HHS Includes Behavioral Healthcare Providers in Provider Relief Fund Phase 3 Distribution 

The Department of Health and Human Services (HHS) on Thursday announced an additional $20 billion is available from the Provider Relief Fund (PRF) for healthcare providers to recover Covid-19-related financial losses and changes in operating expenses.

HHS highlighted behavioral healthcare providers in its announcement and encouraged these providers to apply for this latest round of funding. HHS has developed a list of behavioral healthcare providers who are now eligible for funding, such as addiction counseling centers, mental health counselors, and psychiatrists.

“Our behavioral health providers have shouldered the burden of responding and confronting this expanded challenge triggered by the pandemic,” HHS said in the announcement. “When traditional face-to-face counseling was restricted and new telehealth flexibilities were put in place in response to the pandemic, many behavioral health providers invested in and adopted telehealth technologies to continue providing patient care.”

Providers are encouraged to apply early. Be sure to apply between Monday, Oct. 5 through Friday, Nov. 6, 2020. 

Eligible providers include behavioral healthcare providers who had previously not been eligible (presumably because they did not participate in Medicare or Medicaid); providers who had already received PRF payments; and providers who began practicing in 2020 and were therefore not eligible to apply previously.

Providers who apply will be considered first for the 2% of patient care revenue that has already been made available. If they have not yet received payments from the PRF amounting to 2% of patient care revenue, they will receive funding to reach that amount.

In addition, those who apply will receive an add-on payment above the 2% from the $20 billion allocation based on the following criteria:

• Change in operating revenues from patient care;
• Change in operating expenses from patient care, including expenses incurred related to the coronavirus; and
• Payments already received through the prior PRF distributions

All providers receiving PRF funding will be required to accept the associated terms and conditions including reporting requirements.

HHS said it plans to hold webinars to assist with the application process.

HHS Provider Relief Fund Reporting Requirements Change Terms for Recovering Lost Revenue

The Department of Health and Human Services (HHS) has issued guidance that contradicts the department’s June FAQ about calculating lost revenue from Covid-19 that may be recovered through the Coronavirus Aid, Relief, and Economic Security Act’s (CARES) Provider Relief Fund (PRF).

In the June FAQ, HHS said hospitals could “use any reasonable method of estimating the revenue during March and April 2020 compared to the same period had Covid-19 not appeared.” This latest guidance defines lost revenue that may be recovered as being limited to “a negative change in year-over-year net patient care operating income.” The guidance further specifies that providers generally will only be able to apply their PRF payments to lost revenue up to a facility’s net patient operating income for 2019.

As HHS announced previously, providers who have received more than $10,000 from the PRF are required to submit a report by Feb.15, 2021, on the use of those funds through Dec. 31, 2020, and, if necessary, a second and final report by July 31, 2021.

The PRF funding provided through the CARES Act and subsequent legislation was intended to reimburse eligible providers for healthcare-related expenses and lost revenues attributable to Covid-19. HHS had included a general commitment to reporting on the use of the PRF funds in the terms and conditions that PRF fund recipients agreed to for the funding. Previously HHS said it would issue detailed reporting instructions by Aug. 17, 2020 and the reporting system would be available Oct. 1. The reporting system is not yet available.

“We urge you to rescind the changes included in the Sept. 19 guidance regarding how lost revenue may be calculated,” NABH President and CEO Shawn Coughlin wrote in a letter to HHS Secy. Alex Azar on Oct. 1. “Please clarify that providers may continue to rely on the June guidance as an alternative and equally valid approach to calculating lost revenue attributable to Covid-19 and eligible for reimbursement with funding from the PRF.”

Please contact your U.S. senators and representatives today and ask them to urge the White House and HHS to reinstate the Covid-19 PRF reporting requirements that HHS outlined in June. Providers must be able to use these funds to recover any revenue lost due to Covid-19, rather than be limited by these new details from HHS.

NABH Sends 2021 OPPS Rule Comment Letter to CMS

NABH this week submitted comments to the Centers for Medicare & Medicaid Services (CMS) concerning partial hospitalization program (PHP) provisions in the agency’s 2021 outpatient prospective payment system (OPPS) proposed rule.

In a letter to CMS Administrator Seema Verma, NABH President and CEO Shawn Coughlin said NABH supports provisions in the rule that continue using the geometric mean per diem cost methodology to set the rates for PHPs. The association also supports maintaining a separate cost floor for the Community Mental Health Center PHPs and the Hospital-based PHPs, the letter noted.

“We agree that it is important that the per diem rates not fluctuate too greatly from year to year to provide stability for PHP providers,” Coughlin wrote in the letter. “In order to ensure stability in future rates, we recommend that CMS consider incorporating an annual adjustment to the cost floor in order to ensure that it reflects updated cost information and continues to help minimize the impact of significant changes in the median costs.”

NABH’s letter also expressed concerns about the decrease in the rate for ambulatory payment classification (APC) 5822 Level 2 Health and Behavior Services, and urged the agency to consider continuing telehealth coverage for PHP services and coverage for associated facility fees so individuals with serious behavioral health conditions can continue to access critical services.

SAMHSA Releases ‘My Mental Health Crisis Plan” Mobile App

The Substance Abuse and Mental Health Services Administration (SAMHSA) this week released “My Mental Health Crisis Plan,” a new mobile app that allows individuals with serious mental illness (SMI) to create a plan to help guide their treatment during a mental health crisis.

A SAMHSA announcement said the app was developed through SMI Adviser, a project that SAMHSA administers with funding from the American Psychiatric Association. The new resource provides a step-by-step process for individuals to create and share a psychiatric advance directive (PAD), a legal document that includes a list of instructions and preference that the individual wishes to be followed during a mental health crisis if the person is unable to make his or her own decisions.

My Mental Health Crisis Plan also allows individuals to state clearly which medications to use and not to use, preferences for hospitals and mental health professionals, the names of trusted persons who can act on their behalf, and more.

The mobile app is available in the Apple App Store and Google Play.

JAMA Study Examines PTSD Risk Factors Among First Responders in a Crisis

First responders in a major crisis may be most likely to experience post traumatic stress disorder (PTSD) if they are older and affected personally by the disasters, a new JAMA study has concluded.

For the study, researchers studied data from more than 56,000 first responders after a 9.0 magnitude earthquake that struck Japan in March 2011 that led to nearly 16,000 deaths. The responders were surveyed several times during a six-year period, and researchers found that although only 7% of the study group likely had PTSD overall, being personally affected by the disaster meant a 96% increase in likelihood of PTSD.

“Given these findings, in the future, first responders’ PTSD symptoms might be mitigated by shortening deployment length, avoiding post-deployment overtime work, and paying special attention to the needs of personal experience of the disaster or older age,” the study said. “Efforts to alleviate responders’ initial symptoms will be required.”

Please Complete the 2020 NABH Annual Survey!

The 2020 NABH Annual Survey opened in late August and NABH members should have received personalized links to the survey from consulting firm Dobson DaVanzo.

If you have not received a link, please click here and follow the instructions to submit your survey today. Your feedback will help inform and improve NABH’s advocacy efforts.

The survey closes on Saturday, Oct. 31. Thank you for your time!

Fact of the Week

Researchers from the University of Washington used data from the National Survey of Drug Use and Health to identify risk factors for suicide among individuals with mental health challenges who had criminal justice system involvement. They found that while there was a higher frequency of suicide attempts in all populations that had been involved with the criminal justice system, those who had been recently arrested were at the highest risk for suicide compared with those on parole or probation. The results suggest that prioritizing suicide prevention and mental health services after arrest could have significant impacts on this population.

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

Congress Passes National Suicide Hotline Designation Act

The House of Representatives this week passed a Senate-approved bill designating ‘988’ as the three-digit phone number for a national suicide prevention lifeline.

In a voice vote Monday, the House passed the National Suicide Hotline Designation Act, which amends the Communications Act to designate 988 as the universal dialing code for the National Suicide Prevention Lifeline. The legislation allows states to impose a 988 surcharge on phone bills to help fund the call centers, a practice states follow to support 911.

The bill has moved to the White House for President Trump’s signature. After it becomes law, the Federal Communications Commission requires all phone service providers to transition to 988 by July 16, 2022.

FDA Requires Strong Warning Labels for Benzodiazepines

The U.S. Food and Drug Administration (FDA) on Wednesday said it is requiring class-wide labeling changes for benzodiapines to include the risks of abuse, misuse, addiction, physical dependence, and withdrawal reactions to help improve their safe use.

According to the FDA, an estimated 92 million benzodiapine prescriptions were dispensed from U.S. outpatient pharmacies in 2019, with alprazolam (38%) being the most common, followed by clonazepam (24%) and lorazepam (20%).  Meanwhile, an estimated 50% of patients dispensed oral benzodiapines—commonly used to treat anxiety, insomnia, seizures, and panic disorders—received them for two months or longer, the agency noted.

“While benzodiazepines are important therapies for many Americans, they are also commonly abused and misused, often together with opioid pain relievers and other medicines, alcohol and illicit drugs,” FDA Commissioner Stephen M. Hahn, M.D., said in a news release. “We are taking measures and requiring new labeling information to help healthcare professionals and patients better understand that while benzodiazepines have many treatment benefits, they also carry with them an increased risk of abuse, misuse, addiction and dependence.”

CDC’s National Center for Health Statistics Releases Reports on Mental Health and Treatment

The Centers for Disease Control and Prevention’s (CDC) National Center for Health Statistics (NCHS) has released three new reports that examine anxiety disorder, depression, and treatment among U.S. adults in 2019.

The findings showed that more than 15% of U.S. adults experienced symptoms of anxiety and 18.5% of U.S. adults had symptoms of depression that were “mild, moderate, or severe in the past two weeks.”

The studies also showed women were more likely than men to have received any mental health treatment, and the percentage of adults who received any mental treatment varied by age group and urbanization level.

HHS-OIG Report Says CMS Should Pursue Strategies to Boost the Number of At-Risk Medicaid Beneficiaries Acquiring Naloxone

A new report from the U.S. Department of Health and Human Services’ (HHS) Office of Inspector General (OIG) concluded that the Centers for Medicare & Medicaid Services (CMS) should pursue strategies to increase the number of at-risk beneficiaries acquiring community-use versions of naloxone through Medicaid.

The study notes that, on average, 130 people in the United States die every day from an opioid overdose, and the drug naloxone “plays a critical role in saving the lives of those who abuse or misuse opioids.” As one review of emergency data found that, when given naloxone, 94% of people survived their overdose. In 2018, the U.S. Surgeon General issued an advisory that said increasing naloxone’s availability and targeted distribution is a “critical component” of efforts to reduce opioid-related overdose deaths.

For the report, the OIG’s office used state-reported Medicaid data to determine how total utilization for naloxone changed in the Medicaid program between 2014 and 2018. By using manufacturer-reported sales data, the researchers determined the proportion of all naloxone distributed nationwide.

“Access to naloxone for Medicaid beneficiaries has expanded significantly, with the program paying for 21 times more doses in 2018 than in 2014,” the OIG report said. “Despite this growth, Medicaid paid for only 5% of all naloxone distributed in the United States in 2018,” it continued. “This figure is especially concerning given that (1) Medicaid covers almost 40% of nonelderly adults with opioid use disorder (OUD) and (2) some States with extremely high overdose mortality rates paid for relatively little naloxone under Medicaid.”

Treatment Advocacy Center Releases New Analysis on State Involuntary Treatment Laws 

New research from the Treatment Advocacy Center shows that whether or not a person receives timely, appropriate treatment for acute psychiatric crisis or chronic psychiatric disease is almost entirely dependent on the state in which he or she is living when the crisis occurs.

Grading the States: An Analysis of U.S. Psychiatric Treatment Laws offers a detailed evaluation of each state’s treatment laws compared with other states, and it also identifies specific statutory changes that states can make to improve access to care for this population. According to the report, 10 states earned an “A” grade while eight states earned an “F.”

Meanwhile, six states—Alabama, Delaware, Georgia, Oklahoma, Pennsylvania, and Tennessee—still have an outdated requirement that harm to self or others be imminent for a person to qualify for inpatient commitment, and seven states—Georgia, Ohio, Oklahoma, Oregon, Rhode Island, Wisconsin, and Wyoming—require harm from failing to meet basic needs to be imminent to intervene.

“The U.S. mental health system is not one single broken system, but many,” the study said. “Responsibility for making needed reform is in the hands of the states and thousands of local governments,” it continued. “Each has a unique set of laws, regulations, policies and budget priorities that, collectively, make up our national mental health system.”

September is National Recovery Month & National Suicide Prevention Month

There are a few days remaining in National Recovery Month and National Suicide Prevention Month, commemorated every September to educate Americans about services, treatment, and resources available to those with mental health and substance use disorders and to promote suicide prevention.

SAMHSA has hosted a webinar series throughout the month that featured topics including supported employment, communities supporting recovery, and the importance of integrating recovery support services.

Meanwhile, the National Action Alliance (Action Alliance) for Suicide Prevention has developed several resources to help build awareness about suicide prevention. Please see the Action Alliance’s #BeThere activities and use the hashtag #BeThere to educate your organization’s social media followers.

And please remember to follow NABH on Twitter and LinkedIn to learn what NABH members, federal agencies, and other organizations are doing to honor National Recovery Month and National Suicide Prevention Month.

Please Complete the 2020 NABH Annual Survey! 

The 2020 NABH Annual Survey opened in late August and NABH members should have received personalized links to the survey from consulting firm Dobson DaVanzo.

If you have not received a link, please click here and follow the instructions to submit your survey today. Your feedback will help inform and improve NABH’s advocacy efforts.

The survey closes on Saturday, Oct. 31. Thank you for your time!

Fact of the Week

Emerging literature shows a connection between air pollution and anxiety and depression: “It’s thought that the change in the nervous system that seems to be stimulated by air pollution, and perhaps the vascular system changes, can affect brain function and lead people into a more depressive state,” Michael Jerrett, Ph.D. of the Center for Healthy Climate Solutions at UCLA’s Fielding School of Public Health told Kaiser Health News.

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

NABH Sends CMS Comments on Covid-19 Reporting Requirements

NABH this week urged the Centers for Medicare & Medicaid Services (CMS) to exempt psychiatric hospitals and psychiatric units in inpatient hospitals from the Covid-19 reporting requirements the agency added to the Conditions of Participation (CoP) and announced in an interim final rule.

In a letter to CMS Administrator Seema Verma, NABH President and CEO Shawn Coughlin asked that if the agency does not exempt psychiatric hospitals and units, that it at least modify the requirements to remove the ones that are not relevant to psychiatric facilities. These requirements relate to supplies and use of Remdesivir, intensive care unit beds, ventilators and ventilator supplies and medications, and the use of emergency department or overflow locations for Covid-19 patients while those patients wait for an inpatient bed.

“Furthermore, we ask that you modify the interim final rule to lessen the frequency of reporting,” Coughlin wrote in the letter. “The rule does not explain why this very burdensome reporting must be done every day, seven days a week. It is especially unclear why this daily reporting is necessary for facilities that are not focused on treating Covid-19. The staffing information is particularly arduous to submit on a daily basis.”

The letter also highlights that guidance on data elements incorporated in the interim final rule indicate that some hospitals may report to their state agencies, which will report to the federal government on their behalf. But it’s unclear how hospitals will know whether their states have been certified to conduct that reporting.

“In addition, the status of each state’s certification may change, and states may be permitted to report for some of their hospitals, but not all,” the letter noted. “It is not clear how hospitals will know whether they should report this information to their state agencies or to the federal government, especially because a state’s certification may change over time.”

SAMHSA Proposes Establishing Guidelines to Include Hair Specimens in Federal Workplace Drug Testing Programs

The Substance Abuse and Mental Health Services Administration (SAMHSA) is proposing to establish scientific and technical guidelines to include hair specimens in the Mandatory Guidelines for Federal Workplace Drug Testing Programs using Hair (HMG).

In a recent notice, SAMHSA said the HMG will allow federal executive branch agencies to collect and test a hair specimen as part of their drug testing program within the limitation that hair specimen be used for pre-employment and random testing.

A federal agency that chooses to test hair specimens must authorize collection and testing of at least one other specimen type (i.e., urine or oral fluid) that is authorized under the Mandatory Guidelines for Federal Workplace Drug Testing Programs and provide procedures in which the alternate specimen is used in cases when a donor is unable to provide a sufficient amount or length of hair.

SAMHSA has requested public comments on this notice through Monday, Nov. 9. Click here to learn more about the guidelines and how to submit comments.

CMS Issues Covid-19 Reporting Guidance for Labs and Long-term Care Facilities

CMS has issued new surveyor guidance for Covid-19 laboratory test reporting for Clinical Laboratory Improvement Amendments-certified laboratories.

These labs are expected to adhere to the new requirements no later than Wednesday, Sept. 23 and will be subject to civil monetary penalties if they do not comply.

New Report Highlights Harmful Effects of Eating Disorders on Individuals, Families, and Society

About 9% of the U.S. population, or approximately 28.8 million Americans, will have an eating disorder in their lifetime, says a new report from the Strategic Training Initiative for the Prevention of Eating Disorders, or STRIPED.

Working with the Academy for Eating Disorders and Deloitte Access Economics, STRIPED spent a year gathering evidence on the effects of eating disorders on individuals, families, and societies; analyzing the direct costs for treatment; and reporting other economic costs, such as informal caregiving, productivity, and estimated substantial losses in wellbeing.

Researchers found that eating disorders cost the U.S. about $64.7 billion a year, including $48.6 billion in productivity losses, $6.7 billion in informal caregiving, $4.8 billion in efficiency losses, and $4.6 billion throughout the country’s health system.

Eating disorders affect everyone, the report found, but people of color with eating disorders are half as likely to be diagnosed or to receive treatment. Meanwhile, females are twice as likely to have an eating disorder than males.

CMS to Host Open Door Forum on Hospital IPPS and OPPS Rules Next Week 

CMS will host an Open Door Forum on Thursday, Sept. 17 to provide an update and answer questions about the agency’s 2021 Hospital Inpatient Prospective Payment System final rule and 2021 Outpatient Prospective Payment System proposed rule.

The hourlong event will begin at 2 p.m. ET, and CMS has requested that participants dial in 15 minutes before the call begins. This is a conference call only. Click here for details.

September is National Recovery Month & National Suicide Prevention Month

September is National Recovery Month and National Suicide Prevention Month, which are intended to educate Americans about services, treatment, and resources available to those with mental health and substance use disorders and to promote suicide prevention.

SAMHSA will host a webinar series throughout Recovery Month that will feature a different topic every Thursday. Upcoming topics include supported employment, communities supporting recovery, and the importance of integrating recovery support services.

Meanwhile, the National Action Alliance (Action Alliance) for Suicide Prevention has developed several resources to help build awareness about suicide prevention. Please see the Action Alliance’s #BeThere activities and use the hashtag #BeThere to educate your organization’s social media followers.

And please remember to follow NABH on Twitter and LinkedIn to learn what NABH members, federal agencies, and other organizations are doing to honor National Recovery Month and National Suicide Prevention Month.

Please Complete the 2020 NABH Annual Survey!

The 2020 NABH Annual Survey opened late last month and NABH members should have received personalized links to the survey from consulting firm Dobson DaVanzo.

If you have not received a link, please click here and follow the instructions to submit your survey today. Your feedback will help inform and improve NABH’s advocacy efforts. Thank you for your time!

Fact of the Week

Calls to the National Eating Disorders Association’s helpline are up 70% to 80% in recent months.

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