You’re not alone. Call 988 to connect to the National Suicide and Crisis Lifeline.

CEO Update 134

CMS Announces Special Enrollment Period in Marketplaces During Covid-19 Pandemic

The Centers for Medicare & Medicaid Services (CMS) has announced a special enrollment period (SEP) for consumers—including both individuals and families—in the 36 states that operate health insurance marketplaces through HealthCare.gov, citing the “unprecedented challenges” that the Covid-19 public health emergency has created.

“Millions of Americans are facing uncertainty and millions of Americans are experiencing new health problems during the pandemic,” said the announcement, which aligns with an Executive Order from President Biden. “Due to the exceptional circumstances and rapidly changing Public Health Emergency impacting millions of people throughout the U.S. every day, many Americans remain uninsured or underinsured and still need affordable health coverage.”

Beginning Feb. 15 and continuing through May 15, marketplaces using the HealthCare.gov platform will make an SEP available to all marketplace-eligible consumers who are submitting a new application or updating an existing one.

Eligible consumers who enroll under this SEP will be able to select a plan with coverage that starts prospectively the first month after plan selection. Consumers will then have 30 days from the time they applied to choose a plan.

ONDCP Announces 100-Day Priorities

The White House Office of National Drug Control Policy (ONDCP) this week outlined its priorities for the first 100 days of the new Biden administration, including a focus to lift burdensome restrictions on medications for opioid use disorder.

The announcement from Acting Director Regina LaBelle perhaps signals that the Biden administration might further consider regulations related to buprenorphine prescribing for physicians who treat fewer than 30 patients. On Jan. 21, the new administration pulled back a guidance changing the requirements for these physicians as part of the regulatory freeze on Trump administration policies issued in the previous 60-days.

In addition, ONDCP’s strategic aims include enhancing evidence-based, harm-reduction efforts, a departure from the previous administration.

Joint Commission Releases Sentinel Event Alert: Pandemic Special Edition, Part 1

The Joint Commission this week released a Sentinel Event Alert that addresses concerns from healthcare workers and offers examples for providers to manage the current Covid-19 pandemic and respond to future challenges.

“Covid-19 is highlighting the absolute indispensability of a dedicated and fearless healthcare workforce,” the article noted. “The need to better ensure the safety and health of workers has become the topic of a national conversation,” it continued. “As of Jan. 15, 2021, 3,176 healthcare workers have died from Covid-19, according to independent tracking from The Guardian and Kaiser Health News.”

The seven-page article examines how to foster transparent communication, remove barriers to workers seeking mental health services, ensure patient safety, develop and evaluate a flexible workforce, and more.

According to the Joint Commission, this is the first in a series of special edition Sentinel Event Alerts about the Covid-19 pandemic.

JAMA Psychiatry Examines Trends in ED Visits for Mental Health, Overdose, and Violence

A study of nearly 190 million emergency department (ED) visits found that ED visit rates for mental health conditions, suicide attempts, all drug and opioid overdoses, intimate partner violence, and child abuse and neglect were higher in mid-March 2020 through October 2020, compared with the same period in 2019.

The findings published this week in JAMA Psychiatry suggest that seeking care in an ED shifts during a pandemic and underscores the need to integrate mental health, substance use, and violence screening and prevention services into response activities during public health crises.

University of Michigan’s Behavioral Health Workforce Research Center Releases Telehealth Study Findings

All healthcare providers who participated in a study of Michigan behavioral healthcare providers last summer indicated they would like to see telebehavioral health services continue after the Covid-19 pandemic ends.

Between late July and mid-August 2020, a team at the University of Michigan’s Behavioral Health Workforce Research Center, a contractor for the Substance Abuse and Mental Health Services Administration, conducted a study that included in-depth interviews with 31 Michigan behavioral healthcare providers statewide who provide telebehavioral health services. The center released a report that summarizes the study’s findings and suggests future policy considerations. Two accompanying briefs from the University of Michigan’s Institute for Healthcare Policy & Innovation—which funded the project— highlight the report’s essential findings and policy considerations, including one focused on state policy implications and the other on federal policy implications.

“In order to continue treating clients and keep them safe, and as a result of state and federal policy changes, providers rapidly expanded their use of telehealth,” the summary noted. “Policy changes at the state and federal level expanded telehealth authorization and reimbursement across insurers, allowed for services to be delivered via video or audio-only methods, and removed requirements for written consent for treatment, allowing verbal consent, among other changes,” the summary added.

Sarah Wattenberg, NABH’s director of quality and addiction services, is a member of the University of Michigan’s Behavioral Health Workforce Research Center’s Advisory Group, which guides the center’s research work. Please contact Sarah if you have ideas for future research projects.

DOJ Accepting Applications for Substance Use-Related Programs

The U.S. Justice Department (DOJ) is accepting applications for two substance use-related programs: the Second Chance Act Pay for Success Initiative and the Residential Substance Abuse Treatment (RSAT) for State Prisoners Program.

In the Second Chance Act Pay for Success Initiative, the DOJ is seeking applications for funding for state, local, and tribal governments to enhance or implement performance-based and outcomes-based contracts with reentry, permanent supportive housing, or recovery housing providers to reduce recidivism and address the substance use disorders impacting formerly incarcerated people.

The DOJ is also seeking funding applications for the RSAT program, which helps state, local, and tribal efforts to break the cycle of drug addiction and violence by reducing the demand for, use, and trafficking of illegal drugs.

Applications for both programs are due in March; click here to learn more about the Second Chance Act Pay for Success Initiative and here to learn about the RSAT for State Prisoners Program.

Justice Clearinghouse to Host Webinar on Successful Mental Health Diversion Programs: Feb. 9

The Justice Clearinghouse, an organization of more than 80,000 justice and public safety professionals, will host a webinar next week that will explore what successful mental health diversion should look like.

John Snook, NABH’s new director of government relations and strategic initiatives, will serve as a presenter during the webinar, which is scheduled for Tuesday, Feb. 9 from 3 p.m. to 4:15 p.m. ET.

Click here to learn about the other presenters and to register.

Save the Date: NABH 2021 Annual Meeting

NABH will host its 2021 Annual Meeting from Wednesday, Oct. 6 – Friday, Oct. 8, 2021 at the Mandarin Oriental Washington, DC.

The association re-scheduled for this later date in 2021 due to the ongoing Covid-19 pandemic. We hope you can join us!

After 2021, NABH will host its subsequent Annual Meetings in June. Please save the date for these future NABH Annual Meetings:

  • June 13-15, 2022
  • June 12-14, 2023

We look forward to seeing you again in Washington!

Fact of the Week

The New York Times reports that 69% of U.S. mothers say they have experienced adverse health effects due to worry and stress during the pandemic, compared with 51% of U.S. fathers.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond

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CEO Update 133

CMS Issues Memo to Clarify Expectations of Hospital Surveys During Pandemic

The Centers for Medicare & Medicaid Services (CMS) Center for Clinical Standards and Quality has issued a memo that clarifies expectations regarding hospital surveys during the ongoing Covid-19 global pandemic.

According to the memo, surveys will be limited to “Immediate Danger” complaint allegations for the 30 days following the memo’s release on Jan. 20. The memo also said hospital recertification surveys would be suspended for the most part. Meanwhile, hospital enforcement actions for deficiencies that do not represent “Immediate Jeopardy” will have their termination date extended for at least 30 days.

The memo is also posted on NABH’s Covid-19 resources webpage.

HHS Releases Call to Action to Implement the National Strategy for Suicide Prevention

HHS has released The Surgeon General’s Call to Action to Implement the National Suicide Prevention Strategy (National Strategy), a 92-page guide from Jerome Adams, M.D., M.P.H., the nation’s most recent U.S. surgeon general.

First released in 2001, the National Strategy was updated in collaboration with the Action Alliance in 2012. It identifies 13 goals and 60 objectives that address every aspect of suicide prevention—from fostering healthy and empowered individuals, families, and communities to providing effective prevention programs and clinical care.

The guide is categorized into the following six action areas: activating a broad-based public health response to suicide, addressing upstream factors that impact suicide, ensuring lethal means safety, supporting adoption of evidence-based care for suicide risk, enhancing crisis care and care transitions, and improving the quality, timeliness, and use of suicide-related data.

Adams served as U.S. surgeon general from September 2017 until Jan. 20, 2021. This week President Biden appointed Rear Admiral Susan Orsega, M.S.N. as acting U.S. surgeon general pending Senate confirmation of Vivek Murthy, M.D., M.B.A, who served as U.S. surgeon general from 2014 through 2017 in the Obama administration. Orsega has served in the surgeon general’s office since March 2019.

In a letter this week to the Biden administration, the Kennedy Forum, Mental Health America, and the National Alliance on Mental Illness urged policymakers to integrate the nation’s mental health and addiction response in the fight against Covid-19 and listed suicide prevention as one of the priorities.

Coalition Endorses Principles to Guide State and Local Spending of Opioid Litigation Settlement Funds 

The faculty at the Johns Hopkins Bloomberg School of Public Health has coordinated a coalition of 31 professional and advocacy organizations that has released Principles for the Use of Funds from the Opioid Litigation, which provides five principles to help guide state and local spending of the forthcoming opioid litigation settlement funds. NABH was one of the organizations to endorse the principles.

An announcement noted the guidelines are meant to avoid mistakes made in the 1988 tobacco litigation settlement and support efforts based on evidence to save lives.

“As states, counties, and municipalities begin receiving funds from entities that exacerbated America’s opioid overdose crisis, it will be critical for decision makers to use that money wisely,” Paul Earley, M.D., president of the American Society of Addiction Medicine, said in the announcement. “To make the most of this opportunity, state and local leaders should invest in evidence-based approaches to prevent and treat addiction, promote racial equity, and save lives.”

The five principles include spending money to save lives, using evidence to guide spending, investing in youth prevention, focusing on racial equity, and developing a fair and transparent process for deciding where to spend the funding.

Research Shows Schizophrenia Second to Age as Greatest Risk Factor for Covid-19 Death

A new study shows people with schizophrenia, a mental disorder that affects mood and perception of reality, are nearly three times as likely to die from the coronavirus than those without the psychiatric illness.

Researchers at the New York University Grossman School of Medicine led the study, which found that schizophrenia is by far the biggest factor (2.7 times increased odds of dying) after age (being 75 and older increased the odds of dying 35.7 times).

“Our findings illustrate that people with schizophrenia are extremely vulnerable to the effects of Covid-19, lead author Katlyn Nemani, M.D., said in a news release about the study. “With this newfound understanding, healthcare providers can better prioritize vaccine distribution, testing, and medical care for this group.”

The study was published this week in JAMA Psychiatry.

Center for Connected Health Policy to Host Telehealth Policy Webinar Next Week

The Center for Connected Health Policy will host Telehealth & Medicaid: What’s Next? A Roadmap for Telehealth Beyond the Pandemic next Friday, Feb. 5, 2021 at 2 p.m. ET.

The webinar will feature experts in a panel discussion about what the future looks like for telehealth policy in Medicaid. Attendees will hear from high-level administrators and policy staff from the Medicaid and CHIP Payment Advisory Commission (MACPAC), the Arizona Health Care Cost Containment System, the Colorado Department of Health Care Policy and Financing, and the Oregon Health Authority.

Click here to learn more and to register.

Save the Date: NABH 2021 Annual Meeting

NABH will host its 2021 Annual Meeting from Wednesday, Oct. 6 – Friday, Oct. 8, 2021 at the Mandarin Oriental Washington, DC.

The association re-scheduled for this later date in 2021 due to the ongoing Covid-19 pandemic. We hope you can join us!

After 2021, NABH will host its subsequent Annual Meetings in June. Please save the date for these future NABH Annual Meetings:

  • June 13-15, 2022
  • June 12-14, 2023

We look forward to seeing you again in Washington!

Fact of the Week

A new study reports 46% of health care workers say their mental health has worsened during the pandemic, while 38% say there’s been no change.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond

Read more

CEO Update 132

Coderre & LaBelle Named as Acting Heads of SAMHSA and ONDCP

Tom Coderre, former Region 1 administrator at the Substance Abuse and Mental Health Services Administration (SAMHSA), has been named SAMHSA’s acting assistant secretary for mental health and substance use, and Regina LaBelle, former chief of staff at the White House Office of National Drug Policy (ONDCP), has been named ONDCP’s acting director in the new Biden administration.

Coderre served in the Rhode Island Senate from 1995 until 2003 and later as senior advisor to Rhode Island Gov. Gina Raimando. In his previous role as chief of staff at SAMHSA, he led the team that produced Facing Addiction in America: The Surgeon General’s Report on Alcohol, Drugs, and Health. Coderre is the first person in recovery to lead SAMHSA, and his bio notes that he acknowledges the essential role of peer recovery support services to help people with mental health and substance use disorder (SUD) rebuild their lives.

LaBelle is a distinguished scholar and program director of the addiction and public policy initiative at the O’Neill Institute for National and Global Health Law at Georgetown University and is on a leave of absence from that position. LaBelle worked as the chief of staff and senior policy advisor at ONDCP during the Obama administration and oversaw the agency’s efforts to address the nation’s opioid crisis.

White House Issues Regulatory Freeze Pending Review 

The White House on Thursday notified the leaders of federal executive departments and agencies that the Biden administration is freezing the federal regulatory process pending review.

A memorandum from Ron Klain, assistant to the president and chief of staff, outlined the steps that department and agency leaders are expected to take immediately. It begins with the instruction that—subject to exceptions from the Office of Management and Budget in emergency situations—they propose or issue no rule in any manner, including sending a rule to the Office of the Federal Register, until a department or agency head appointed or designated by President Biden reviews and approves the rule.

The memo also includes details about rules that have been published in the Federal Register, and those that have been issued in any manner but have not yet taken effect.

Joint Commission Proposes New Standards for Preventing Workplace Violence 

The Joint Commission (TJC) on Wednesday proposed new, revised standards for workplace violence prevention.

The standards provide a framework for developing strong workplace violence prevention systems, defining workplace violence, and developing a leadership structure, policies, and procedures, reporting systems, post-incident strategies, training, and education to decrease workplace violence.

TJC will accept comments on the proposed new standards until Tuesday, Feb. 16. Click here to read the standards and to submit comments.

CMS Releases T-MSIS-based Medicaid SUD Data Book

The Centers for Medicare & Medicaid Services (CMS) this week released its second publication of the Transformed Medicaid Statistical Information System (T-MSIS)-based Medicaid Substance Use Disorder (SUD) Data Book to help policymakers, researchers, and other stakeholders better understand where to focus drug prevention and treatment efforts.

The data book includes 2018 data on Medicaid beneficiaries treated for SUD and the services they received by type, setting, delivery system, and progression of care. According to the data book’s findings, of the 55.9 Medicaid beneficiaries ages 12 and older with full or comprehensive benefits, 4.6 million, or 8%, were treated for a SUD in 2018.

Meanwhile, nearly half of beneficiaries, or 46%, treated for SUD received emergency services, and 26% received at least one service in an outpatient or home- or community-based setting within 30 days of discharge.

NABH Welcomes New Committee Chairs

NABH is pleased to announce new leaders for some of the association’s standing committees and thanks its outgoing leaders for their service.

Tom Kenny of Sequel Youth & Family Services succeeds Pat Connell of Boys Town Behavioral Health Division as the new chairman of NABH’s Youth Services Committee, and Joe Pritchard of Pinnacle Treatment Centers succeeds Jeff Hillis of AdCare Hospital as the new chairman of the association’s Addiction Treatment Commitment. NABH is also pleased to welcome Kim Sanderson of Acadia Healthcare as the chairwoman for the SUD Medication Treatment Subcommittee.

NABH Releases Issue Brief on Changes to Medicare Coverage for SUD

NABH this week sent members an NABH Issue Brief to provide more details about recent changes to Medicare coverage for SUD that were included in the 2021 Physician Fee Schedule (PFS) rule.

The Issue Brief includes information about how the rule expanded the PFS bundled payments to include all SUDs, as well as details about nasal naloxone.

Center for Connected Health Policy to Host Telehealth Policy Webinar on Feb. 5

The Center for Connected Health Policy will host Telehealth & Medicaid: What’s Next? A Roadmap for Telehealth Beyond the Pandemic on Friday, Feb. 5, 2021 at 2 p.m. ET.

The webinar will feature experts in a panel discussion about what the future looks like for telehealth policy in Medicaid. Attendees will hear from high-level administrators and policy staff from the Medicaid and CHIP Payment Advisory Commission (MACPAC), the Arizona Health Care Cost Containment System, the Colorado Department of Health Care Policy and Financing, and the Oregon Health Authority.

Click here to learn more and to register.

Save the Date: NABH 2021 Annual Meeting

NABH will host its 2021 Annual Meeting from Wednesday, Oct. 6 – Friday, Oct. 8, 2021 at the Mandarin Oriental Washington, DC.
The association re-scheduled for this later date in 2021 due to the ongoing Covid-19 pandemic. We hope you can join us!

After 2021, NABH will host its subsequent Annual Meetings in June. Please save the date for these future NABH Annual Meetings:

  • June 13-15, 2022
  • June 12-14, 2023

We look forward to seeing you again in Washington!

Fact of the Week

Compared with 2019, the proportion of mental health-related visits for children aged 5 to 11 years old and 12 to 17 years old increased about 24% and 31%, respectively.

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

Read more

Changes to Medicare Coverage for Substance Use Disorder (SUD) Treatment Services

This NABH Issue Brief highlights changes to coverage for substance use disorder (SUD) treatment services that the Centers for Medicare & Medicaid Services (CMS) included in its 2021 Medicare Physician Fee Schedule (PFS) and other final rules.

The PFS rule also contains many changes related to telehealth for substance use disorder (SUD) services. For a review of these modifications, please see NABH Issue Brief CMS Expands Medicare Telehealth Coverage for Mental Health and Addiction Treatment Services.

SECTION I: PFS and Other Rules

  1. CMS adopted the proposal to expand the PFS bundled payments to include all SUDs, not just OUD treatment services.
    • To avoid duplicate billing for treating individuals who require treatment for more than one substance, HCPCS codes G2086-G2088 should not be billed more than once per month.

2. The agency adopted a new code to reimburse for medication assisted treatment (MAT) and additional services in the emergency department. The drug is paid for separately. There are no minimum number of minutes required. The following code was established for this purpose:

    • HCPCS code G2213: Initiation of medication to treat OUD in the emergency department setting, including assessment, referral to ongoing care, and arranging access to supportive services. (List separately in addition to code for primary procedure).

3. The Initial Preventive Physical Examination (IPPE) and Annual Wellness Visit (AWV) was modified to include a) screening for potential SUDs and b) review of any current opioid prescriptions. CMS adjusted the valuation of these services to reflect the changes in value for office/outpatient E/M visits to which they are cross-walked.

4. CMS finalized the proposal to make the Query of PDMP measure under the Electronic Prescribing objective for MIPS eligible clinicians an optional measure eligible for 10 bonus points in CY 2021, an increase of five points from last year.

SECTION II: Coverage for OUD Treatment Services in OTPs

Nasal Naloxone

  1. CMS revised the definition of OUD treatment services to include short-acting opioid antagonist medications, such as naloxone, including nasal and injectable forms.
    • CMS finalized the proposed drug costs of ASP+0 for nasal naloxone. CMS noted NABH’s concern related to pricing methodology for nasal naloxone and indicated it will monitor utilization of claims data to determine whether payment policies are suppressing naloxone access and need changes in future rulemaking.
    • Injectable naloxone is based on contractor pricing. CMS will monitor the data to determine typical dosages and national pricing in future rulemaking.

2. The agency revised its definition of OUD treatment services to include overdose education. The reimbursement rate for overdose education is $2.53. Payments are attached to the provision of naloxone (see Naloxone add-on codes below).

    • CMS will consider the need for independent coding for overdose education in future rulemaking.

3. Naloxone add-on codes consist of both a drug component and a non-drug component that would account for the provision of overdose education each time the OTP furnishes naloxone.

    • HCPCS G2215: Take-home supply of nasal naloxone (provision of the services by a Medicare-enrolled Opioid Treatment Program); list separately in addition to code for primary procedure.
Drug Cost Non-Drug Cost Total
89.63 2.53 92.16
    • HCPCS G2216: Take-home supply of injectable naloxone (provision of the services by a Medicare-enrolled Opioid Treatment Program); list separately in addition to code for primary procedure.
Drug Cost Non-Drug Cost Total
Contracted Price 2.53 Contracted Price

 

4. CMS noted that the brand and authorized generic formulation of the auto-injector naloxone have been discontinued. Therefore, an add-on code for auto-injector naloxone was not finalized.

5. The proposed frequency limit on Medicare payments to OTPs for naloxone was finalized at one add-on code (HCPCS code G2215 or G2216) every 30 days.

6. However, CMS noted NABH’s clinical concern about limiting naloxone and allowed for exceptions to the frequency limitation when it is a medically reasonable and necessary part of the treatment for OUD (e.g., when the beneficiary overdoses and uses the initial supply). Exceptions must be documented in the medical record.

7. CMS finalized its proposal to recoup duplicative payments of naloxone from the OTPs, based on the rationale that as coordinators of patient care, OTPs are best positioned to know whether naloxone is part of the OTP treatment plan or is supplied by another provider or supplier.

8. CMS finalized enrollment through use of Form CMS-855A (Medicare Enrollment Application for Institutional Providers) OR CMS-855B (Medicare Enrollment Application: Clinics/Group Practices and Certain Other Suppliers).

    • OTPs currently enrolled via CMS-855B may switch to enrollment via CMS-855A without an additional site visit and, if applicable, fingerprinting. This is also true if an OTP is currently enrolled under CMS 855-A and switches to CMS-855B.
    • The effective billing date that was established for the OTP under the original enrollment continues to apply.
    • Application fees still apply.

9. As proposed, CMS finalized that periodic assessments (add-on) via audio-visual technology require a face-to-face interaction.

      • Therefore, periodic assessments are permitted to continue after the public health emergency ends but are not permitted to be performed via audio-only
      • Audio-only is permitted to be included as part of the bundled rate but not as an add-on code.
      • Periodic assessments are permitted when medically necessary and documented in the medical record.

10. CMS confirmed the permitted use of “standard billing cycles” in which episodes of care for all patients begin on the same day of the week and “weekly billing cycles” that vary across patients based on patient admission date (or when Medicare billing began).

11. CMS did not finalize its proposal to stratify the bundle.

    • CMS will consider refinements to account for resource variation for different service intensity, such as induction and maintenance periods.

Please click here for comprehensive information about billing and payment and here for comprehensive information about enrollment.

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HHS Announces Delay in Provider Relief Fund Reporting Deadline and Revisions to ‘Lost Revenue’ Definition

The U.S. Health and Human Services Department (HHS) has announced a new reporting portal for providers to register and submit information about how they have used payments from the Provider Relief Fund (PRF) to cover Covid-19-related costs and lost revenues.

HHS also said the deadline for reporting is extended, although it did not specify the deadline. The agency said providers can register and become familiar with the reporting portal in the meantime.

Previously HHS said that providers who received payments amounting to more than $10,000 from the PRF were required to report by Feb. 15, 2021 on how they used those funds. The department had also said providers had until July 31, 2021 to report on funds not expended by the end of 2020.

Late last month, Congress passed the Coronavirus Response and Relief Supplemental Appropriations Act, which added $3 billion to the PRF. This legislation changed the reporting requirements to allow more flexibility in how providers may use PRF funds to cover lost revenues. HHS said in its recent announcement that it is updating PRF reporting requirements to align with the new law.

The department highlighted reporting requirement changes in the highlighted section of this document.

Read more

CEO Update 131

HHS to Expand Access to MAT by Eliminating ‘X-Waiver’ for DEA-Registered Physicians

The U.S. Health and Human Services Department (HHS) on Thursday said it will publish new guidelines that will exempt office-based physicians from having to receive a DATA 2000 waiver, known as the X-waiver, in order to prescribe buprenorphine for opioid use disorder treatment for up to 30 patients. The guidance is effective immediately.

Specifically, the new guidance permits physicians to prescribe buprenorphine for up to 30 patients without completing eight hours of training prior to prescribing buprenorphine. The training requirement has been cited as a barrier to more physicians prescribing the drug. The new guidance does not change the existing regulations for physician assistants, nurse practitioners, or other mid-level practitioners.

This move is intended to address the surge in opioid deaths in the past year. After declining between 2017 and 2018 by 4.1%, the number of overdose deaths increased 18.2% from June 2019 to May 2020. During this period, overdose deaths increased more than 20% in 25 states and the District of Columbia, 10% to 19% in 11 states and New York City, and up to 9% in 10 states.

The new guidance has been issued under regulatory flexibility that permits the administration to make exemptions from the regulatory requirements, as deemed necessary, in consultation with the Drug Enforcement Administration, the National Institute on Drug Abuse, and the U.S. Food and Drug Administration.

A new issue brief from the HHS Office of the Assistant Secretary for Planning and Evaluation (ASPE) found that increasing buprenorphine prescribing capacity of one patient per 100 residents increases prescribing by 3.8% and decreases the use of other opioid prescribing by 2.3%. The relationship holds true only for metropolitan areas.

Meena Vythilingam, M.D. Named Acting Assistant Secretary for Mental Health and Substance Use

Capt. Meena Vythilingam, M.D. of the United States Public Health Service is serving as the acting assistant secretary for mental health and substance use, succeeding Elinore McCance-Katz, M.D., Ph.D., who resigned last week.

Vythilingam, a board-certified psychiatrist, is also the first director of the HHS Center for Health Innovation, and the senior advisor for mental health and opioids in HHS’ office of the assistant secretary for health.

Before she completed her psychiatry residency and post-doctoral fellowship at the Yale University School of Medicine, Vythilingam completed a residency in psychological medicine at the National Institute of Mental Health and Neurosciences in Bangalore, India.

The Substance Abuse and Mental Health Services Administration (SAMHSA) announcement did not indicate how long Vythilingam will serve in the position.

NABH Highlights Priorities in Letter to the Biden-Harris Transition Team 

NABH this week sent a letter to the Biden-Harris transition team that outlines the biggest challenges for behavioral healthcare and recommendations on how to address those problems.

The 12-page letter describes the heightened need for mental health and substance use disorder services in the United States, which the Covid-19 pandemic has exacerbated.

“Elevated levels of mental health and substance use disorders are expected to linger long after the Covid-19 pandemic ends,” NABH President and CEO Shawn Coughlin wrote. “Large-scale disasters such as the current pandemic are known to have widespread and long-lasting detrimental effects on mental health and substance use. Moreover, studies of past disasters have shown the mental health distress and suicidality often do not peak until years after the disaster has ended.”

The letter includes recommendations related to vaccines for behavioral healthcare providers, continued telehealth coverage for mental health and addiction treatment, flexibilities regarding Special Conditions of Participation, increased availability of behavioral healthcare for children and youth, and the 988 hotline.

NABH Issue Brief Provides Details on Expanded Telehealth Coverage 

NABH this week sent an Issue Brief to members that highlights details of the extended Medicare coverage that the Centers for Medicare & Medicaid Services (CMS) authorized in its final 2021 Medicare Physician Fee Schedule rule that was published in the Federal Register last month. Click here to learn more.

RAND Corp. Releases Report on Transforming U.S. Mental Health System

RAND Corp. has released a report with analysis and recommendations in 15 areas where there is potential to help improve the lives of more than 60 million Americans living with mental illness.

How to Transform the U.S. Mental Health System addresses the following three questions: 1) How can policy changes at all levels of government effect transformational change to improve the lives of Americans with mental illness? 2) What are the best practices and recent innovations in the mental health sector? and 3) What opportunities for change in the mental healthcare system are supported by the research literature?

The report is divided into five chapters, and it focuses on topics areas such as integrating behavioral health expertise in general health settings, strengthening mental health parity regulation and enforcement, establishing evidence-based behavioral health treatments at their true cost, linking homeless individuals with mental illness to supportive housing, and more.

NABH Director of Policy and Regulatory Affairs Kirsten Beronio served on the advisory panel for this report.

NIH-Supported Study Finds Team-Based Approach May Improve Buprenorphine Care 

A recent pilot study concluded that a collaborative approach to treating opioid use disorder that relies heavily on community pharmacists “is feasible and may increase adherence and participant satisfaction,” according to research published in the journal Addiction.
 
The study—which the National Institute on Drug Abuse, part of the National Institutes of Health, supported—studied the transfer of care of 71 participants using buprenorphine maintenance therapy for opioid use disorder from waivered physicians to trained community pharmacists. According to the study, about 90% of people in the United States live within five miles of a community pharmacy.

Researchers from Duke University and their collaborators found that nearly 89% of participants remained in the study and 95.3% adhered to the daily medication regimen. “Participants, physicians, and pharmacists alike reported high rates of satisfaction with the program,” the journal article noted.

The study’s authors concluded that the pilot shows “strong support” for advancing physician-pharmacist team-based approaches to leveraging community resources when it comes to expanding access to opioid use disorder treatment with buprenorphine.

SAMHSA Accepting Applications for Grants to Prevent Prescription Drug/Opioid Overdose-Related Deaths

SAMHSA’s Center for Substance Abuse Treatment is accepting applications for fiscal year 2021 grants to prevent prescription drug and opioid overdose-related deaths through Monday, March 1.

The program is meant to reduce the number of prescription drug and opioid overdose-related deaths and adverse events among individuals aged 18 and older by training first responders and community members on preventing these deaths and on how to implement secondary prevention strategies, such as buying and distributing naloxone.

SAMHSA said it has a total amount of about $11.4 million for this project and expects to grant 13 awards of up to $850,000 per year for up to five years. Click here to learn more.

Center for Connected Health Policy to Host Telehealth Policy Webinar on Feb. 5

The Center for Connected Health Policy will host Telehealth & Medicaid: What’s Next? A Roadmap for Telehealth Beyond the Pandemic on Friday, Feb. 5, 2021 at 2 p.m. ET.
 
The webinar will feature experts in a panel discussion about what the future looks like for telehealth policy in Medicaid. Attendees will hear from high-level administrators and policy staff from the Medicaid and CHIP Payment Advisory Commission (MACPAC), the Arizona Health Care Cost Containment System, the Colorado Department of Health Care Policy and Financing, and the Oregon Health Authority.

Click here to learn more and to register.

Save the Date: NABH 2021 Annual Meeting

NABH will host its 2021 Annual Meeting from Wednesday, Oct. 6 – Friday, Oct. 8, 2021 at the Mandarin Oriental Washington, DC.

The association re-scheduled for this later date in 2021 due to the ongoing Covid-19 pandemic. We hope you can join us!

After 2021, NABH will host its subsequent Annual Meetings in June. Please save the date for these future NABH Annual Meetings:

  • June 13-15, 2022
  • June 12-14, 2023

We look forward to seeing you in Washington!

Fact of the Week

A Mental Health America survey between June-September 2020 found that 76% of healthcare workers reported exhaustion and burnout.

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

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CMS Expands Medicare Telehealth Coverage for Mental Health and Addiction Treatment Services

The Centers for Medicare & Medicaid Services (CMS) extended some Medicare coverage of telehealth services that the agency authorized during the Covid-19 pandemic. The changes were included in the final 2021 Medicare Physician Fee Schedule rule that was published in the Federal Register on Dec. 28, 2020.

Extended Coverage of Certain Services

CMS permanently extended Medicare coverage of the following services provided via telehealth:

  • Home Visits, Established Patients (only for treatment of substance use disorders (SUDs) and co-occurring mental health disorder when less complex, lasting typically 25 minutes) (99347 & 99348),
  • Group Psychotherapy (other than of a multiple-family group) (90853),
  • Psychological and Neuropsychological Testing (96121),
  • Care Planning for Patients with Cognitive Impairment (99483),
  • Domiciliary, Rest Home, or Custodial Care services (99334),
  • Domiciliary, Rest Home, or Custodial Care services (99335),
  • Visit Complexity with certain office/outpatient evaluation and management services (G2211),
  • Prolonged office or other outpatient evaluation and management service(s) (G2212), and
  • New codes for the initial month or subsequent months of psychiatric collaborative care model services (G2214).

CMS also finalized a long list of telehealth services that are covered temporarily until the end of the calendar year in which the public health emergency (PHE) ends. Here are some examples:

  • Home Visits, Established Patients (only for the treatment of substance use disorder or co-occurring mental health disorder when moderate to severe, typically lasting 60 minutes) (99349, 99350),
  • Psychological and Neuropsychological Testing (96130- 96133, 96136- 96139),
  • Therapy Services, Physical, and Occupational Therapy (97161-97168, 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521- 92524, 92507),
  • Emergency Department Visits (99281-99285),
  • Domiciliary, Rest Home, or Custodial Care services, Established patients (99336 & 99337),
  • Initial Hospital Care and Hospital Discharge Day Management (99221-99223, 99238, 99239), and
  • Subsequent Observation and Observation Discharge Day Management (99217, 99224-99226).

CMS said it intends these temporary extensions of coverage to allow time for the agency to consider whether these services should be extended permanently.

Special Coverage of Mental Health and Substance Use Disorder Treatment via Telehealth

This rule implements a change in the Medicare statute enacted in the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act) authorizing Medicare coverage as of July 2019 of telehealth visits in a patient’s home (instead of a healthcare facility that qualifies as originating site) and regardless of whether the patient lives in a rural area, but only for treatment of substance use disorders (SUDs) and co-occurring mental illnesses. This final rule states that permanent Medicare coverage of home visits for treatment of SUDs and co-occurring mental health conditions is limited to established patients with less complex conditions. Medicare coverage of home visits via telehealth for moderate to severe SUDs or co-occurring mental illnesses will be covered temporarily until the end of the calendar year in which the PHE ends.

CMS also finalized regulations allowing periodic assessments, which are part of opioid use disorder treatment services for opioid treatment programs, to be furnished via two-way interactive audio-video communication technology, as clinically appropriate, if all other applicable requirements are met.

With a late-breaking addition, the FY 2021 Appropriations and Covid-19 Relief legislation enacted into law on Dec. 27, 2020 includes a provision authorizing Medicare coverage of mental health services via telehealth to beneficiaries in their homes regardless of geographic location. This provision adds mental health to the existing Medicare coverage authorized in the SUPPORT Act of telehealth services for beneficiaries in their homes, regardless of geographic location, to treat SUDs and co-occurring mental health conditions. The new law adds a requirement that a provider must have seen the beneficiary within six months before receiving the telehealth service to treat a mental health condition. The provision in the latest Covid-19 Relief legislation also states that the Health and Human Services (HHS) secretary may implement this section by interim final rule or “program instruction.” NABH will advise members when HHS takes action to implement the important provision.

Coverage of Audio-only and Some Other Services Not Extended

Medicare will no longer cover audio-only telehealth visits by physicians (99441-99443) and non-physician practitioners (98966-98968) after the PHE ends. CMS explained that its longstanding interpretation of the statutory provision that authorizes coverage of telehealth refers use of an “interactive telecommunication system” that CMS interprets to exclude audio-only technology.

However, CMS did create a new code (G2252) to be used for coverage of longer virtual check-ins (11 to 20 minutes of medical discussion when the acuity of the patient’s problem is not likely necessary to warrant a visit, but the needs of the patient require more assessment time from the practitioner). This new code is valued at the same rate as 99442, whereas the pre-existing virtual check-in service (G2012) is valued at the rate of 99441.

Telehealth visits will also no longer be covered for the initial visit with patients in skilled nursing facilities (SNFs) after the PHE. But CMS will allow more frequent subsequent SNF visits via telehealth, every 14 days instead of every 30 days.

Continued Coverage of Telehealth Physician Supervision of Residents and Services “Incident To” Physicians’ Services

CMS is continuing Medicare coverage of telehealth services delivered incident to the services of a billing professional until the later of the end of the year when the PHE ends or on Dec. 31, 2021. To bill Medicare, the supervising physician must be immediately available to intervene using live, two-way, audio-visual technology (e.g., a Zoom call with the patient, non-physician practitioner and physician).

In addition, CMS will continue to cover services for residents who are supervised by physicians via telehealth until the end of the PHE. Teaching physicians must use real-time audio-visual technology. This coverage will be extended after the PHE only in rural areas.
CMS clarified that Medicare will continue covering e-visits provided by licensed clinical social workers, clinical psychologists, (as well as physical therapists, occupational therapists, and speech-language pathologists) on a permanent basis. E-visits include brief online assessment and management services via telehealth as well as virtual check-ins and remote evaluation services.

CMS has created two new codes for this expanded coverage:

  • Brief communication technology-based service, e.g. virtual check-in, by a qualified healthcare professional who cannot report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous seven days nor leading to a service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion (G2251); and
  • Remote assessment of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related service provided within the previous seven days nor leading to a service or procedure within the next 24 hours or soonest available appointment (G2250).
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CEO Update 130

SAMHSA’s Elinore McCance-Katz Resigns Following Violence at U.S. Capitol

Elinore McCance-Katz, M.D., Ph.D. announced Thursday she is resigning as the nation’s assistant secretary for mental health and substance use, citing the riotous takeover of the U.S. Capitol on Jan. 6.

According to her statement, McCance-Katz had intended to stay in her role at the Substance Abuse and Mental Health Services Administration (SAMHSA) until the change in administration later this month. Those plans changed after she returned from a visit to a residential treatment program in New York and saw events unfold Wednesday.

“I believe that we are given certain life situations where we must make the difficult decisions and we get one chance to do it the right way,” McCance-Katz said in her statement. “Because I believe that the mental health of our people has suffered so greatly under the stresses of Covid-19, the social justice issues that have been so painful for so many, and now with the rending of our nation over questions raised about the presidential election, I cannot support language that results in incitement of violence and risks our very existence.”

McCance-Katz adds her name to a list of other high-ranking officials who have distanced themselves from the Trump administration through their resignations this week, including Transportation Secretary Elaine Chao, Education Secretary Betsy DeVos, Deputy National Security Adviser Matthew Pottinger, and others.

CMS Issues Guidance on Medicaid Coverage for Opioid Use Disorder Treatment

The Centers for Medicare & Medicaid Services (CMS) released guidance in late December about new Medicaid coverage requirements to treat opioid use disorders (OUD).

The guidance provides information to state Medicaid programs about a new mandatory Medicaid benefit added under the 2018 SUPPORT Act that requires these programs to cover all drugs and biologicals that the U.S. Food and Drug Administration has approved or licensed to treat OUD, including methadone. It also includes information about the medications and treatment services included in this new medication-assisted treatment (MAT) benefit and the locations where MAT can be provided.

In addition, the guidance includes details about other Medicaid authorities to help states expand their opioid use disorder service continuum.

SAMHSA Report Addresses How to Manage Increased Need for Services During Pandemic

SAMHSA has released a 25-page report and plan on how to address the heightened need for mental and behavioral healthcare services resulting from the effects of the Covid-19 global pandemic.

Saving Lives Through Increased Support for Mental and Behavioral Health Needs is a result of President Trump’s Executive Order of the same name on Oct. 5, 2020. The effort is meant to address preventing suicide, ending the nation’s opioid crisis, and improving mental and behavioral health in the United States.

The Executive Order’s goal is to reduce the number of immediate life-threatening situations related to mental illness and substance use disorders, and it also outlines ways to alleviate these ongoing problems.

Most of the report highlights “building on existing strengths,” such as prevention, crisis services, the work of current programs, and more, while the remainder of the report offers recommendations.

NABH Welcomes Jameson Norton as 2021 Board Chair and New Board Members

NABH is pleased to welcome Jameson K. Norton, M.B.A., F.A.C.H.E., who has served on the NABH Board of Trustees, as the association’s 2021 Board Chair, effective Jan. 1.

Based in Nashville, Norton serves as the chief operating officer of Newport Healthcare, which treats individuals ages 12–27 who struggle with depression, anxiety, and/or trauma-related issues, along with co-occurring eating disorders and substance abuse. Formerly he served as president of Vanderbilt Psychiatric Hospital and Outpatient Services. Norton has served in the U.S. Marine Corps and earned a B.A. at the University of Virginia and M.B.A. at Vanderbilt University’s Owen Graduate School of Management.

In addition, NABH welcomes board members Pat Connell, M.B.A., F.A.C.H.E., C.B.H.E., C.H.C., vice president of behavioral health, compliance and government relations at Boys Town Behavioral Health Division in Boys Town, Neb.; Dwight A. Lacy, M.B.A., group president of western operations at Franklin, Tenn.-based Acadia Healthcare, Inc.; and Susan L. Wright, M.B.A., director of behavioral health operations at BayCare Behavioral Health in Clearwater, Fla.

The association also welcomes Teena Ahuja, vice president of behavioral health at Prime Healthcare in Ontario, Calif.; Joe Pritchard, CEO of Pinnacle Treatment Centers, Inc. in Mount Laurel, N.J.; and Patricia Rehmer, M.S.N., A.C.H.E., president, behavioral health network and senior vice president of Hartford HealthCare, who have joined as automatic board seat members.

John Snook to Join NABH as Director of Government Relations and Strategic Initiatives

John Snook will join the National Association for Behavioral Healthcare (NABH) as director of government relations and strategic initiatives on Jan. 18.

John comes to NABH from the Treatment Advocacy Center, where he served as the mental health advocacy organization’s executive director since 2015. He also brings with him more than 15 years of advocacy and policy experience at the state and federal levels. The Treatment Advocacy Center’s influence has been far-reaching: more than half of the states have reformed their mental health laws due in large part to the Center’s advocacy efforts, and the group’s original research on issues such as criminalization of mental illness has rewritten the national narrative on severe mental illness treatment.

During his tenure as executive director of the Treatment Advocacy Center, John secured more than $70 million in federal funding for assisted outpatient treatment programs across the country, guided advocacy efforts that led to bipartisan mental health reforms in the 21st Century Cures Act; directed the publication of 15 major research reports; and oversaw the passage of 44 new laws designed to improve access to treatment for people with severe mental illness.

“John is well-respected in Washington for his strong commitment to improving behavioral healthcare access and services in the United States,” said NABH President and CEO Shawn Coughlin. “We are excited and fortunate to welcome him to NABH,” he added. “Our national membership and Washington-based team will benefit greatly from his knowledge, experience, and ideas.”

John’s interest in mental health began when he was in law school and saw a loved one struggle with mental illness. He championed mental illness reform, working first with the West Virginia Supreme Court on mental health issues, and then as an advocate at the Treatment Advocacy Center.

John earned a B.A. from Washington & Jefferson College and a J.D. from the George Mason School of Law. 

Center for Connected Health Policy to Host Telehealth Policy Webinar on Feb. 5 

The Center for Connected Health Policy will host Telehealth & Medicaid: What’s Next? A Roadmap for Telehealth Beyond the Pandemic on Friday, Feb. 5, 2021 at 2 p.m. ET.
 
The webinar will feature experts in a panel discussion about what the future looks like for telehealth policy in Medicaid. Attendees will hear from high-level administrators and policy staff from the Medicaid and CHIP Payment Advisory Commission (MACPAC), the Arizona Health Care Cost Containment System, the Colorado Department of Health Care Policy and Financing, and the Oregon Health Authority.

Click here to learn more and to register.

Save the Date: NABH 2021 Annual Meeting

NABH will host its 2021 Annual Meeting from Wednesday, Oct. 6 – Friday, Oct. 8, 2021 at the Mandarin Oriental Washington, DC.

The association re-scheduled for this later date in 2021 due to the ongoing Covid-19 pandemic. We hope you can join us!

After 2021, NABH will host its subsequent Annual Meetings in June. Please save the date for these future NABH Annual Meetings:

  • June 13-15, 2022
  • June 12-14, 2023

We look forward to seeing you in Washington!

Fact of the Week

In a typical year, Native American youth die by suicide at nearly twice the rate of their white peers in the United States, according to a story in Kaiser Health News that cited the Centers for Disease Control and Prevention.

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

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