CMS Freezes CY 2022 Methadone Reimbursement Rates in Interim Final Rule
In an interim final rule (IFR), the Centers for Medicare & Medicaid Services (CMS) said it will freeze methadone reimbursement rates for calendar year (CY) 2022.
CMS is establishing a limited exception to the current CMS methodology for determining rates for the drug episode of care for methadone (HCPCS G2067-weekly bundle) and the add-on take-home for methadone (HCPCS G2708) by freezing rates at the CY2021 rate.
The most recent average sale price (ASP) quarterly rates for oral methadone decreased by just more than 50% over last year’s rate, resulting in a reimbursement rate of 17.64 versus the CY 2021 rate of 37.38 (100% of ASP). CMS said the reduction is due to the inclusion of methadone tablets, where previously only the oral concentrate form was reflected in ASP sales. In addition, because ASP is not required for oral methadone, only a small number of manufacturers report ASP data. Moreover, CMS is not clear about OTP utilization rates for the oral and tablet forms of methadone; however, the agency has heard anecdotally that OTPs use oral methadone exclusively.
CMS said that collectively, these three factors raised concerns about implementing such a “sudden and significant decrease in the rate for methadone” [that] could affect the ability of OTPs to continue to offer services to Medicare beneficiaries, thereby impeding access to treatment for OUD, at a time when overdose deaths are at an all-time high.” The freeze of reimbursement rates at the CY 2021 rates will allow time for further research and discussion with stakeholders to develop a new payment methodology in time for the CY 2023 payment rate determination.
CMS requested information from stakeholders on the following are of interest:
- The exception being made
- Frequency of use of methadone oral concentrate compared with tablets, and how this should factor into rate setting
- How the reduced payment changes (discussed above) will affect operations and beneficiary access to treatment
Public comments are due by Jan. 3, 2022. The rule will be published in the Federal Register on Nov. 19 and will become effective on Jan. 1, 2022.
NABH Sends Letters to U.S. Senate Finance and HELP Committees
NABH recently sent letters to members of the influential Senate Finance and Senate Health, Education, Labor, & Pensions (HELP) Committees that provided detailed information and recommendations about how to improve access to mental health and addiction treatment.
The first letter to Senate Finance Committee Chairman Ron Wyden (D-Ore.) and Ranking Member Mike Crapo (R-Idaho) was a response to a request for information from the senators this summer. In it, NABH emphasized ensuring parity; expanding telehealth; strengthening workforce; increasing integration, coordination, and access; improving access for children and youth; and increasing Medicare Advantage accountability for mental health and addiction treatment.
NABH also sent a letter to Senators Christopher Murphy (D-Conn.) and Bill Cassidy, M.D. (R-La.) of the Senate HELP Committee regarding their request for feedback on the programs authorized in the Mental Health Reform Act of 2016.
“The pandemic has highlighted and amplified the need for improved access to mental health and addiction treatment,” NABH President and CEO Shawn Coughlin explained in both letters. “Studies have consistently found significantly higher levels of anxiety and depression and suicidal ideation. In addition, alcohol consumption has increased significantly,” he added. “Drug overdose deaths increased almost 30% in 2020 to more than 90,000 deaths, the highest number ever recorded over a 12-month period. Although suicide rates seemed to have leveled off and decreased last year, there have been troubling increases in suicides and suicidal ideation among certain subgroups including Black Americans and adolescent girls.”
Both letters also noted that experts expect mental health and substance use disorders to remain elevated long after the Covid-19 pandemic ends.
NABH and Other Behavioral Health Groups Send Letter to OSHA on Workplace Violence
NABH led development of a stakeholder group letter to the U.S. Labor Department’s Occupational Safety and Health Administration (OSHA) about ensuring the safety of personnel in healthcare settings, including those focused on behavioral health.
The letter from NABH, the American Nurses Association, the American Psychiatric Association, the National Alliance on Mental Illness, the National Association of State Mental Health Program Directors, and the National Council for Mental Wellbeing followed an early August meeting with representatives from all of the organizations and OSHA that focused on settings where people access mental health or substance use disorder treatment.
NABH and the other organizations highlighted a variety of issues, including incorporating trauma-informed care to inform both environmental interventions and settings; conducting debriefing sessions when incidents do occur, including the patient’s perspective to inform additional prevention measures; and providing clinician and staff development/training on de-escalation techniques.
The Commonwealth Fund and Council of State Governments Release Policy Options to Advance Mental Health
The Commonwealth Fund and the Council of State Governments have released Mental Health Resource Guide for State Policymakers, a new resource based on state priorities, best practices, and perspectives from leaders in the field of mental health.
Overseen by an advisory group of state legislators, health officials, and experts, the guide focuses on four policy areas: social isolation and loneliness, maternal mental health, social determinants of mental health, and mental health insurance parity.
“The resource guide addresses the issue of workforce shortages, and also highlights ways to stretch existing resources, including, for instance, providing peer support and consultation between primary care and behavioral health providers,” The Commonwealth Fund noted in its announcement about the guide. “Some strategies include expanding telehealth psychiatric services and incorporating mental health screening and interventions into various settings like schools, senior centers, workplaces, primary care offices, and in law enforcement.”
ASAM and Well Being Trust Release Toolkit for Strengthening Patient-Centered Addiction Care
The American Society of Addiction Medicine (ASAM) and the Well Being Trust this week released Speaking the Same Language: A Toolkit for Strengthening Patient-Centered Addiction Care in the United States, a toolkit written by Manatt Health Strategies to emphasize the need for adopting a common framework to addiction care in the United States.
The toolkit is meant to educate stakeholders about the strategies and tools available to support more effective implementation of The ASAM Criteria and also provide legislative, regulatory, and contractual language that interested states can use.
SAMHSA to Host Webinar on Behavioral Health Equity on Tuesday, Nov. 16
The Substance Abuse and Mental Health Services Administration (SAMHSA) will host Advancing Behavioral Health Equity: National CLAS Standards in Action on Tuesday, Nov. 16 at 2:30 p.m. ET.
The webinar will examine real-world examples of behavioral health service providers who use the National Standards for Culturally and Linguistically Appropriate Services (CLAS) and the Behavioral Health Implementation Guide.
Presenters include Assistant Secretary for Mental Health and Substance Use Miriam Delphin-Rittmon, Ph.D. and Rear Admiral Felicia Collins, M.D., M.P.H., director of the U.S. Health and Human Services Department’s Office of Minority Health. Click here to register.
NABH 2021 Annual Meeting Photos and Recorded Sessions Now Available!
Photos and recorded sessions from last month’s Annual Meeting are now available on the association’s Annual Meeting webpage.
NABH looks forward to welcoming members to the 2022 Annual Meeting in Washington from June 13-15, 2022!
Reminder: NABH Denial-of-Care Portal is Open to Members
NABH’s Denial-of-Care Portal is available for members to provide information about their experiences with managed care organizations that impose barriers to care through insurance-claim denials.
NABH’s Managed Care Committee worked for more than a year to develop the Denial-of-Care Portal as a way to collect specific data on insurers who deny care—often without regard for parity or the effects on patients.
This NABH member-only, survey-like tool allows users to add the name of a managed care organization, type of plan, level of care, type of care (mental health or substance use disorder), duration of approved treatment, duration of unapproved treatment, criteria used to deny a claim, and more.
The portal allows members to submit individual examples of claim denials or upload multiple entries via Excel. It also includes sections on appeals and physician participation. In time, the tool could be a valuable resource for the NABH team’s advocacy efforts.
Please e-mail Emily Wilkins, NABH’s administrative coordinator, if you have questions about the portal.
Fact of the Week
A new study shows that the Centers for Disease Control and Prevention’s 2016 Guideline for Prescribing Opioids for Chronic Pain was associated with substantial reductions in dispensing opioids, including a reduction in patients’ rate of receiving at least one opioid prescription by about 20 percentage points by December 2018 with the counterfactual, no-guideline scenario.
For questions or comments about this CEO Update, please contact Jessica Zigmond.