White House Proposes Changes to IMD Exclusion in 2021 Budget Proposal to Congress

The White House this week released a $4.8 trillion budget for 2021 that would modify Medicaid’s Institutions for Mental Diseases (IMD) exclusion to provide states with flexibility to provide inpatient mental health services to beneficiaries with serious mental illness (SMI).

The budget requests $94.5 billion for HHS, a 10-percent decrease from the 2020 enacted level. Although Congress is likely to reject President Trump’s proposal, the budget is significant for outlining the president’s top policy priorities as he seeks re-election in November. Notably for NABH, those priorities include mental health and addiction treatment services.

That includes changes to the IMD exclusion, which under current law states Medicaid cannot pay for certain inpatient stays at IMDs. The president’s budget would provide more than $5 billion in new federal funding to states to ensure the full continuum of care exists to provide help to people with SMI. These changes—which appear in summary tables at the end of the budget proposal—would also exempt Qualified Residential Treatment Programs (QRTPs) from the IMD exclusion.

The budget also includes $225 million for Certified Community Behavioral Health Clinics (CCBHC) expansion grants, and would extend, through 2021, the CCBHC Medicaid demonstration programs to improve community mental health services for the eight states participating currently in the demonstration. In addition, the White House has proposed $25 million to expand primary healthcare services to address homelessness. These provisions, together with the changes to the IMD exclusion, are “part of a comprehensive strategy that includes improvements to community-based treatment,” the budget proposal noted.

Meanwhile, the president’s 2021 budget would continue 2020 funding to expand medication assisted treatment (MAT) from a small pilot program to half of all eligible Bureau of Prisons (BOP) facilities and provide an additional $37 million to complete MAT expansion to all eligible BOP facilities.

The proposal also includes $1.6 billion—an $85 million increase from the 2020 enacted level—for State Opioid Response grants, which support prevention, treatment, and recovery support services. States would be given flexibility to use these funds to address the increasing number of overdoses related to psychostimulants, in­cluding methamphetamines.

NABH will continue to analyze the Trump administration’s budget proposal and keep NABH apprised of any additional details regarding the IMD exclusion, MAT funding, and other topics related to the association’s policy priorities.

CMS Recommends 2020-2021 Policy Changes to Several Programs in Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would revise regulations for Medicare Advantage (Part C), the Medicare Prescription Drug Benefit (Part D) program, the Medicare Cost Plan, Programs of All-Inclusive Care for the Elderly (PACE), and the Medicaid program in 2020 and 2021.

According to a summary, the rule would implement certain sections of the Bipartisan Budget Act of 2018, the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT), and the 21^st Century Cures Act. The rule aims to improve Medicare’s Part C and D programs, codify several existing CMS policies, and implement other technical changes.

For Medicare Part D’s mandatory drug management programs (DMPs), the rule proposes to reduce the misuse of opioid medications in prescription drug plans. Currently, Part D plan sponsors are required to include Part D beneficiaries with a history of opioid-related overdose in DMPs. The rule would create a new exemption DMP category that includes individuals with sickle cell disease, those who receive hospice care, or those who live in long-term care facilities.

CMS will accept public comments on the rule through Monday, April 6.

NABH Supports FCC’s Suicide Hotline Implementation Act Proposed Rule and Nutrition CARE Act

NABH this week joined other members of the Mental Health Liaison Group (MHLG) in sending a public comment letter to Federal Communications Commission Chairman (FCC) Ajit Pai about the FCC’s proposed rule for the Implementation of the National Suicide Hotline Improvement Act of 2018.

“MHLG fully supports the FCC’s proposed rule plan to identify a three-digit number – 9-8-8 – to be designated for suicide and other mental health crises,” the MHLG wrote. “It is important that the designated number can be implemented quickly and with minimal confusion for the public,” it continued. “We implore the FCC and other policy leaders to make it a priority for the new 9-8-8 system to be nationally available and adequately resourced, so that all Americans have access to this crisis line.”

NABH also recently signed onto a letter of support for the Nutrition Counseling Aiding Recovery for Eating Disorders (CARE) Act, which would provide medical nutrition therapy (dietitian services) for seniors and persons with disabilities who are affected by eating disorders under Medicare Part B. As the letter notes, eating disorders are serious mental illnesses that affect 30 million Americans in the course of their lifetime. These disorders have the second highest mortality rates of any psychiatric illness after opioid use disorder.

NABH was one of 27 organizations that sent the letter to Senate Finance Committee Chairman Chuck Grassley (R-Iowa) and Ranking Member Ron Wyden (D-Ore.) to urge the committee to advance S. 2907 for consideration.

CMS to Host Medicare Learning Network Event on Availability of SUD Benefits

CMS will host a Medicare Learning Network event next week to seek feedback from clinicians and associations that represent healthcare providers on what supplemental benefits they use to treat Medicare Advantage patients with substance use disorders (SUDs).

The SUPPORT Act outlines strategies to address opioid misuse and requires CMS to evaluate the extent to which Medicare Advantage plans offer supplemental benefits to treat or prevent SUDs not otherwise covered under traditional Medicare, including how clinicians are impacted by the availability of supplemental benefits used to treat SUDs.

A presentation will be available before the event, which CMS will host on Tuesday, Feb. 18 from 1:30 p.m. until 3 p.m. ET. Click here to learn more and to register.

Join Us for Hill Day at the NABH 2020 Annual Meeting!

NABH is pleased to present Hill Day 2020 at the association’s Annual Meeting in Washington, D.C. on Tuesday, March 17 from 1:30 to 5 p.m. ET.

The NABH team will schedule Capitol Hill meetings and briefings for Annual Meeting attendees interested in Hill Day and will provide background materials and legislative priority documents to attendees before the Annual Meeting.

To take advantage of this free opportunity, please indicate that you want to participate in Hill Day when you register for the Annual Meeting, or contact Julia E. Richardson, director of advocacy and senior counsel, at julia@nabh.org or 202.393.6700, ext. 103.

Please visit NABH’s Annual Meeting homepage to view the meeting’s preliminary program and learn about the meeting’s speakers, exhibitors, and sponsors.

We look forward to seeing you next month!

Fact of the Week

In 2018 an estimated 31.9 million Americans reported using an illicit drug in the past month.

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

ONDCP Issues 2020 National Drug Control Strategy and Treatment Plan

The Office of National Drug Control Policy (ONDCP) this week issued its national 2020 National Drug Control Strategy (Strategy) and accompanying National Treatment Plan (NTP) that includes action items for federal agencies and external stakeholders to increase access to care and close the addiction treatment gap. 
 
The Strategy is presented using the domains of prevention, treatment and recovery, and supply-side strategies for reducing the availability and consumption of illicit drugs. These domains are established as ‘pillars’ that undergird the following federal initiatives of “expanding the early intervention, treatment and recovery infrastructure; improving the delivery system; and improving quality.”

Specifically, the NTP calls for treatment expansion and improved quality by:

• Developing protocols for medically managed withdrawal including MAT to prevent relapse and promote stabilization;
• Increasing emergency department use of addiction medicine specialty services;
• Exploring the inclusion of stimulant disorder treatment in opioid treatment programs;
• Increasing access to all medication and psychosocial services, promoting syringe exchange, interim methadone, mobile methadone vans, and peer outreach (one objective of the federal Performance and Reporting System is to make sure 100% of all specialty providers offer MAT by 2020);
• Adopting model state specialty SUD treatment licensing laws;
• Developing mobile and online platform with updated information on treatment slot availability with online appoint capacity;
• Encouraging public and private payers to cover comprehensive services and improve reimbursement rates where out-of-network rates are higher;
• Urging providers to subsidize and provide treatment scholarships; and
• Exploring the idea of developing national consensus standards for addiction treatment to consolidate treatment quality standards.

Please contact Sarah Wattenberg, NABH’s director of quality and addiction services, if you have questions about the Strategy or NTP.

OIG Report Finds More Than One-Third of New Jersey’s Federal Medicaid Reimbursement for Providing Community-Based Treatment Services Was Unallowable

HHS’ Office of Inspector General (OIG) has recommended the state of New Jersey refund the federal government $14.8 million after the OIG concluded more than a third of the state’s federal Medicaid reimbursement for providing community-based treatment services was unallowable.
 
The OIG’s report said that of New Jersey’s 100 sampled claims for federal Medicaid reimbursements of payments for Programs of Assertive Community Treatment (PACT), 50 complied with federal and state requirements, but 50 did not. Meanwhile, of the 100 claims, 21 contained more than 1 deficiency.
 
“We found PACT program services provided were not adequately supported or documented (36 claims), plan of care requirements were not met (17 claims), PACT teams did not include staff from required clinical disciplines (8 claims), and providers did not obtain prior authorization for beneficiaries (5 claims), among other findings,” the report said.
 
The OIG’s other recommendations include the state improving procedures to identify deficiencies similar to those identified in the report, and considering regulations for periodic reassessments to determine whether beneficiaries enrolled in PACT continue to require PACT services.

The National Academies Releases Report to Improve OUD and Infectious Disease Services

The National Academies of Sciences, Engineering, and Medicine (NASEM) has released Opportunities to Improve Opioid Use Disorder and Infectious Disease Services: Integrating Responses to a Dual Epidemic, which identifies barriers to integrating opioid use disorder (OUD) and infectious disease services and recommendations to overcome those challenges.
 
The report notes that infectious diseases related to OUD today include human immunodeficiency virus (HIV) and hepatitis A, B, and C viruses, as well as bacterial fungal, and other infections. Barriers to integrating OUD and infectious disease prevention and treatment services include, but are not limited to, prior authorization policies, lack of data and integration sharing, inadequate workforce training, and a disconnect between the health and criminal justice systems.
 
“Integrating medical services—such as co-locating services, sharing a common vision, and aligning processes—is a well-recognized strategy for the delivery of comprehensive healthcare,” the report noted. “When SUD treatment is moved from a stand-alone clinic to a general medical setting, the emphasis may expand to encompass harm reduction tactics and principles, including strategies for safer drug use, minimizing risk of overdose, and preventing transmission of infectious disease.”

JAMA Study Examines Comparative Effectiveness of Different Treatment Pathways for OUD

New research in JAMA Network Open shows treatment with buprenorphine or methadone was associated with reductions in overdose and serious opioid-related acute care use, but only a few individuals were treated with these medications.
 
In the comparative effectiveness research study of 40,885 adults with OUD that compared six different treatment pathways, only treatment with buprenorphine or methadone was associated with reduced risk of overdose and serious opioid-related acute care use compared with not treatment during three and 12 months of follow-up.
 
“These findings suggest that opportunities exist for health plans to reduce restrictions on use for medication for opioid use disorder (MOUD) and the need for treatment models that prioritize access to and retention of MOUD treatment,” the study concluded.

Trump Administration Releases Tool to Help Rural Leaders Build Drug-Free Communities

The Trump administration has released the Rural Action Guide: Building Stronger, Healthy, Drug-Free Rural Communities, a nearly 100-page document meant to help rural community leaders build an effective, local response to addiction.
 
“The Rural Community Action Guide is an important tool to equip rural leaders with critical information from lessons learned on the frontlines of prevention, treatment, and recovery in rural America,” James Carroll, director of national drug control policy, wrote in the preface to the guide. “While no two rural communities are the same, there are promising practices gleaned from rural leaders in one town that can be replicated in another,” he added. “With this information, local leaders can then design a more effective strategy for deployment in their own community.”
 The guide is divided into five sections: face of addiction, impact of addiction on a rural community, prevention, treatment, and recovery.

SAMHSA to Host IDSUDCC Meeting on Friday, Feb. 28

The Substance Abuse and Mental Health Services Administration (SAMHSA) announced the Interdepartmental Substance Use Disorders Coordinating Committee (ISUDCC) will meet on Friday, Feb. 28 at 9:30 a.m. ET.

Held at SAMHSA’s headquarters in Rockville, Md., the meeting is open to the public and will focus on both federal and non-federal advances to address substance use disorders.

Click here for more information.

Political Analyst Nathan L. Gonzales to Address NABH 2020 Annual Meeting Attendees

NABH is pleased to welcome Nathan Gonzales, editor and publisher of Inside Elections with Nathan L. Gonzales, as the 2020 Annual Meeting Luncheon speaker.

Inside Elections with Nathan L. Gonzales provides non-partisan analysis of campaigns for Senate, House, governor and president. Mr. Gonzales can be seen regularly on CNN discussing the latest in politics, and the New York Times, the Washington Post, the Wall Street Journal, and USA Today have all sought him out for his expertise.

Mr. Gonzales will speak on Tuesday, March 17 at noon during the Annual Meeting Luncheon.

Please learn more about our Annual Meeting speakers and register for the 2020 Annual Meeting if you haven’t done so already. Also, be sure to reserve your room before the hotel cut-off date on Friday, Feb. 14.

We look forward to seeing you in Washington!

Fact of the Week

Only a small portion of clinicians in SAMHSA’s buprenorphine practitioner locator ultimately offered initial appointments, implying the database is only marginally useful for patients.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond