction strategy for health care buyers.

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

Senate Finance Committee Advances RFK, Jr.’s Nomination for HHS Secretary

The Senate Finance Committee on Feb. 4 advanced Robert F. Kennedy Jr.’s nomination to serve as secretary of the U.S. Health and Human Services Department (HHS).
 
President Donald Trump named Kennedy to lead HHS after Kennedy dropped his own presidential bid and endorsed Trump. Since then, Kennedy has overcome opposition from both Democrats and Republicans concerned about his views on vaccines, abortion, environmental regulation, food production and drug legalization.
 
The Senate panel voted 14-13 along party lines to advance Kennedy to a full Senate vote. During his confirmation hearing, Kennedy promised to work with senators to repeal the federal ban on Medicaid funding for Institutions for Mental Diseases following a question from Sen. Marsha Blackburn (R-Tenn.).
 
“This is a discriminatory exclusion, and it denies payment for medically necessary care based on the illness that is being treated, and it has perpetuated unequal coverage in mental healthcare,” Blackburn noted. “So, if you’re confirmed, when you’re confirmed, will you commit to working with me on repealing this discriminatory exclusion and ensuring equal access to mental health care for Medicaid beneficiaries?”
 
Kennedy answered yes. Congress has previously considered repealing or altering the IMD exclusion, but progress has stalled due to a historically high price tag. Advocates have said they hope this will change because the Congressional Budget Office’s latest estimate found eliminating the IMD exclusion for some or all behavioral healthcare treatments would cost between $7.7 billion and $38.4 billion — far lower than the 2016 proposal’s estimate of $40 billion to $60 billion.
 
Now the full Senate will decide whether Kennedy will lead HHS. A Senate floor vote has not been scheduled, although it is expected to occur soon.
 
Meanwhile, the physician and TV personality Mehmet Oz, M.D., M.B.A. has started meeting with senators to garner support for his nomination to lead the Centers for Medicare & Medicaid Services (CMS). The Senate Finance Committee will also decide whether Oz will lead CMS.
 
Concurrently, the Department of Government Efficiency, or DOGE, has been on-site at CMS to mine key systems for examples of what DOGE considers fraud or waste. The DOGE representatives have gained access to payment and contracting systems.  It remains unclear how the DOGE personnel will use any data from the agency to combat any fraud.
 
In a 77-23 vote, the Senate confirmed former Rep. Doug Collins, a Georgia Republican, to lead the U.S. Veterans Affairs Department (VA). Only Democrats opposed the nominee, who will now inherit an agency that has historically struggled to provide quality healthcare to the millions of veterans it serves. During his confirmation hearing, Collins pledged to expand access to care outside the VA. 

NASHP Releases Report on Behavioral Healthcare Workforce Strategies

The National Academy for State Health Policy (NASHP) this week released Key Strategies for Strengthening the Behavioral Health Workforce after the organization convened a multi-sector roundtable composed of policymakers, payors, providers, employers, and others who examined the issue.
 
The extensive report focused on six themes: 1) understanding the workforce you are building, 2) scaling effective treatment teams for greater impact, 3) better patient matching to need, 4) technological workforce extenders, 5) optimizing the unlicensed skilled workforce, and 6) payment and financing strategies.
 
Click here to read the full report.

MHA Report Examines Social Media and Youth Well-being

Mental Health America recently released Breaking the Algorithm: Redesigning Social Media for Youth Well-being, a report that explores how social media is affecting young people’s mental health, relationships, and daily lives.
 
The report gathers insights from more than 900 survey respondents, focus groups with young people, and conversations with youth co-researcher to analyze the dual nature of social media as both a connector and a source of harm, how algorithms shape youth experiences – often without their full understanding or consent –, and why it’s critical to empower young people with tools, education, and a voice in the systems that share their digital worlds.
 
Click here to read the full report.

ICYMI: NABH’s Safe Connections Campaign Highlights Cyber-aggression

NABH recently released and promoted two new resources about cyber-aggression as part of its Safe Connections campaign about healthy minds and social media habits for America’s youth.
 
Please visit our Youth Services page to access all of the Safe Connections resources and share our social media posts on LinkedIn and X.
 
NABH thanks Donald Grant, Ph.D., with Newport Healthcare, and the NABH Youth Services Committee for its work on this campaign.

ICYMI: NABH Analysis on How Medicaid Proposals Could Disrupt Behavioral Healthcare Access

Recently NABH sent all members an analysis explaining how several proposals could lower federal financial participation (FFP) in Medicaid.
 
These proposals include changing the current formula for Federal Medical Assistance Percentages, instituting caps to FFP at the state- or enrollee-levels (such as by transitioning Medicaid to a block grant), or limiting the existing safe harbor preventing a portion of state taxes on providers’ net patient revenue from being considered when calculating FFP.
 
Other recommendations have been made to institute work requirements for Medicaid beneficiaries. Click here to read the NABH Analysis from Dan Schwarz, NABH’s director of quality and addiction services.

Save the Date: Join Us in May for the 2025 NABH Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for this year’s NABH Annual Meeting.
 
NABH will provide more details soon in future editions of CEO Update and in NABH Annual Meeting Alerts. We look forward to seeing you in Washington!

Fact of the Week

The Centers for Disease Control and Prevention reports the percentage of adults who used electronic cigarettes increased to 6.5% in 2023 from 4.5% in 2019.

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

Senate Committees Hold Hearings for HHS Secretary Nominee

The Senate Finance Committee and Senate Health, Education, Labor, and Pensions Committee held hearings on Wednesday and Thursday, respectively, to consider the nomination of Robert F. Kennedy Jr. for Secretary of Health and Human Services.
 
On issues related to behavioral health, Kennedy indicated a willingness to work with Congress on repealing Medicaid’s Institution for Mental Diseases exclusion, proposed to incorporate more training on substance use disorder treatment into graduate medical education for primary care providers, said that medications for substance use disorders should be available but are not the gold standard of treatment, and suggested that additional studies be conducted on the safety of antidepressants.
 
Prior to the hearings, Patrick Kennedy – former congressman and founder of The Kennedy Forum –  expressed support for his cousin’s nomination with respect to substance use disorder treatment, saying that Robert F. Kennedy Jr. is open to multiple pathways to recovery, including medication.
 
The Senate Finance Committee is expected to vote on Kennedy’s nomination next week.

States’ Access to Medicaid Portals is Restored, but Uncertainty Remains with Federal Funding Pause

On Monday, the White House issued a memo directing federal agencies to temporarily pause spending on a broad swath of programs while their compliance with recent executive orders is reviewed. This coincided with an outage of portals for states to access Medicaid payments, prompting concern that the pause applied to federal Medicaid funding. The White House subsequently issued guidance clarifying that the pause did not apply to Medicaid, and access to portals was restored.
 
Nonetheless, uncertainty remains about the status of the funding pause; a judge temporarily blocked its implementation, after which the White House rescinded the memo that directed the pause but then later stated that the pause is still in effect.
 
NABH continues to monitor this situation as it evolves.

President Trump Issues Executive Order on Transgender Youth Services

President Trump issued an executive order on Tuesday aimed at limiting the use of gender-affirming care (i.e., hormones, hormone blockers, surgery) for youth under age 19 who are transgender or experience gender dysphoria.
 
This order directs federal agencies to ensure that medical institutions receiving research or education grants do not provide such services to youth, as well as consider other actions to prevent the availability of these services, which may involve conditions of participation for Medicare and Medicaid, essential health benefits requirements, and other policies. Among other things, the order also directs TRICARE and federal employees’ health plans to exclude coverage of these services for youth and requires the publication of best practices for youth experiencing gender dysphoria.

NABH is Preparing a Response to the Proposed Rule on Telehealth for Controlled Substances

The Drug Enforcement Administration (DEA) recently proposed a rule regarding the prescribing of controlled substances via telehealth without an in-person evaluation (a final rule specific to prescribing buprenorphine for opioid use disorder via telehealth was also released). The proposed rule includes a variety of concerning items, such as substantial limitations on prescribing schedule II medications, an expansive prescription drug monitoring program review requirement, and the need to obtain multiple registrations. For a summary of the proposed rule, please check out NABH’s issue brief.
 
NABH plans to submit a comment letter outlining concerns with the proposed rule. To inform its development, we would like to meet with interested members to discuss major concerns. If you would like to be involved, please reach out to Dan Schwartz.

The Joint Commission Updates Requirements for Behavioral Healthcare Providers

The Joint Commission made updates to emergency management and infection control requirements in the behavioral healthcare and human services accreditation program, which will take effect on July 1, 2025. For infection control, a fully revised chapter will replace the current requirements, in alignment with updates for other hospitals; see this reference guide on changes to standards. For emergency management, the updates seek to provide more clarity on hazard vulnerability analyses, leadership involvement, and staff education and training.
 
While the NABH Quality Committee will review these updates, all members are encouraged to email any questions or concerns to Rochelle Archuleta.

House Schedules Hearing on Illicit Drug Threats

The House Energy and Commerce Committee’s Health Subcommittee scheduled a hearing on existing and emerging illicit drug threats for February 6. The announcement highlights xylazine and nitazenes as concerning issues and mentions that the hearing will help advance the subcommittee’s previous work to “crack down on drug traffickers; provide support to those suffering from substance use disorder; and restore hope to families, law enforcement, and emergency medical personnel.”
 
Up to now, the federal government has formally designated two emerging drug threats: (1) methamphetamine, and (2) fentanyl adulterated or associated with xylazine.

FDA Approves New Non-Opioid Pain Medication

On Thursday, the Food and Drug Administration (FDA) approved Journavx (suzetrigine), a first-in-class non-opioid oral pain medication indicated for adults with moderate to severe pain. Journavax works by inhibiting the transmission of pain signals in the peripheral nervous system before reaching the brain, which could be associated with a lower risk of dependence relative to opioids.

Researchers Find a Decline in Availability of Some Crisis Services Since 988 Launch

In July 2022, the 988 Suicide and Crisis Lifeline was created to make it easier for people experiencing behavioral health crises to access support than the previous ten-digit dialing code. However, a study found that after 988 launched, several crisis services had less availability nationally: emergency psychiatric walk-in services, mobile crisis response, and suicide prevention services. The greatest decrease was for emergency psychiatric services, a trend that began prior to 988’s launch. Meanwhile, there was an increase in the availability of peer support services.
 
Across states, there were significant differences in changes to crisis service availability, which may be attributable to different funding levels or varying degrees of preparedness for 988. There were also a variety of facility-level factors associated with greater crisis service availability, such as accepting Medicaid or private insurance.
 
Ultimately, the authors indicated that “the lack of meaningful growth in most crisis services may limit the long-term success of 988, in particular if callers feel that reaching out to 988 fails to result in access to appropriate sources of care.”

Study Shows Promising Results from Emergency Department Methadone Bridge Clinic

Findings from a new study indicate that emergency departments have the potential to facilitate uptake of methadone for patients with opioid use disorder. Among a small sample of patients initiating methadone at an emergency department-based bridge clinic, 56% completed linkage to a partner Opioid Treatment Program, and 100% of linked patients were retained in treatment at 30 days.
 
This clinic leveraged a federal rule that allows non-Opioid Treatment Program clinicians to initiate patients with opioid use disorder on methadone by dispensing up to a three-day supply of medication.

Save the Date: Join Us in May for the 2025 NABH Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for the 2025 NABH Annual Meeting.
 
NABH will provide more details soon in future editions of CEO Update and in NABH Annual Meeting Alerts. We look forward to seeing you in Washington!

Fact of the Week

A new JAMA study suggests that mindfulness groups may be useful during opioid use disorder treatment, especially for patients with residual opioid craving while they are prescribed buprenorphine.

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

Second Trump Administration Health Policy Priorities Start to Take Shape

The newly installed Trump administration’s health policy priorities and the senior officials designated with implementing them are coming into focus.
 
Attorney Robert F. Kennedy, Jr. is making the rounds with senators before his confirmation process to lead HHS. Kennedy’s first nomination hearing is scheduled for Wednesday, Jan. 29 before the Senate Finance Committee, with the Senate Health, Education, Labor and Pensions (HELP) Committee scheduled to meet with him the next day. Sen. Mike Crapo (R-Idaho) chairs the Senate Finance Committee, which ultimately will vote whether to advance Kennedy’s nomination to the Senate floor.
 
Meanwhile, the administration has announced candidates for senior staff positions at HHS. These include: John Brooks, a first-term Trump health official who is running the transition’s HHS landing team, will return as chief operating officer at the Centers for Medicare & Medicaid Services (CMS); Drew Snyder is expected to run the CMS’ Medicaid program; Abe Sutton is in line to lead the CMS Innovation Center; Chris Klomp will helm the Medicare program; and Heather Flick, a former senior HHS official during the first Trump term, will return as chief of staff to Kennedy if his appointment is confirmed.
 
At the Office of Management and Budget (OMB), Don Dempsey is expected to return to the agency as associate director overseeing healthcare programs. Dempsey is currently vice president of policy and research at the Better Medicare Alliance.
 
Policy decisions and pronouncements are also moving swiftly. At HHS, a recent agency-wide memo directs officials to refrain from issuing any guidance, regulation, notice or grant announcement until it’s been approved by a presidential appointee. The freeze also applies to press releases, social media posts, website posts, communications via listservs and any speaking engagements.
 
President Trump’s first moves on Medicaid and the Affordable Care Act signal his administration’s willingness to make major changes to the government programs. Trump’s first administration approved several waivers to install Medicaid work requirements, which critics said would only lead to coverage losses. Executive orders for healthcare typically instruct agencies; to date, Trump’s orders only rescind the earlier Biden administration orders and don’t explain how policies should be addressed.
 
On Inauguration Day, Trump issued an Executive Order asking all agencies to refrain from issuing a rule until it has been reviewed and approved by a Trump administration department head, and to immediately withdraw rules that have been sent to the Office of the Federal Register (OFR) but have not been published. Department heads were also directed to postpone the effective data for any rules published in the Federal Register or that have been issued but have not taken effect so that they can be reviewed. Agencies might also consider reopening comment periods and potentially delaying the rules beyond 60 days.
 
That Executive Order presumably includes the 2026 Medicare Advantage and Part D rate notice and 2026 draft Part D redesign guidance released Jan. 10, and the 2026 Notice of Benefit and Payment Parameters finalized on Jan. 13 that became effective two days later.
 
Also unknown is if the Trump administration will choose to fund and implement the Biden Administration’s September 2024 updated parity rule, which established more stringent protocols, amended existing provisions, and added new ones to implement the Mental Health Parity and Addiction Equity Act (MHPAEA).
 
NABH is contacting new administration officials to support the rule and working with partners to continue supporting the landmark 2008 law’s implementation.

HHS, DOL, and Treasury Send 2024 MHPAEA Report to Congress

HHS, the U.S. Labor Department, and U.S. Treasury Department have released the  2024 MHPAEA Report to Congress, which highlights both progress and continued problems implementing the 2008 parity law.
 
A fact sheet from the three agencies noted that in fiscal year (FY) 2023, CMS received 43 MHPAEA-related complaints through the “No Surprises” Help Desk and investigated and closed 599 health plan investigations in FY 2023. Of those investigations, 457 involved issuers offering fully insured group or individual health insurance coverage and 142 involved self-funded non-federal governmental plans.
 
According to a report from Thomson Reuters’ Westlaw Today, a key announcement from the 2024 report is the three agencies’ indication they will release a comparative analysis (CA) with written explanations and supporting documents to show how a plan applied factors and standards in designing non-qualified treatment limitations (NQTLs) consistent with the 2024 final regulations.
 
“The sample CAs will assess various aspects of how NQTLs are designed and applied,” the Westlaw summary said. “In turn, this will help determine whether any processes, strategies, evidentiary standards, or other factors used in designing and applying the NQTL for MH/SUD benefits are comparable to—and not applied more stringently than—those for M/S benefits.”

ICYMI: NABH Analysis on How Medicaid Proposals Could Disrupt Behavioral Healthcare Access

Earlier this week NABH sent all members an analysis explaining how several proposals could lower federal financial participation (FFP) in Medicaid.
 
These proposals include changing the current formula for Federal Medical Assistance Percentages, instituting caps to FFP at the state- or enrollee-levels (such as by transitioning Medicaid to a block grant), or limiting the existing safe harbor preventing a portion of state taxes on providers’ net patient revenue from being considered when calculating FFP.
 
Other recommendations have been made to institute work requirements for Medicaid beneficiaries. Click here to read the NABH Analysis from Dan Schwartz, NABH’s director of quality and addiction services.

Safe Connections: Cyber-aggression Resources

NABH this week released and promoted two new resources about cyber-aggression as part of its Safe Connections campaign about healthy minds and social media habits for America’s youth.
 
Please visit our Youth Services page to access all of the Safe Connections resources and share our social media posts on LinkedIn and X.
 
NABH thanks Donald Grant, Ph.D., with Newport Healthcare, and the NABH Youth Services Committee for its work on this campaign.

Deadline is Today: CMS and Abt Seek Nominations for TEP to Design a Patient Assessment Instrument

CMS and its contractor Abt, a research and consulting firm, are assembling a TEP that will provide guidance on clinical and operational issues to design and implement a patient assessment instrument (PAI).
 
Abt seeks a mix of clinical and operational leaders, including participants with direct knowledge of the patient assessment process. Please refer to the TEP Charter for more information. The TEP will meet periodically for up to four years. All meetings will be held virtually, including the first meeting in February or March 2025.
 
Nomination packets must include a signed TEP nomination form, letter of interest, and CV, all of which must be e-mailed to IPF-PAI_testing@abtglobal.com with “Nomination” in the subject line. The deadline for applications is today, Jan. 24, 2025 at 5 p.m. ET.

Save the Date: Join Us in May for the 2025 NABH Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for this year’s NABH Annual Meeting.
 
NABH will provide more details soon in future editions of CEO Update and in NABH Annual Meeting Alerts. We look forward to seeing you in Washington!

Fact of the Week

A new study published in JAMA Network found that interventions in young people (aged 10 to 24 years old) had a significant short-term association with improvements in stigma-related knowledge, attitudes, and behaviors and help-seeking attitudes and intentions.

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

HHS and DEA Partially Extend COVID-19-Era Telehealth Flexibilities

HHS and the U.S. Drug Enforcement Administration (DEA) on Wednesday proceeded with rulemaking to partially extend COVID-19 pandemic-era flexibilities for prescribing controlled substances via telehealth without ever having conducted an in-person medical evaluation.
 
The federal agencies introduced a final rule focused on buprenorphine for opioid use disorder (OUD), and a notice of proposed rulemaking (NPRM) for special registrations focused on all Schedule II-V controlled substances.
 
The final rule will allow practitioners to prescribe buprenorphine for OUD for up to six months via audiovisual or audio-only telehealth before conducting an in-person medical evaluation, subject to certain requirements. This rule is likely to become effective on Feb. 16, 2025.
 
The NPRM would create multiple special registrations for practitioners to prescribe controlled substances via telehealth indefinitely, including a Telemedicine Prescribing Registration covering Schedules III-V; and an Advanced Telemedicine Prescribing Registration covering Schedules II-V, which would be limited to practitioners with specific specialties (e.g., psychiatry, pediatrics) or who work in long-term care facilities. In addition, practitioners would generally be required to obtain a State Telemedicine Registration for each state in which their patients are located.
 
The NPRM includes various requirements for practitioners, such as noting the special registration number on prescriptions, expansive PDMP checks, reporting certain prescribing information to DEA annually, being physically located in the same state as a patient when issuing a Schedule II prescription, limiting the number of special registration Schedule II prescriptions to less than 50% of the total number Schedule II prescriptions issued each month, and using audiovisual technology (there is an exception for buprenorphine for OUD, whereby audio-only visits are permitted after a telehealth evaluation with audiovisual technology).
 
NABH staff will coordinate with relevant NABH committees to develop a response to the NPRM. We expect that comments will be due by March 18, 2025.
 
Please read NABH’s Issue Brief for more details.

MedPAC Supports Eliminating Medicare’s 190-day Lifetime Limit

The Medicare Payment and Advisory Commission (MedPAC) this week unanimously supported a draft recommendation to Congress to eliminate both Medicare’s 190-day lifetime limit on covered days in freestanding inpatient psychiatric hospitals, as well as the policy that reduces the cap on covered days for patients who received similar care during the 150 days preceding Medicare eligibility.
 
MedPAC reported that while only 50,000 Medicare beneficiaries were at or near the 190-day limit in 2023, this group of patients is “highly vulnerable” relative to the general Medicare population. The Commission projects that changing these 60-year-old policies would increase access to care and cost approximately $50 million in additional federal spending per year.
 
NABH expects the Commission to vote on the measure this month and include the recommendation in the Commission’s annual March report to Congress. The Commission will report its related research on the quality of care and readmissions within 30 days of discharge for these hospitals this spring.

HHS Releases Report on Private Equity in Healthcare

HHS this week released a report highlighting the effects of increasing consolidation in America’s healthcare markets and recent influx of private equity (PE) and other private investors active in the healthcare space.
 
The U.S. Justice Department and the Federal Trade Commission contributed to the nearly 40-page report after the three federal agencies announced a tri-agency collaboration in December 2023 to promote competition in healthcare markets. As part of that effort, the three agencies released a request for information in March 2024 to understand how certain healthcare market transactions among health systems, private insurers, PE funds, and other private investors may increase consolidation and compromise patients’ health, quality of care, and affordability—and may also threaten workers’ safety, satisfaction, and wages while creating taxpayer burden.
 
One of the key findings of the report showed through case studies how PE firms loaded hospitals with debt, sold the hospitals’ underlying assets, and paid investors through dividends and financially engineered sales, resulting in negative consequences such as bankruptcy, closure of facilities and service lines, staffing shortages, and patient safety and quality concerns.
 
The report also included policy recommendations, such as enhancing ownership transparency; increasing disclosures of mergers & acquisitions in healthcare by lowering reporting thresholds, requiring review and approval, and empowering relevant authorities with data and resources needed to conduct review of health care transactions; pursuing further enforcement actions to halt hospital mergers and industry rollup; and continuing to improve data sharing and other collaboration across agencies, Congress, and state and local authorities in an all-government approach to promote competition.  

SAMHSA Releases Updated National Behavioral Health Crisis Care Guidance

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released updated National Behavioral Health Crisis Care Guidance that includes three documents: the 2025 National Guidelines for a Behavioral Health Coordinated System of Crisis Care, Model Definitions for Behavioral Health Emergency, Crisis, and Crisis-Related Services, and Mobile Crisis Team Services: An Implementation Toolkit Draft. 

The updated National Guidance reflects the nation’s transition to the 988 Suicide & Crisis Lifeline in 2022 and other progress and emerging needs related to behavioral health crisis care. It also provides a framework for transforming behavioral health crisis care systems in communities throughout the United States, at a time when the country continues to face record high rates of suicide and overdose.

Reminder: CMS and Abt Seek Nominations for TEP to Design a Patient Assessment Instrument

CMS and its contractor Abt, a research and consulting firm, are assembling a TEP that will provide guidance on clinical and operational issues to design and implement a patient assessment instrument (PAI).
 
Abt seeks a mix of clinical and operational leaders, including participants with direct knowledge of the patient assessment process. Please refer to the TEP Charter for more information. The TEP will meet periodically for up to four years. All meetings will be held virtually, including the first meeting in February or March 2025.
 
Nomination packets must include a signed TEP nomination form, letter of interest, and CV, all of which must be e-mailed to IPF-PAI_testing@abtglobal.com with “Nomination” in the subject line. The deadline for applications is next Friday, Jan. 24, 2025 at 5 p.m. ET.

Update: CMS Launches Innovation in Behavioral Health Model in Four States

At the start of January, the Centers for Medicare & Medicaid Services (CMS) launched an eight-year Innovation in Behavioral Health (IBH) model with the Medicaid agencies in Michigan, New York, Oklahoma, and South Carolina to develop managed care payments for integrated physical and mental healthcare services.
 
These states will partner with managed care organizations and outpatient providers, including physician practices, opioid treatment programs, hospital- or university-affiliated outpatient behavioral healthcare providers, safety net providers and others. Behavioral healthcare provider participants will conduct patient screenings. assessments of behavioral and physical health needs, and other care management functions. Participants will be eligible to receive infrastructure funding and risk-adjusted per-person-per-month integration payments in years two through five, followed by integration payments, performance-based payments and possible bonuses in years four through eight.
 
The infrastructure funding will range from $100,000 to $200,000 per participant and can be used on staffing, information technology (IT,) and workflow changes needed to implement the model, including the adoption and upgrading of electronic health record systems and telehealth tools.
 
To learn more, please refer to the Notice of Funding Opportunity, FAQs, and fact sheet. Those who are interested may register for CMS’ listserv to receive ongoing updates and/or issue questions to CMS’ healthcare strategy team.   

Congratulations to 2023 NABH Board Chair Harsh Trivedi on Joint Commission Appointment

NABH congratulates 2023 NABH Board Chair Harsh Trivedi, M.D., M.B.A on his recent appointment to The Joint Commission’s Board of Commissioners on Jan. 1.

Trivedi, president and CEO of Sheppard Pratt, was one of six new members named to the Commission’s governing body, which advises on strategies to drive organizational success.  
 
Congratulations, Harsh!

Coming Soon: NABH Developing Advocacy Document on Potential Medicaid Changes

NABH is developing an advocacy document to educate policymakers about the risks of proposed changes to Medicaid financing and eligibility.
 
The analysis will describe how state efforts to offset reduced revenue could exacerbate existing challenges with low reimbursement and narrow networks, and it will outline potential issues with applying work requirements to people with behavioral health conditions.
 
NABH’s resource will emphasize the critical need for Medicaid as a funding source for behavioral healthcare organizations, particularly Opioid Treatment Programs.

Save the Date: Join Us in May for the 2025 NABH Annual Meeting!

Please plan to join your peers and the NABH team at the Salamander Washington, DC from May 12-14 for the 2025 NABH Annual Meeting.
 
NABH will provide more details soon in future editions of CEO Update and in NABH Annual Meeting Alerts. We look forward to seeing you in Washington!

Fact of the Week

A National Institutes of Health-funded study of nearly 10,000 adolescents has identified distinct differences in the brain structures of those who used substances before age 15 compared with those who did not. Many of these structural brain differences appeared to exist in childhood before any substance use, suggesting they may play a role in the risk of substance use initiation later in life, in tandem with genetic, environmental, and other neurological factors.

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

NABH Welcomes Jim Shaheen as 2025 Board Chair

NABH is pleased to welcome New Season CEO Jim Shaheen as chair of the NABH Board of Trustees for 2025.
 
A longtime NABH member, Jim has served NABH in many capacities, including currently as vice president of the NABH Education and Research Foundation and member of the Addiction Treatment Committee, and previously as treasurer of the NABH Board of Trustees.
 
Jim leads New Season, a medication-assisted treatment company that serves more than 32,000 patients in 88 clinics located in 20 different states. Prior to his current role, Jim founded Shaheen Strategic Investments (SSI) to provide a vehicle for the Shaheen family to grow and expand its holdings in a variety of businesses. Before that, Shaheen founded the national healthcare company Strategic Behavioral Health, a chain of private psychiatric and substance use hospitals nationwide. Headquartered in Memphis, Tenn., the company expanded to 13 hospitals in 8 states.
 
With more than 33 years of behavioral healthcare experience, Shaheen has helped a variety of small and large companies grow and expand services to meet the demands of behavioral healthcare services in many communities. Currently he serves as chairman of the UT Health Science Center College of Medicine Board of Visitors. 
 
Jim holds a master’s degree in organizational communications from Murray State University and an undergraduate degree in Therapeutic Recreation, also from Murray State University.
 
The association’s Washington-based team is eager to work with Jim this year and appreciates his passion and leadership for both the behavioral healthcare segment and the association.
In addition, the NABH team is very grateful to Rutgers University Behavioral Health Care CEO Frank Ghinassi, Ph.D., A.B.P.P., for his service as NABH’s 2024 board chair and all he does to promote NABH’s priorities and the association’s vision and mission. Thank you, Frank!

SAMHSA Updates Contingency Management Incentive Limit in New Advisory

In a new advisory, the Substance Abuse and Mental Health Services Administration (SAMHSA) has raised the annual contingency management (CM) incentive limit to $750 per patient from $75 per patient for entities that implement CM using funds from the State Opioid Response and Tribal Opioid Response grant programs.
 
The advisory also outlines safeguards for grantees implementing CM that align with recommendations HHS outlined in a November 2023 report.
 
This policy change is a big win for the addiction-treatment community and NABH, which has led advocacy efforts for several years to revise policies that previously limited the uptake of this evidence-based treatment, especially given the rise in stimulant-involved overdose deaths.

Please Share Your Feedback on CMS’ New Cybersecurity Rule

The Centers for Medicare & Services (CMS) recently proposed a rule that seeks to strengthen cybersecurity protections for electronic health information.
 
The proposed rule would modify the Health Insurance Portability and Accountability Act’s (HIPAA) security rule, which establishes national standards to protect individuals’ electronic health information by entities such as health plans, health care clearinghouses, and healthcare providers.
 
Last February’s cyberattack on UnitedHealth’s medical claims processor – the largest attack ever reported, which affected the private health information of approximately 100 million people – prompted CMS to propose this regulation.

Both lengthy and complex, the proposed rule includes mandatory and voluntary cybersecurity measures, including updating the HIPAA security rule, that would affect NABH member operations, including:

• Requiring written documentation of all HIPAA security policies, procedures, plans, and analyses;
• Updating definitions and revising implementation specifications to reflect changes in technology and terminology;
• Adding specific compliance time periods for many existing requirements;
• Requiring the development and revision of a technology-asset inventory and a network map that illustrates the movement of patient health information throughout providers’ electronic information system(s), at least once every 12 months;
• Requiring more specific risk analysis protocols; and
• Multiple additional provisions.

Please read the agency’s fact sheet for more information.

NABH encourages members to e-mail Rochelle Archuleta soon to help identify the provisions that would have the greatest effects on your operations and all other concerns and questions. Your feedback will help NABH prepare the association’s comment letter before CMS’ March 7^th deadline.

CMS and Mathematica Seek Experts for TEP on Quality Reporting and Payment

CMS and its contractor Mathematica, a research and data analytics consultancy, seek nominations for a Technical Expert Panel (TEP) to provide information about new and existing measures for CMS quality reporting and payment programs.
 
This work falls under Mathematica’s Behavioral Health Measures Development and Inpatient and Outpatient Measure Maintenance (BHIOMM) project. The BHIOMM TEP’s objective is to provide feedback and offer opinions on the identification, development, specification, testing, maintenance, re-evaluation, and implementation of health-related quality measures used in CMS’ quality programs.

Click here for more information. The deadline for nominations is next Wednesday, Jan. 15, 2025. Please contact BHIOMMmeasures@mathematica-mpr.com if you have questions.

CMS and Abt Seek Nominations for TEP to Design a Patient Assessment Instrument

CMS and its contractor Abt, a research and consulting firm, are assembling a TEP that will provide guidance on clinical and operational issues to design and implement a patient assessment instrument (PAI).
 
Abt seeks a mix of clinical and operational leaders, including participants with direct knowledge of the patient assessment process. Please refer to the TEP Charter for more information. The TEP will meet periodically for up to four years. All meetings will be held virtually, including the first meeting in February or March 2025.
 
Nomination packets must include a signed TEP nomination form, letter of interest, and CV, all of which must be e-mailed to IPF-PAI_testing@abtglobal.com with “Nomination” in the subject line. The deadline for applications is Friday, Jan. 24, 2025 at 5 p.m. ET.

NABH Developing Advocacy Document on Potential Medicaid Changes

NABH is developing an advocacy document to educate policymakers about the risks of proposed changes to Medicaid financing and eligibility.
 
The analysis will describe how state efforts to offset reduced revenue could exacerbate existing challenges with low reimbursement and narrow networks, and it will outline potential issues with applying work requirements to people with behavioral health conditions.
 
NABH’s resource will emphasize the critical need for Medicaid as a funding source for behavioral healthcare organizations, particularly Opioid Treatment Programs.

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

NABH recently 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 this month.

Fact of the Week

After declining significantly during the COVID-19 pandemic, substance use among adolescents has continued to hold steady at lowered levels for the fourth year in a row, according to the latest results from the National Institutes for Health-funded Monitoring the Future Survey.

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

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