CMS Announces New Survey and Certification Process for Psychiatric Hospitals

The Centers for Medicare & Medicaid Services (CMS) this week announced it has streamlined the process to survey the nation’s psychiatric hospitals to review for compliance with participation requirements in one comprehensive survey.
 
Beginning in March, CMS will send psychiatric hospitals one survey to evaluate their compliance with both general hospital and psychiatric hospital participation requirements. CMS is not making any changes to the special psychiatric Conditions of Participation (CoPs) in this process.

Under this change, CMS will move the interpretive guidelines from State Operations Manual (SOM) Appendix AA, or the special psychiatric CoPs, into Appendix A, the CoPs for general hospitals. Subsequently CMS will delete Appendix AA. This change will allow CMS to issue a single survey and report to hospitals, rather than two.

“We appreciate CMS’ attention on the special psychiatric CoPs, which is long overdue,” NABH President and CEO Shawn Coughlin said in a news release NABH issued about the announcement. “At the same time, shifting these components into a single survey without reforming these CoPs does not provide relief to providers,” he added. “The special psychiatric CoPs are no longer appropriate in today’s environment of care. CMS should update the interpretive guidance to reflect modern methods of psychiatric services.”

Click here to read the Jan. 13 announcement from CMS.

NABH Responds to CMS’ Request for Information on Reducing Administrative Burden

NABH on Friday submitted recommendations to CMS on how to reduce the administrative burden for behavioral healthcare providers.

The letter to CMS Administrator Seema Verma was NABH’s response to CMS’ request for information as part of the agency’s Patients Over Paperwork initiative. In it, NABH made recommendations regarding special Conditions of Participation, B-Tags, and the Emergency Medical Treatment and Labor Act (EMTALA).

“Adopting fewer burdensome requirements would benefit the healthcare system by reducing unnecessary costs and providing greater stability and predictability for providers as they navigate the regulatory environment,” NABH President and CEO Shawn Coughlin wrote in the letter. “In addition, patients would benefit as clinicians would be able to shift more of their attention, and facilities would be able to shift more of their resources, away from compliance for compliance’s sake and toward initiatives that meaningfully contribute to safe, high-quality care.”

NABH Sends Support Letter for Expanding Access to Inpatient Mental Health Act

NABH sent a letter this week to Rep. Tom Emmer (R-Minn.) supporting the Minnesota Republican’s Expanding Access to Inpatient Mental Health Act, a bill that would make changes to Medicaid’s 15-day cap for inpatient stays.

In 2016 CMS changed how the Institutions for Mental Diseases (IMD) exclusion applies to managed Medicaid programs. Since then, that change has permitted Medicaid managed care states to receive payments for an enrollee in an IMD if the patient’s stay is no longer than 15 days in a month.

While NABH is pleased this change has allowed thousands of new low-income patients to receive treatment, the arbitrary 15-day cap too often prevents patients from receiving the care they need if those patients lack coverage beyond 15 days.

NABH strongly supports Expanding Access to Inpatient Mental Health Act because this legislation improves on the changes made in 2016 by removing the 15-day cap. Closing this coverage gap will allow patients and their treatment teams to decide on the appropriate length of stay.

NABH Welcomes NIMH Director Joshua Gordon, M.D., Ph.D. as Annual Meeting Speaker

NABH is pleased to welcome Joshua Gordon, M.D., Ph.D., director of the National Institute of Mental Health (NIMH) as an Annual Meeting keynote speaker on Tuesday, March 17 at 8:30 a.m.

Gordon earned his M.D. and Ph.D. at the University of California, San Francisco, and completed his psychiatry resident and research fellowship at Columbia. He joined the Columbia faculty in 2004 as an assistant professor in the Department of Psychiatry, where he conducted research, taught residents, and maintained a general psychiatry practice. He has been director of the NIMH since September 2016.

Please visit our Annual Meeting Speakers page to learn more. And please be sure to register for the Annual Meeting and reserve your hotel room if you haven’t done so yet.

We look forward to seeing you in Washington!

Study Examines Relationship Between Community Care and Inpatient Services

Community care and inpatient psychiatric services are complements, not substitutes, in behavioral healthcare, according to a study published online in Psychiatric Services.

Consequently, “Substantial resources should be allocated to services along a coordinated, balanced continuum of mental health care, where both psychiatric hospitals and community psychiatric services offer critical points of service,” author Isabel M. Perera wrote in the study.

According to the findings, countries that provide high levels of psychiatric hospital services also tend to provide high levels of community-based care. Perera wrote that additional research is needed to examine this relationship and the mechanisms underlying it.

“One hypothesis is that the hospital serves a coordinating role,” Perera wrote. “In the same way that general hospitals develop outpatient units, urgent care centers, and satellite clinics, so too do hospitals diversify their psychiatric services.”

Government Accountability Office Requests MedPAC Nominations

The Government Accountability Office (GAO) is requesting nominations for the Medicare Payment Advisory Commission, or MedPAC.

GAO will accept letters of nomination and resumes until Friday, Feb. 14. NABH is pleased to help any NABH member who is interested in applying. Please contact Emily Wilkins, NABH’s administrative coordinator, if you have questions.

Save the Date: IPFQR Webinar Scheduled for Thursday, Jan. 30

CMS’ Quality Reporting Center will host a webinar for participants in the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program on Thursday, Jan. 30 at 2 p.m. ET.

The presentation will review updates to the latest version of the IPFQR Program Manual and optional paper tools to equip inpatient psychiatric facilities with program requirements.

Click here to register.

Save the Date: O’Neill Institute’s Addiction Policy & Practice Summer Program

The O’Neill Institute for National and Global Health Law and Georgetown University’s Graduate School of Arts and Sciences will host an Addiction Policy & Practice Summer Program from June 10-12, 2020 at Georgetown University.

The program will bring together policymakers, advocates, journalists, and academics to examine different aspects of drug law and policy, and topics will range from adverse childhood experiences and substance use disorders to international development and supply-reduction strategies.

A detailed agenda and registration information will be available in February.

Fact of the Week

Persons with psychiatric disorders were approximately 3 to 4 times more likely than their siblings without psychiatric disorders to be either subjected to violence or to perpetrate violence.
 
For questions or comments about this CEO Update, please contact Jessica Zigmond

CMS Releases Fact Sheet for Medicare-Enrolled OTPs

The Centers for Medicare & Medicaid Services (CMS) has released an 18-page fact sheet about Medicare billing and payment for opioid treatment programs (OTPs) that participate in the federal program.

CMS began paying for enrolled OTPs to deliver opioid use disorder (OUD) treatment services to Medicare beneficiaries on Jan. 1. The fact sheet includes information about a host of issues, including covered OUD treatment services, enrollment in Medicare Electronic Data Interchange, Medicare beneficiary eligibility, claims services, payment and remittance advice, payment issues, and other resources.

The agency is now accepting and processing OTP enrollment applications. For more information, review the Medicare enrollment fact sheet.

IPFQR Program Manual Version 5.1 Now Available

CMS announced this week that the Inpatient Psychiatric Facility Quality Reporting (IPFQR) Program Manual version 5.1 and the Release Notes version 5.1 are now available.

The manual, which provides an overview of the IPFQR program and measure specifications, offers detailed instructions to register on the QualityNet Secure Portal; submit data using the web-based measures application; and understand IPFQR program preview report processes.

CMS also issued the Release Notes version 5.1, which describes changes to the manual compared with the previous version. These resources are available on the Quality Reporting Center’s IPFQR Program Resources and Tools webpage.

MACPAC Releases Report to Congress on Oversight of IMDs

Fulfilling a SUPPORT Act requirement, the Medicaid and CHIP Payment and Access Commission (MACPAC) has released its report to Congress on the oversight of Institutions for Mental Diseases (IMDs).

“The IMD exclusion is one of the few instances in Medicaid where federal funding is not available for covered services based on the setting in which they are provided,” MACPAC noted in the 128-page overview. “It is important to note that, despite this longstanding payment exclusion, there are several other Medicaid authorities that states are using to make Medicaid payments for services provided in IMDs.”

There were no recommendations in the report, which is intended instead to identify and describe IMDs in selected states—California, Colorado, Florida, Massachusetts, New Jersey, Ohio, and Texas—and provide a summary of state licensure, certification, or accreditation requirements, and Medicaid clinical and quality standards.

Organized by five chapters, the report examines the history and federal policies related to the IMD exclusion, services provided in IMDs, regulation of facilities that are subject to the IMD exclusion, Medicaid standards for behavioral health facilities, and protections for patients in those facilities.

SAMHSA Accepting Applications for Mental Health Grants

The Substance Abuse and Mental Health Services Administration (SAMHSA) is accepting grant applications for programs that would address suicide prevention as well as planning and development to promote the mental health of children, youth, and families in American Indian/Alaska Natives (AI/AN) communities.

SAMHSA plans to issue one grant of up to about $7.6 million each year for up to five years for its Suicide Prevention Resource Center grant. This program is intended to build national capacity for preventing suicide by providing technical assistance, training, and resources to assist states, tribes, communities, providers, practitioners, and members of the public on suicide-prevention strategies and best practices.

The agency is also accepting applications for its Circles of Care grants, which would provide tribal and urban Indian communities with tools and resources to plan and design a holistic, evidence and community-based, coordinated system of care to support mental health for children, youth, and families in AI/AN communications. SAMHSA said it plans to issue 17 grants of up to $310,000 each year for up to three years.

Grant applications for both programs are due by Monday, March 9. Click here for more information.

 Nearly 60% of Rural Americans Say Opioid Addiction is a ‘Serious Problem’ in Their Community

Almost 60% of Americans living in rural areas said opioid addiction is a “serious problem” in their community, according to a JAMA study published this week.

The study examined the views of U.S. rural adults on serious health and economic concerns and found that 57% of rural adults reported opioid or other drug addiction or abuse as a serious problem in their community, while 49% of rural adults said they personally know someone who has died of an opioid addiction.

“These findings suggest that in today’s economically stretched rural United States, opioid or other drug addiction or abuse has emerged as an equal problem with economic concerns,” researchers from Harvard and the Robert Wood Johnson Foundation noted in the study’s conclusion. “One in three rural adults still have problems paying their medical bills even after the passage and implementation of the Patient Protection and Affordable Care Act.”

View the 2020 Annual Meeting Preliminary Program and Register Today!

The NABH 2020 Annual Meeting preliminary program is now available online. Please take a moment to view the program and register for the meeting.

NABH will update the preliminary program periodically with session and speaker information, and all attendees will receive a final printed program at the Annual Meeting on Monday, March 16.

Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC. We look forward to seeing you in March!

Final Call to Update Your NABH Membership Information!

NABH is preparing the association’s 2020 Membership Directory. If you did not submit your updates by the Jan. 9 deadline, please contact Emily Wilkins, NABH’s administrative coordinator, at emily@nabh.org. Thank you for your cooperation!

 Fact of the Week

Adults with mental health issues were 24% less likely overall to get screened for cancer compared with the general population.

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

Congress Agrees to $5.9 Billion for SAMHSA in FY 2020 Spending Bill Package

Federal lawmakers this week agreed to fund the Substance Abuse and Mental Health Services Administration (SAMHSA) at $5.9 billion in fiscal year (FY) 2020, $140 million above the 2019 enacted level and $205 million above the president’s budget request.

The funding is part of the two legislative packages that include all 12 FY 2020 funding bills, which the House passed on Tuesday, Dec. 17. The Senate is scheduled to vote on the spending bills Friday.

SAMHSA’s funding included $3.8 billion for substance abuse treatment, $206 million for substance abuse prevention, $16 million for suicide prevention, $19 million for the Suicide Lifeline, and an increase in funding for mental health resources for children.

President Trump is expected to sign the full funding package.

NABH Participates in White House Mental Health Summit

NABH participated in the White House Mental Health Summit on Dec. 19, where President Trump underscored his administration’s commitment to addressing serious mental illness in the United States.

Shawn Coughlin, NABH’s executive vice president for government relations and public policy, and Scott Dziengelski, director of policy and regulation, attended the summit, where attendees heard from HHS Secretary Alex Azar and SAMHSA Assistant Secretary Ellie McCance-Katz moderated a panel discussion with mental health advocates about the need for reform.

NABH also submitted questions, and part of the discussion centered on Medicaid’s Institution for Mental Diseases (IMD) exclusion.

NABH Calls on Congress to Examine Insurers and Parity Following GAO Report 

NABH this week called on Congress to hold oversight hearings to examine whether the nation’s insurers are complying with parity following the release of a Government Accountability Office (GAO) report on Dec. 13.

The GAO’s 67-page report evaluated the practices, policies, and guidance from the U.S. Health and Human Services (HHS) and the U.S. Labor Department (DOL), the two federal offices that oversee compliance with the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008.

In its review, GAO found that both HHS and DOL “conduct targeted reviews of certain employer-sponsored group plans when they receive information—such as consumer complaints—about possible noncompliance with MH/SU parity requirements or other federal healthcare requirements.”

Consequently, NABH is urging federal lawmakers to hold congressional hearings early in the New Year to study the issue and learn more.

“For years, NABH has heard from our members—who receive complaints from patients and withstand parity violations every day—that the current compliance process is woefully inadequate to determine whether health plans are following the law,” NABH’s Shawn Coughlin said in a news release. “This is unacceptable.”

CMS Releases Informational Bulletin on Dual Eligibles Receiving OTP Services 

The Centers for Medicare & Medicaid Services (CMS) this week released an Informational Bulletin that provides guidance on coverage for Medicare and Medicaid dual-eligible beneficiaries who receive opioid treatment program (OTP) services.

Revisions to the Physician Fee Schedule (CY 2020) allow for a new OTP bundled payment benefit under Medicare, which replaces Medicaid as the primary payer for OTP services for the dual-eligible population. The new benefit is effective January 1, 2020; however, not all OTP providers will have completed Medicare enrollment by that time.

To assure continuity of patient care, states must pay OTP claims for Medicaid state plan covered services for Medicaid enrolled providers while Medicare enrollments are being completed. The new guidance from CMS provides information to state Medicaid agencies about strategies for continuing to pay for OTP services, including continuing to pay for claims for a specified period, and advising OTPs to submit claims only after their Medicare enrollment has been approved.

CMS recommends that states communicate with Medicaid managed care plans that cover OTP benefits, as well as with providers to advise them to enroll in Medicare.

Federal Survey Shows Adolescent Marijuana Vaping Surged in 2019

The latest Monitoring the Future survey showed that increases in adolescent marijuana vaping from 2018 to 2019 ranked among the largest single-year increases the survey has observed in the past 45 years among all outcomes measured.

In 2019, the percentage of adolescents who had vaped in the last 12 months was 21% in 12^th grade, 19% in 10^th grade, and 7% in 8^th grade.

Nicotine vaping also increased, as the survey showed 35% of 12^th graders reported vaping nicotine in the last 12 months, an increase of 5.6 points from 2018. Similarly, 31% of 10^th graders reported vaping nicotine in the last year, reflecting an increase of 6.1 percentage points from 2018.

Also this week, SAMHSA released Substance Misuse Prevention for Young Adults, a guide to help healthcare providers, systems, and communities prevent substance misuse among young adults.

CMS Announces $50 Million in Funding to 10 States for Maternal Opioid Misuse Model

CMS on Thursday said 10 states will receive a total of $50 million over five years funding under the Maternal Opioid Misuse, or MOM, model to help pregnant and postpartum Medicaid beneficiaries with opioid use disorder.

Colorado, Indiana, Louisiana, Maine, Maryland, Missouri, New Hampshire, Tennessee, Texas, and West Virginia were granted the awards, which they will use to transition into the model of care and then implement their plans.

Click here to learn more.

New JAMA Study Shows Most Opioid Deaths Are Accidental; 4% Are Suicide

Accidental overdoses cause 90% of all U.S. opioid-related deaths while suicides account for 4% of all opioid-related deaths, according to a new study published in JAMA this week.

In 2017, opioid-related deaths totaled about 47,500 and included 43,000 accidental deaths and 1,880 suicides. The cause of about 2,590 deaths could not be determined.

Government researchers analyzed death certificates for people aged 15 and older, and the findings contrast with a 2018 article in the New England Journal of Medicine that estimated—based on emergency department data—that at least 20% to 30% of those deaths had been suicides.

Understanding that most overdoses are accidental “puts the primary focus of care more squarely on the patient’s addiction,” although physicians should still evaluate their mental health, too, Dr. Mark Olfson, a psychiatrist at Columbia University and co-author of the study, told the Associated Press in a story about the analysis.

Please Update Your NABH Member Information Today!

NABH is preparing the association’s 2020 Membership Directory and asks all members to provide the most up-to-date information on their organizations.

To help ensure we have the most accurate data on our members, please contact Emily Wilkins, NABH’s administrative coordinator, at emily@nabh.org for a personalized link to enter information about your organization’s facilities.

The deadline to submit your information to NABH is Thursday, Jan. 9.

Register Today for the 2020 NABH Annual Meeting!

This week NABH sent members and Annual Meeting attendees the first in a series of weekly alerts about the 2020 Annual Meeting.

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance, learn about our speakers, and to register for the meeting. Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020.
 
NABH will post the Annual Meeting’s online preliminary program in January. We look forward to seeing you in Washington!

Fact of the Week

Among U.S. 12^th graders, the prevalence of marijuana vaping increased 7.7 percentage points in 2019, reflecting the second largest increase in 12-month substance use ever recorded in this grade.

Happy Holidays from NABH!

NABH will not publish CEO Update for the next two weeks and will resume on Friday, Jan. 10. The entire NABH team wishes you and your families a very happy holiday season!
 
For questions or comments about this CEO Update, please contact Jessica Zigmond.

FCC Chairman Proposes ‘988’ for National Suicide Prevention Hotline

Federal Communications Commission Chairman (FCC) Ajit Pai this week proposed rulemaking to establish 988 as a new, nationwide, three-digit phone number for a suicide prevention and mental health hotline.

“The suicide rate in the United States is at its highest level since World War II and designating 988 as the suicide prevention and mental health hotline would be a major boost for our nation’s suicide prevention efforts,” Pai said at an event with federal agency partners on Nov. 19. “When it comes to saving lives, time is of the essence, and we believe that 988 can be activated more quickly than other possible three-digit codes,” he said, adding that 988 also “has an echo of the 911 number” that is universally recognized as an emergency number.

In early June, NABH sent a letter to the FCC asking the agency to immediately repurpose a nationwide, three-digit phone number for suicide prevention.

The Commission will vote on Pai’s proposal at its public meeting on Thursday, Dec. 12.

National Action Alliance for Suicide Prevention Releases ‘Best Practices in Care Transitions’

The National Action Alliance for Suicide Prevention has released Best Practices in Care Transitions for Individuals with Suicide Risk: Inpatient Care to Outpatient Care, a 25-page report intended to help health systems and providers close gaps in care, improve patient experience and outcomes, and prevent suicide deaths.

Research shows that in the month after patients leave inpatient psychiatric care, their suicide death rate is 300 times higher in the first week and 200 times higher in the first month than in the general population, but nearly a third of these patients do not make it to outpatient care in this timeframe.

The report aims to advance two goals of the Action Alliance’s National Strategy for Suicide Prevention: promote suicide prevention as a core component of healthcare, and promote and implement effective clinical and professional practices for assessing and treating those identified as being at risk for suicidal behaviors.

Milliman Disparities Report Highlights Need for NABH’s Access to Care Initiative

A report this week from Milliman, Inc. about disparities between physical and behavioral healthcare for both in-network access and provider reimbursement rates underscores NABH’s position that unnecessary barriers continue to deny access to behavioral healthcare for patients who need it.

The Bowman Family Foundation commissioned Milliman to produce Addiction and Mental Health vs. Physical Health: Widening disparities in network use and provider reimbursement, a 140-page report that shows the gap in disparities for employees and their families seeking mental health and addiction treatment versus treatment for physical health conditions widened in 2016 and 2017.

According to the report, inpatient out-of-network use for behavioral health was over five times more likely than for medical/surgical services, worsening from 2.8 times more likely in 2013 to 5.2 times more likely in 2017, reflecting an 85% increase in disparities over five years. Meanwhile, office visit disparities were already five times higher in 2013 and worsened to 5.4 times in 2017, the report said.

In news releases from both Milliman and NABH, Mark Covall said the report’s findings emphasize what NABH members have said for years: unfair managed care practices too often create barriers for patients to access the care they need. Earlier this year, NABH launched its Access to Care initiative to inform policymakers, the media, patient advocates, and the general public about two major challenges—unjust managed care practices and countless regulations—that prevent behavioral healthcare providers from providing a full range of services to patients.

CMS Announces Reorganization to Improve Regional Office Functions and Structure

The Centers for Medicare & Medicaid Services (CMS) this week announced a host of changes to its regional office structure as part of the agency’s earlier-announced Modernizing CMS Strategic Initiative.

Among the changes is a plan to bring together staff, regardless of their location, who work on quality improvement and who survey facility quality and safety as a way to ensure consistency. Another program change will combine the regionally based Medicare operations work, the local oversight of the federally facilitated exchange plans, and external affairs into a single office that reports directly to the Office of the Administrator by creating the Office of Program Operations and Local Engagement, or OPLE.

CMS also said it will position the Medicaid program to better serve stakeholders by creating centers of excellence.

The announcement will be published in the Federal Register on Monday, Nov. 25.

SAMHSA to Host Webinar on National Agenda for Behavioral Health in Youth Next Week

The Substance Abuse and Mental Health Services Administration (SAMHSA) will host a webinar titled Fostering Healthy Mental, Emotional, and Behavioral Health in Children and Youth: A National Agenda next Tuesday, Nov. 26 at 6 p.m. ET.

The webinar will provide an overview of the newly released National Academies of Sciences, Engineering, and Medicine’s consensus report on this topic and will feature contributors to the report. They will recommend how to leverage the research to create a national agenda where children and youth thrive. The previous report on this topic was released 10 years ago.

Click here to learn more about the webinar and here to register.

SAMHSA Applications for Community Services Program Grant Due Dec. 23

SAMHSA is accepting applications for its Recovery Community Services Program to provide peer recovery support services through recovery community organizations to individuals with substance use disorders or co-occurring substance use and mental health disorders.

The agency said it plans to issue six grants of up to $300,000 per year for up to five years. Applications are due by Monday, Dec. 23. Click here to learn more and to register.

Register Today for the 2020 NABH Annual Meeting!

Please visit NABH’s Annual Meeting homepage today to view the Schedule At-a-Glance, learn about our speakers, and to register for the meeting.

Also please be sure to make your hotel reservation at the Mandarin Oriental Washington, DC from March 16-18, 2020. We look forward to seeing you next March!

Fact of the Week

In 2017, a child’s out-of-network office visit for behavioral healthcare was 10.1 times more likely than for an out-of-network primary care office visit, which was more than twice the disparity seen for adults.

Happy Thanksgiving from NABH!

NABH’s office will be closed next Thursday, Nov. 28 and Friday, Nov. 29 for Thanksgiving.  CEO Update will resume on Friday, Dec. 6. The NABH staff wishes its members and their families a very happy Thanksgiving!

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