NABH Urges CMS to Strengthen Medicaid Parity Regulations
NABH Urges CMS to Strengthen Medicaid Parity Regulations
Dan Schwartz Joins NABH as Director of Quality and Addiction Services
WASHINGTON, Dec. 10, 2024 /PRNewswire/ — The National Association for Behavioral Healthcare (NABH) is pleased to welcome Dan Schwartz as the association’s director of quality and addiction services.
Dan brings to NABH a range of experiences in federal agencies related to addiction services, including most recently in his role as a senior behavioral health policy analyst in the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services (HHS).
In that role, Dan engaged in federal policymaking efforts by providing subject matter expertise about the delivery, financing, and regulation of behavioral health services, with an emphasis on the substance use disorder care continuum, controlled substances, and various mental health topics.
Dan also served as the staff lead for the HHS Workgroup on Implementation Strategies for Contingency Management; co-led a workgroup that supported developing legislative proposals related to behavioral health; and was a lead analyst for developing and implementing the HHS Overdose Prevention Strategy.
“We are excited to have Dan join our team,” said NABH President and CEO Shawn Coughlin. “He brings energy, experience, and enthusiasm to a critical role in our association.”
Prior to working at ASPE, Dan worked at the White House Office of National Drug Control Policy and the Substance Abuse and Mental Health Services Administration.
Dan earned a master’s degree in public health from Johns Hopkins University, where he was a Bloomberg Fellow in Addiction & Overdose, and a bachelor’s degree in public health from George Washington University.
About NABH
The National Association for Behavioral Healthcare (NABH) represents provider systems that treat children, adolescents, adults, and older adults with mental health and substance use disorders in inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, medication assisted treatment centers, specialty outpatient behavioral healthcare programs, and recovery support services in 49 states and Washington, D.C. The association was founded in 1933.
SOURCE National Association for Behavioral Healthcare
NABH Responds to The New York Times story on Opioid Treatment Programs
Washington, Dec. 7, 2024—A story published in The New York Times on Dec. 7 has prompted NABH to clarify the purpose and critical need for opioid treatment programs (OTPs) in the United States.
NABH is concerned the article’s incomplete picture of how OTP treatment works could contribute to what is already a stigmatized disease in an environment where patients should be encouraged to seek the care they need desperately. OTPs are among the most regulated facilities in the healthcare system and provide lifesaving care every day.
Millions of Americans struggle with opioid addiction, and the Centers for Disease Control and Prevention reports more than 81,000 Americans died from an opioid-related overdose in 2023.
NABH member facilities, including those that Acadia Healthcare operates, provide a lifeline to those in need. Opioid treatment programs provide medication-assisted treatment (MAT), which combines U.S. Food and Drug Administration (FDA)-approved medications, behavioral therapies, and wraparound support services. MAT is the most effective intervention to treat opioid use disorder and is proven to reduce overdose fatalities by up to 60%.[1] Meanwhile, the U.S. Surgeon General has called MAT the “gold standard” for treating opioid use disorder (OUD).[2] OTPs provide MAT while addressing patients’ unique needs, reducing barriers to care, and implementing safeguards that support long-term recovery and sustained treatment engagement.
It is important to understand that treatment at OTPs is voluntary, and staff members see patients only after patients make the decision to seek treatment. Patients benefit from the expertise of a multidisciplinary team including physicians, nurses, counselors, clinicians, peer recovery specialists, and case managers, and patients can choose to start or complete treatment based on their own decisions and unique circumstances.
In addition, OTPs are subject to strict regulations and are required by law to employ a licensed physician who oversees all medical services provided to patients based on rigorous clinical guidelines. OTPs are also accredited and regularly inspected to uphold high standards of care, and, in many cases, our members exceed the state and federal regulatory requirements needed to maintain their licenses. These providers invest heavily in staff, training and medical care, counseling, case management and wraparound support— services that often exceed what insurance will reimburse.
Our members see firsthand the growing lethality of drug use and the severe ramifications of individuals not being able to receive needed treatment right away. Yet only 1 out of 5 people living with OUD are receiving needed treatment.[3] Early intervention is critical, with scientific research showing significantly better outcomes for patients who receive comprehensive care compared with those who don’t.
NABH strongly supports the potential of recent federal efforts to expand access to care through telehealth services, expanded methadone take-home privileges, and other flexibilities offered through regulatory revisions. However, we continue to express serious concerns regarding the Modernizing Opioid Treatment Access Act (MOTAA) due to the potential unintended consequences and harms that may result from legislation proposing such abrupt and expansive regulatory changes.
And we are not alone. Other stakeholders have also expressed significant concerns, including six of the nation’s largest law enforcement organizations. For more information about this issue, please see NABH’s letter to House and Senate leaders on Dec. 4, 2024.
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.
About NABH
The National Association for Behavioral Healthcare (NABH) represents provider systems that treat children, adolescents, adults, and older adults with mental health and substance use disorders in inpatient behavioral healthcare hospitals and units, residential treatment facilities, partial hospitalization and intensive outpatient programs, medication assisted treatment centers, specialty outpatient behavioral healthcare programs, and recovery support services in 49 states and Washington, D.C. The association was founded in 1933.
NABH MOTAA Letter to House Senate Leadership – Dec. 2024
NABH MOTAA Letter to House Senate Leadership - Dec. 2024
NABH Letter to CMS on Accrediting Organizations
NABH Letter to CMS on Accrediting Organizations
NABH Letter to The Joint Commission-April 2024
NABH Letter to The Joint Commission-April 2024
NABH BHIT Letter to ONC and SAMHSA
NABH BHIT Letter to ONC and SAMHSA
NABH 2024 Advocacy Priorities
NABH 2024 Advocacy Priorities
2024 Annual Meeting At-a-Glance
2024 Annual Meeting At-a-Glance
MOTAA – NABH Letter
MOTAA - NABH Letter
SAMHSA Updates OTP Regulations
SAMHSA Updates OTP Regulations
Updated Feb. 2, 2024 The Substance Abuse and Mental Health Services Administration published Medications for the Treatment of Opioid Use Disorder late yesterday for public inspection. The final rule was published earlier today and becomes effective on April 2, 2024, with compliance by October 2, 2024. [Please note that this is a correction of the compliance date of October 2, 2026 that was published yesterday in the public notice.] NABH provided comments on the Notice of Proposed Rule Making that was issued in December 2022 calling for greater regulatory flexibility for opioid treatment programs (OTPs). The final regulations align closely to NABH recommendations and herald greater deference to clinical decision-making in the nation’s (OTPs). Among the provisions, the regulations:- Make permanent the Covid-era take-home schedule;
- Permit methadone for new patients via audio-visual telemedicine with the dispensing of medication at the OTP (not audio-only).
- Permit audio-only telemedicine when the patient is in the presence of a practitioner who is registered to prescribe SII, including dispensing.
- Clarify (in response to NABH off-line discussion and official comments) that the prescription of methadone to community pharmacies is NOT permitted;
- Change the requirement for a one-year history of OUD for eligibility so that now either the patient must a) meet diagnostic criteria for moderate-severe OUD, or b) be in OUD remission, or c) at high risk for overdose;
- Remove the requirement for two treatment failures for people under 18 to be eligible for services;
- Remove requirement for a one-year history of OUD for people recently released from a correctional facility, pregnant patients, or previously enrolled individuals;
- Allow medication units to provide all OTP services;
- Decouple medication and attendance at counseling services;
- Permit interim treatment for 180 days, including at for-profit OTPs;
- Permit mid-levels (“…those appropriate licensed by the state”) to prescribe without exemption;
- Clarified accreditation standards to reduce potential for a burdensome increase in less-than 3-year accreditations;
- Permit buprenorphine prescribing in an OTP via audio-only and audio-visual without an in-person evaluation; and
- Update terminology to reflect contemporary, non-stigmatizing language.
NABH Comments on Medicare Advantage
NABH Comments on Medicare Advantage
NABH Comment Letter- Medicaid & CHIP Parity
NABH Comment Letter- Medicaid CHIP Parity
NABH Letter on SUPPORT Act Reauthorization
NABH Letter on SUPPORT Act Reauthorization
NABH Letter to Senate HELP Committee on MOTAA
NABH Letter to Senate HELP Committee on MOTAA
NABH Parity Comment Letter
NABH Parity Comment Letter
NABH Urges Lawmakers to Reauthorize the SUPPORT Act
NABH SUPPORT ACT Endorsement
NABH Comments-OPPS PFS CY 24 Proposed Rule
NABH Comments-OPPS PFS CY 24 Proposed Rule
9th Circuit Order-Wit-August 2023
9th Circuit Order-Wit-August 2023
Andrew Dodson Joins NABH as Director of Congressional Affairs
CMS Final Rule Estimates Overall IPF Payments to Increase by 2.3% in 2024
HHS, DOL and Treasury Release Proposed Rules to Strengthen MHPAEA
CSOO Letter: Due Process Continuity of Care Act
CSOO Letter: Due Process Continuity of Care Act
NABH Letter on IPF PPS Proposed Rule
NABH Letter IPF PPS FY 2024 Proposed Rule
CMS Coverage for PHP Telehealth Services Set to End After May 11
DEA Extends COVID-19 Telehealth Flexibilities for Prescription of Controlled Medications for Now
CMS PHE Fact Sheet
CMS PHE Fact Sheet
NABH Education & Research Foundation Webpage Now Features Grants & Funding Opportunities
CBO Report: Budgetary Effects of Modifying or Eliminating the IMD Exclusion
CBO Report: Budgetary Effects of Modifying or Eliminating the IMD Exclusion
NABH Contingency Management Fact Sheet
NABH Contingency Management Fact Sheet
NABH Letter to DEA Telehealth Schedule II Telemedicine
NABH DEA Letter on Schedule II Telemedicine
2023 NABH Advocacy Priorities
NABH 2023 Advocacy Priorities
FDA Approves First Over-the-Counter Naloxone Spray
NABH Letter to Norcross-Markey
NABH Letter to Norcross-Markey
NABH Response- Senate HELP Workforce RFI
NABH Response- Senate HELP Workforce RFI
Amicus Brief: Wit v. UBH (3-17-23)
Amicus Brief: Wit v. UBH (3-17-23)
NABH FTC Non-Compete Comment Letter
NABH FTC Non-Compete Comment Letter
NABH Prior Authorization Comment Letter
NABH Prior Authorization Comment Letter
HALO Letter on Medicaid DSH Cuts March 2023
HALO Letter on Medicaid DSH Cuts
DEA Telehealth Proposed Rules
DEA Telehealth Proposed Rules
CY 2024 MA Proposed Rule Comments
CY 2024 MA Proposed Rule Comments
NABH OTP Comment Letter
NABH OTP Comment Letter
President Biden to Outline Approach for Addressing Nation’s Mental Health & Opioid Crises in State of the Union
NABH Education and Research Foundation Partners with Manatt to Produce Issue Brief on Telehealth Services in PHP and IOP
- During the COVID-19 crisis, regulatory flexibilities enabled traditional in-person PHPs and IOP programs to implement telehealth services rapidly.
- Using telehealth to deliver PHP and IOP services has improved access to care for remote patients and those facing other access obstacles.
- Emerging research is showing that, relative to in-person care, the use of telehealth in PHPs and IOPs generally is improving the quality of clinical care, patient satisfaction and the overall efficiency of the healthcare system.
NABH Comments on Benefit and Payment Parameters for 2024
Benefit and Payment Parameters for 2024 NABH Comment Letter
Joint Letter to ONDCP on Contingency Management
Joint Letter to ONDCP on Contingency Management
SAMHSA Proposed Rule Permits Methadone Prescribing for New Patients via Telemedicine
- expanding the definition of an OTP treatment practitioner to include any provider who is appropriately licensed to dispense and/or prescribe approved medications. The current Part 8 rule defines a practitioner as being: “a physician who is appropriately licensed by the State to dispense covered medications and who possesses a waiver under 21 U.S.C.823(g)(2).” During the Covid-19 public health emergency, this has been formally expanded to align with broader definitions of a practitioner (nurse practitioners, physician assistants, etc.), and OTPs reported that this change was essential in supporting workflow and access;
- adding evidence-based delivery models of care, such as split dosing, telehealth, and harm-reduction activities;
- removing such outdated terms as “detoxification”;
- updating criteria for provision of take-home doses of methadone;
- strengthening the patient-practitioner relationship through promoting shared and evidence-based decision-making;
- allowing for early access to take-home doses of methadone for all patients, to promote flexibility in creating plans of care that facilitate such every-day needs as employment, while also affording people with unstable access to reliable transportation the opportunity to also receive treatment; likewise, promoting mobile medication units to expand an OTPs geographic reach; and
- reviewing OTP accreditation standards.