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ABHW Archives

Comment Letters

  • March 18, 2025 ABHW Response to the Special Registration for Telemedicine and Limited State Telemedicine Registrations Proposed Rule; Docket No. DEA-407.
  • January 27, 2025 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) Medicare Program; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications (MAPD) Notice of Proposed Rulemaking (NPRM or Proposed Rule).
  • January 10, 2025 ABHW Submits a Letter to the Trump Administration Transition Team Regarding Behavioral Health Policies.
  • January 10, 2025 ABHW Comments on the Mental Health Parity and Addiction Equity Act (MHPAEA) Final Rule in a Letter to the Departments of Labor, Health and Human Services, and Treasury.
  • December 19, 2024 ABHW Submits Legislative Priorities and Recommendations for Passage Before the End of This Congress.
  • December 2, 2024 ABHW Comments on the Centers for Medicare and Medicaid Services (CMS), Center for Medicaid and CHIP Services (CMCS) Request for Comments (RFC) on Templates for Documenting Compliance with Mental Health Parity and Addiction Equity Act Requirements in Medicaid and CHIP (Compliance Tools or Templates).
  • September 27, 2024 Request to the Centers for Medicare & Medicaid Services (CMS), Center for Medicaid and CHIP Services (CMCS) to Extend the Comment Period Provided for the Recently Released Request for Comments on Templates for Documenting Compliance with Mental Health Parity and Addiction Equity Act (MHPAEA) Requirements in Medicaid and the Children’s Health Insurance Program (CHIP).
  • September 9, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rulemaking (NPRM or proposed rule) for the Medicare and Medicaid Programs: Calendar Year 2025 Payment Policies Under the Physician Fee Schedule (CY25 PFS or PFS) and Other Changes to Part B Payment and Coverage Policies.
  • September 9, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rulemaking (NPRM or proposed rule) for the Calendar Year 2025 (CY 25) Medicare Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems (OPPS).
  • May 29, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) Request for Information (RFI) on Medicare Advantage (MA) Data.
  • March 1, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services Advance Notice of Methodological Changes for Calendar Year 2025 for Medicare Advantage Capitation Rates and Part C and Part D Payment Policies (Advance Notice).
  • January 8, 2024 ABHW Comments on the U.S. Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) Notice of Proposed Rulemaking (NPRM) on the Notice of Benefit and Payment Parameters for 2025 (NBPP).
  • January 5, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) Medicare Program; Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications (MAPD) Notice of Proposed Rulemaking (NPRM or Proposed Rule).
  • January 2, 2024 ABHW Comments on the Centers for Medicare & Medicaid Services (CMS) 2025 Draft Letter to Issuers in the Federally-facilitated Exchanges (2025 Draft Letter).December 4, 2023 ABHW Comments on the Centers for Medicare and Medicaid Services (CMS), Center for Medicaid and CHIP Services (CMCS) Request for Comments on Processes for Assessing Compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) in Medicaid and CHIP.
  • December 4, 2023 ABHW Comments on the Centers for Medicare and Medicaid Services (CMS), Center for Medicaid and CHIP Services (CMCS) Request for Comments on Processes for Assessing Compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) in Medicaid and CHIP.
  • October 17, 2023 ABHW Comments on Requirements Related to the Mental Health Parity and Addiction Equity Act RIN- 1210–AC11; RIN 1545 – BQ29; RIN 0938-AU-93.
  • October 17, 2023 ABHW Comments on Proposed Relevant Data Requirements for Nonquantitative Treatment Limitations (NQTLs) Related to Network Composition and Enforcement Safe Harbor for Group Health Plans and Health Insurance Issuers Subject to the Mental Health Parity and Addiction Equity Act.
  • September 11, 2023 ABHW Comments on the Centers for Medicare & Medicaid Services Notice of Proposed Rulemaking for the Medicare Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems Intensive Outpatient Program Provisions.
  • September 11, 2023 ABHW Comments on the Centers for Medicare & Medicaid Services Notice of Proposed Rulemaking for the Medicare and Medicaid Programs: Calendar Year 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies.
  • August 28, 2023 ABHW Responds to the National Institutes of Health (NIH) National Institute on Drug Abuse’s (NIDA) Request for Information on the Impact of Telehealth Initiation of Controlled Substances Under the COVID-19 Public Health Emergency (PHE).
  • August 23, 2023 ABHW Submits Comments on the Food and Drug Administration’s Draft Guidance on “Psychedelic Drugs: Considerations for Clinical Investigations.”
  • July 3, 2023 ABHW Comments on the Centers for Medicare & Medicaid Services Notice of Proposed Rulemaking for the Medicaid Program; Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality.
  • July 3, 2023 ABHW Comments on the Centers for Medicare & Medicaid Services Notice of Proposed Rulemaking for the Medicaid Program; Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality.
  • July 3, 2023 ABHW Comments on the Centers for Medicare & Medicaid Services Notice of Proposed Rulemaking for the Medicaid Program; Ensuring Access to Medicaid Services.
  • May 27, 2025 ABHW Comments on the Elimination of Anticompetitive Regulations in Behavioral Health; Docket No. ATR-2025-0001.
  • April 27, 2023 ABHW Comments on the Substance Abuse and Mental Health Services Administration DRAFT Strategic Plan.
  • March 31, 2023 ABHW Submits Comments on the Drug Enforcement Administration Notice of Proposed Rule Making on the Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have Not Had a Prior In-Person Medical Evaluation (NPRM or Proposed Rule).
  • March 31, 2023 ABHW Submits Comments on the DEA NPRM on Introduction of Buprenorphine Via Telemedicine Encounter Proposed Rule.
  • March 6, 2023 ABHW Submits Comments on the Advance Notice of Methodological Changes for Calendar Year (C.Y.) 2024 for Medicare Advantage (M.A.) Capitation Rates and Part C and Part D Payment Policies.
  • February 14, 2023 ABHW Submits Comments on HHS and SAMHSA’s NPRM for Medications for the Treatment of Opioid Use Disorder at Outpatient Treatment Programs (OTP) Waiver Requirements.
  • February 13, 2023 HHS/ SAMHSA Released the Supplemental Notice of Proposed Rulemaking for the Medications for the Treatment of Opioid Use Disorder: Removal of the DATA-2000.
  • February 13, 2023 ABHW Submits Comments on the Notice of Proposed Rulemaking for the Centers for Medicare & Medicaid Services (CMS) Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications (MAPD).
  • January 31, 2023 2023 ABHW Submits Comments on the Notice for Proposed Rulemaking for the Confidentiality of SUD Patient Records.
  • January 31, 2023 ABHW Submits Comments on the HHS/ CMS Request For Information on Essential Health Benefits.
  • January 30, 2023 ABHW Submits Comments on the HHS Notice of Benefit and Payment Parameters for 2024.
  • January 6, 2023 ABHW Responds to the CMS Request for Information on the National Directory of Healthcare Providers and Services. 
  • November 1, 2019 ABHW Comments on the Committee on Energy and Commerce RFI on Substance Use Disorder Treatment.
  • October 31, 2019 ABHW Comments on the Office of National Drug Control Policy’s (ONDCP’s) 2020 National Drug Control Strategy.
  • October 25, 2019 ABHW Comments on Confidentiality of Substance Use Disorder Patient Records Proposed Rule (SAMHSA 4162-20).
  • October 25, 2019 Health Care Coalition Submits Comments to Modernize SUD Treatment Privacy Law and Enhance Coordinated Care and Safety.
  • October 11, 2019 ABHW Comments on CMS’ Request for Information for the Development of a CMS Action Plan to Prevent Opioid Addiction and Enhance Access to Medication-Assisted Treatment (RFI).
  • September 27, 2019 ABHW Comments on CMS’s Proposed Rule for Revisions to Payment Policies Under the Medicare Physician Fee Schedule (PFS) and Other Changes to Part B Payment Policies. 
  • August 26, 2019 ABHW Comments on the Request for Information: Ensuring Patient Access and Effective Drug Enforcement (RFI).
  • August 12, 2019 ABHW Comments on the Request for Information: Reducing Administrative Burden to Put Patients over Paperwork (RFI). 
  • June 5, 2019 Partnership to Amend 42 CFR Part Comment Letter to Senate HELP Committee’s Lower Health Care Costs Act of 2019.
  • May 31, 2019 ABHW Submits Comment Letter on MHPAEA Draft Model Disclosure Request Form.
  • May 14, 2019 ABHW Letter of Support for H.R. 2439, the Opioid Workforce Act of 2019, to Increase Access to Treatment for Substance Use Disorders.
  • May 14, 2019 ABHW Letter of Support for H.R. 2431, the Mental Health Professional Workforce Shortage Loan Repayment Act of 2019.
  • May 14, 2019 ABHW Letter of Support for H.R. 2431, the Mental Health Professional Shortage Loan Repayment Act of 2019.
  • May 3, 2019 ABHW Submits Comments on the IRS’s Draft Model Disclosure Request Form.
  • April 12, 2019 ABHW Provides Feedback to SAMHSA’s Recovery Housing: Best Practices and Suggested Minimum Guidelines.
  • April 1, 2019 ABHW Comments to Congress in Response to Their Request for Information Regarding Comprehensive Telehealth Legislation.
  • March 1, 2019 Partnership to Amend 42 CFR Part 2 Letter to Chairman Alexander on Recommendations to Help Address America’s Rising Health Care Costs.
  • March 1, 2019 ABHW Comments on Medicare Call Letter 2020.
  • February 19, 2019 ABHW Comments on the Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2020 Proposed Rule.
  • February 8, 2019 Request for Information on Modifying HIPAA Rules to Improve Coordinated Care.
  • February 8, 2019 Request for Information on Modifying HIPAA Rules to Improve Coordinated Care.
  • January 28, 2019 ABHW Comments on Draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs.
  • January 28, 2019 Draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs.
  • January 14, 2019 ABHW Comments on the Medicaid Program; Medicaid and Children’s Health Insurance Plan (CHIP) Managed Care proposed rule (proposed rule).
  • November 16, 2018 42 CFR Part 2 Stakeholder Letter to HELP Committee.
  • September 17, 2018 Over 150 Organizations Urge Congress to Modernize Part 2 in Opioid Package.
  • September 10, 2018 ABHW Comments on the Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program (proposed rule).
  • August 8, 2018 ABHW Comments on the July 9th, 2018 Draft Mental Health Parity Guidance.
  • June 22, 2018 ABHW Submits Comments on the OMB Form to Request Documentation from an Employer-Sponsored Health Plan or an Insurer Concerning Treatment Limitations.
  • June 22, 2018 ABHW Submits Comments on the Tri-Department “Proposed FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39” and the “Revised Draft Mental Health Parity and Addiction Equity Act (MHPAEA) Disclosure Template.”
  • June 13, 2018 99 Organizations Call For House Passage Of Overdose Prevention and Patient Safety Act.
  • April 23, 2018 Partnership to Amend 42 CFR Part 2 Comment Letter to House E&C Committee on Opioid Package.
  • April 23, 2018 Partnership to Amend 42 CFR Part 2 Comment Letter to Senate HELP Committee on the Opioid Crisis Response Act of 2018, S.2680.
  • April 23, 2018 Senate Committee on Health, Education, Labor, and Pensions (HELP) taking a leadership role in combatting the opioid epidemic by introducing The Opioid Crisis Response Act of 2018 (S. 2680).
  • April 11, 2018 ABHW Letter of support for H.R. 3545, the Overdose Prevention and Patient Safety Act (OPPS Act).
  • April 11, 2018 ABHW Provides the Senate HELP Committee with Policy Considerations for Addressing the Opioid Crisis.
  • April 11, 2018 Partnership Opioid HELP Letter.
  • March 15, 2018 ABHW Responds to Ways and Means Committee RFI on Opioid Epidemic Solutions.
  • February 28, 2018 ABHW and Partnership to Amend 42 CFR Part 2 Written Comments to SAMHSA on 42 CFR Part 2.
  • February 21, 2018 ABHW Responds to Request by the Ranking Members for the House Committee on Ways and Means and the House Committee on Energy and Commerce Regarding Efforts to Address Opioid Epidemic.
  • February 16, 2018 ABHW Responds to the Senate Finance Committee’s Request for Policy Recommendations Related to Addressing the Opioid Epidemic.
  • January 31, 2018 SAMHSA Listening Session: 42 CFR Part 2 Oral Comments on Behalf of ABHW and the Partnership to Amend 42 CFR Part 2.
  • November 13, 2017 ABHW Express Support for the Bipartisan Health Care Stabilization Act of 2017.
  • October 26, 2017 Partnership to Amend 42 CFR Part 2 Supports New OPPS Act Lead Cosponsor.
  • October 20, 2017 Statement of Pamela Greenberg, MPP, President and CEO, Association for Behavioral Health and Wellness, Before the President’s Commission on Combating Drug Addiction and the Opioid Crisis.
  • October 16, 2017 Partnership to Amend 42 CFR Part 2 Letter of Support for The Protecting Jessica Grubb’s Legacy Act.
  • September 12, 2017 FAQ About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 38.
  • July 27, 2017 ABHW Comments to the Opioid Commission.
  • July 27, 2017 ABHW Written Comments for HHS Listening Session on Strategies for Improving Parity for Mental Health and Substance Use Disorder Coverage.
  • June 26, 2017 ABHW Letter in Support of the Nomination of Elinore F. McCance-Katz, MD, PhD, for Assistant Secretary for Mental Health and Substance Use.
  • June 23, 2017 ABHW Letter to Senate Leadership on the Better Care Reconciliation Act.
  • May 23, 2017 ABHW Letter to Chairman Hatch on Health Care Reform Process in the Senate.
  • May 3, 2017 The Partnership to Amend 42 CFR Part 2 Letter to President’s Opioid Commission.
  • May 2, 2017 ABHW Letter to House Leadership on AHCA and MacArthur Amendment.
  • April 21, 2017 ABHW Letter to the Centers for Medicare and Medicaid Services in response to their Request for Information.
  • March 22, 2017 ABHW Comment Letter to House Leadership on ACHA.
  • March 10, 2017 ABHW Comment Letter to Representative Murphy.
  • March 8, 2017 ABHW Comment Letter on Market Stabilization Proposed Rule.
  • February 17, 2017 ABHW SNPRM Comment Letter to SAMHSA on Confidentiality.
  • January 3, 2017 ABHW Comments to DOJ and HHS on the Mental Health Parity and Addiction Equity Act.
  • December 9, 2016 ABHW Letter to Senate Leadership thanking them for including mental health provisions in the 21st Century Cures Act.
  • December 9, 2016 ABHW Letter to House Leadership thanking them for including mental health provisions in the 21st Century Cures Act.

Health Care Reform

  • January 27, 2022 ABHW Comment on the Centers for Medicare and Medicaid Services’ (CMS) Proposed Notice of Benefit and Payment Parameters Rule for 2023 (Proposed Rule).
  • December 24, 2020 ABHW Comments on the Effective and Innovative Approaches/Best Practices in Health Care in Response to the COVID-19 Pandemic; Request for Information
  • April 12, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ (CMS) Request for Information Regarding Maternal and Infant Health Care in Rural Communities (RFI).
  • March 2, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ (CMS) Proposed Notice of Benefit and Payment Parameters Rule for 2021 (proposed rule). 
  • January 29, 2020 ABHW Comments on the Department of Health and Human Services’ MLR Proposed Rule and the Transparency Proposed Rule.
  • February 19, 2019 ABHW Comments on the Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2020 Proposed Rule.
  • June 23, 2017 ABHW Letter to Senate Leadership on the Better Care Reconciliation Act.
  • May 23, 2017 ABHW Letter to Chairman Hatch on Health Care Reform Process in the Senate.
  • May 2, 2017 ABHW Letter to House Leadership on AHCA and MacArthur Amendment.
  • March 22, 2017 ABHW Letter to House Leadership on ACHA.
  • March 10, 2017 ABHW Letter to Representative Murphy.
  • March 8, 2017 ABHW Comments on Market Stabilization Proposed Rule.
  • December 9, 2016 ABHW Letter to Senate Leadership thanking them for including mental health provisions in the 21st Century Cures Act.
  • December 9, 2016 ABHW Letter to House Leadership thanking them for including mental health provisions in the 21st Century Cures Act.

Medicare and Medicaid

  • December 6, 2022 ABHW Responds to CMS RFI: Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs.
  • October 21, 2022 ABHW Submits Comments to the Centers for Medicare & Medicaid Services (CMS) on the Proposed Rule on Mandatory Medicaid and CHIP Core Set Reporting.
  • September 13, 2022 Comments on the Centers for Medicare and Medicaid Services’ Proposed CY 2023 Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Organ Acquisition; Rural Emergency Hospitals: Payment Policies, Conditions of Participation, Provider Enrollment, Physician Self-Referral; New Service Category for Hospital Outpatient Department Prior Authorization Process; Overall Hospital Quality Star Rating.
  • September 6, 2022 ABHW Comments on the Centers for Medicare and Medicaid Services’ Proposed CY 2023 Physician Fee Schedule.
  • August 31, 2022 ABHW Comments on the Centers for Medicare and Medicaid Services’ Medicare Program Request for Information. 
  • July 27, 2022 ABHW Comment on the Centers for Medicare and Medicaid Services’ (CMS) Proposed Rule to Implement Certain Provisions of the Consolidated Appropriations Act of 2021 and Other Revisions to Medicare Enrollment and Eligibility Rules.
  • March 7, 2022 ABHW Comment on the Centers for Medicare and Medicaid Services’ Proposed Rule Related to CY 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefits Programs.
  • January 4, 2021 ABHW Comments on the Center for Medicare and Medicaid Services’ Proposed Rule Addressing Prior Authorization and Reducing Burden on Patients and Providers.
  • September 10, 2020 Leading Mental Health Organizations Applaud the Introduction of the PEERS ACT of 2020 to Allow Participation of Peer Support Specialists in Behavioral Health Integration Services in Medicare.
  • July 6, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ 1135 Waivers as well as the Second Interim Final Rule with Comment Period Regarding Additional Policy and Regulatory Revisions to Medicare and Medicaid in Response to the COVID-19 Public Health Emergency.
  • June 1, 2020 ABHW Comment on the Centers for Medicare and Medicaid Services’ (CMS) Interim Final Rule with Comment Period (IFC) Regarding the Policy and Regulatory Revisions to Medicare and Medicaid in Response the COVID-19 Public Health Emergency.
  • April 6, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ Contract Year 2021 and 2022 Medicare Advantage and Part D Proposed Rule. 
  • March 23, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ Request for Information for Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex Conditions (RFI).
  • September 27, 2019 ABHW Comments on CMS’s Proposed Rule for Revisions to Payment Policies Under the Medicare Physician Fee Schedule (PFS) and Other Changes to Part B Payment Policies. 
  • August 12, 2019 ABHW Comments on the Request for Information: Reducing Administrative Burden to Put Patients over Paperwork (RFI). 
  • March 1, 2019 ABHW Comments on Medicare Call Letter 2020.
  • January 14, 2019 ABHW Comments on the Medicaid Program; Medicaid and Children’s Health Insurance Plan (CHIP) Managed Care proposed rule (proposed rule).
  • December 20, 2018 ABHW Comments on the Medicare and Medicaid Programs; Policy and Technical Changes to the Medicare Advantage, Medicare Prescription Drug Benefit, Program of All-Inclusive Care for the Elderly (PACE), Medicaid Fee-for-Service, and Medicaid Managed Care Programs for Years 2020 and 2021 proposed rule (proposed rule).
  • December 17, 2018 ABHW Comments on comment on the Proposed Decision Memo for Vagus Nerve Stimulation (VNS) for Treatment Resistant Depression (TRD) (CAG-00313R2).
  • September 10, 2018 ABHW Comments on the Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program (proposed rule).
  • April 21, 2017 ABHW Letter to the Centers for Medicare and Medicaid Services in response to their Request for Information.
  • August 5, 2015 ABHW Paper on Healthcare Integration in the Era of the Affordable Care Act.
  • ABHW Letter to the Senate Finance and House Energy and Commerce Committees on the role that private sector managed care plans play in Medicaid (November 14, 2014)
  • ABHW Letter to the Senate Finance Committee in response to the Committee’s request for information from the mental health community on how to improve the mental health system in the United States (September 30, 2013)
  • Joint Paper: Preserve Specialty Behavioral Health Option for the Dual Eligible Population
  • ABHW Letter to Administrator Tavenner on Preliminary Medicare Advantage Payment Rates for 2016 (February 25, 2015)
  • ABHW Comment Letter on Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations (February 6, 2015)
  • ABHW Comment Letter on Advancing Telehealth Opportunities in Medicare (January 26, 2015)
  • ABHW Letter on Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2016 (December 22, 2014)
  • ABHW Comment Letter to CMS on criteria for Certified Community Behavioral Health Clinics (December 8, 2014)
  • ABHW Comment Letter to SAMHSA on criteria for Certified Community Behavioral Health Clinics (November 25, 2014)
  • ABHW Comment Letter to SAMHSA on changes needed to 42 CFR Part 2 (June 25, 2014)
  • ABHW Letter to House Energy and Commerce Health Subcommittee on telehealth and the advancement of technology in order to improve our nation’s health care system and help more patients (June 16, 2014)
  • ABHW Letter on H.R. 3717, the Helping Families in Mental Health Crisis Act (May 22, 2014)
  • ABHW Letter on H.R. 4574 the Strengthening Mental Health in Our Communities Act (May 22, 2014)
  • ABHW Comment Letter on the Amendments to Excepted Benefits proposed rule (February 24, 2014)
  • ABHW Letter to Administrator Tavenner on potential Medicare Advantage rate cuts (February 13, 2014)
  • ABHW Comment Letter on a draft report for the Agency for Healthcare Research and Quality, Therapies for Children with Autism Spectrum Disorder – Behavioral Interventions Update (February 11, 2014)
  • ABHW Response on Request for Information Regarding Health Care Quality for Exchanges (December 26, 2012)
  • ABHW Comment Letter on Patient Protection Affordable Care Act; Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation (December 26, 2012)
  • ABHW Comment Letter on the proposed rule for Patient Protection and Affordable Care Act; Data Collection to Support Standards Related to Essential Health Benefits; Recognition of Entities for the Accreditation of Qualified Health Plans (July 5, 2012)
  • ABHW Comment Letter on the Essential Health Benefits Bulletin (January 31, 2012)
  • ABHW Comment Letter on the Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes Under the Patient Protection and Affordable Care Act (September 21, 2010)
  • ABHW Comment Letter on the Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the Patient Protection and Affordable Care Act (August 16, 2010)
  • ABHW Comment Letter on SAMHSA’s draft document entitled “Description of a Modern Addictions and Mental Health Services System” (June 30, 2010)

Mental Health and Substance Use Disorders

  • October 31, 2022 ABHW Comments on Substance Abuse and Mental Health Services Administration’s (SAMHSA) Request for Information on Behavioral Health in the Context of Climate Change and Health Equity.
  • March 21, 2022 ABHW Comments on the Health Resources and Services Administration’s Request for Information Related to the Opioid Response Program Performance Measures in Rural Communities.
  • January 3, 2022 ABHW Comments on the Centers for Medicare and Medicaid Services’ (CMS) Interim Final Rule Related to Opioid Treatment Programs: CY 2022 Methadone Payment Exception (Interim Final Rule).
  • July 16, 2021 ABHW Comments on the Department of Treasury’s Coronavirus State and Local Recovery Funds interim final rule (IFR).
  • July 12, 2021 ABHW Comments on the Federal Communications Commission’s (FCC) Implementation of the National Suicide Hotline Improvement Act of 2018 further notice of proposed rulemaking
  • July 9, 2021 ABHW Comments on the Office of National Drug Control Policy’s (ONDCP) National Drug Control Strategy.
  • January 4, 2021 ABHW Comments on the Implementation of the SUPPORT Act of 2018: Dispensing and Administering Controlled Substances for Medication-Assisted Treatment.
  • December 21, 2020 ABHW Comments on the Federal Communications Commission’s Public Notice Related to Location Information for 9-8-8 Calls.
  • September 23, 2020 Mental Health Crisis Line: Why We Need 9-8-8.
  • April 22, 2020 ABHW Comments on the Drug Enforcement Administration’s proposed rule on Registration Requirements for Narcotic Treatment Programs with Mobile Components.
  • December 20, 2019 ABHW Comments on Cures 2.0 RFI. 
  • October 31, 2019 ABHW Comments on the Office of National Drug Control Policy’s (ONDCP’s) 2020 National Drug Control Strategy (Strategy).
  • October 11, 2019 ABHW Comments on CMS’ Request for Information for the Development of a CMS Action Plan to Prevent Opioid Addiction and Enhance Access to Medication-Assisted Treatment (RFI).
  • August 26, 2019 ABHW Comments on the Request for Information: Ensuring Patient Access and Effective Drug Enforcement (RFI).
  • June 5, 2019 Partnership to Amend 42 CFR Part Comment Letter to Senate HELP Committee’s Lower Health Care Costs Act of 2019
  • May 14, 2019 ABHW Letter of Support for H.R. 2439, the Opioid Workforce Act of 2019, to Increase Access to Treatment for Substance Use Disorders.
  • May 14, 2019 ABHW Letter of Support for H.R. 2431, the Mental Health Professional Workforce Shortage Loan Repayment Act of 2019.
  • April 12, 2019 ABHW Provides Feedback to SAMHSA’s Recovery Housing: Best Practices and Suggested Minimum Guidelines.
  • December 20, 2018 ABHW Comments on the Expanding the Use of Telehealth Services for the Treatment of Opioid Use Disorder under the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act Interim Final Rule and the Medicare Payment for Certain Services Furnished by Opioid Treatment Programs (OTPs) Request for Information.
  • April 23, 2018 Senate Committee on Health, Education, Labor, and Pensions (HELP) taking a leadership role in combatting the opioid epidemic by introducing The Opioid Crisis Response Act of 2018 (S. 2680).
  • April 11, 2018 ABHW Provides the Senate HELP Committee with Policy Considerations for Addressing the Opioid Crisis.
  • April 11, 2018 Partnership Opioid HELP Letter.
  • March 15, 2018 ABHW Responds to Ways and Means Committee RFI on Opioid Epidemic Solutions.
  • February 21, 2018 ABHW Responds to Request by the Ranking Members for the House Committee on Ways and Means and the House Committee on Energy and Commerce Regarding Efforts to Address Opioid Epidemic.
  • February 16, 2018 ABHW responds to the Senate Finance Committee’s request for policy recommendations related to addressing the opioid epidemic.
  • October 20, 2017 Statement of Pamela Greenberg, MPP, President and CEO, Association for Behavioral Health and Wellness, Before the President’s Commission on Combating Drug Addiction and the Opioid Crisis.
  • October 16, 2017 Partnership to Amend 42 CFR Part 2 Letter of Support for The Protecting Jessica Grubb’s Legacy Act.
  • July 27, 2017 ABHW Letter to President’s Opioid Commission.
  • May 3, 2017 The Partnership to Amend 42 CFR Part 2 Letter to President’s Opioid Commission.
  • May 2016 ABHW Paper on Behavioral Health Organizations Current and Future Approaches to Addressing the U.S. Opioid Crisis.
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Parity

  • August 22, 2022 ABHW Comments on Request for Notice of Medical Necessity Criteria Under the Mental Health Parity and Addiction Equity Act of 2008.
  • July 24, 2020 ABHW Comments on the U.S. Department of Labor’s Employee Benefits Security Administration Mental Health Parity and Addiction Equity Act Self-Compliance Tool.
  • May 3, 2019 ABHW Submits Comments on the IRS’s Draft Model Disclosure Request Form.
  • October 3, 2018 ABHW Mental Health and Substance Use Disorder Parity Declaration.
  • August 8, 2018 ABHW Comments on the July 9th, 2018 Draft Mental Health Parity Guidance.
  • June 22, 2018 ABHW Submits Comments on the OMB Form to Request Documentation from an Employer-Sponsored Health Plan or an Insurer Concerning Treatment Limitations.
  • June 22, 2018 ABHW Submits Comments on the Tri-Department “Proposed FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39” and the “Revised Draft Mental Health Parity and Addiction Equity Act (MHPAEA) Disclosure Template.”
  • September 12, 2017 FAQ About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 38.
  • July 27, 2017 ABHW Written Comments for HHS Listening Session on Strategies for Improving Parity for Mental Health and Substance Use Disorder Coverage.
  • September 9, 2016 An Examination of Federal Mental Health Parity Laws and Regulations.

Press Releases

  • November 5, 2019 ABHW Submits Comments to E&C Committee on SUD Treatments.
  • October 30, 2019 ABHW to Host 2ndAnnual Behavioral Health Policy Summit in Washington DC, November 6, 2019.
  • October 25, 2019 ABHW Seeks Additional Changes to Substance Use Disorder Confidentiality Rule. 
  • October 25, 2019 Health Care Coalition Submits Comments to Modernize SUD Treatment Privacy Law and Enhance Coordinated Care and Safety.
  • August 23, 2019 Health Care Coalition Commends Administration’s Actions to Modernize SUD Treatment Privacy Law and Enhance Coordinated Care and Safety.
  • July 17, 2019 ABHW Reveals New Brand with Redesigned Logo and Website.
  • May 9, 2019 ABHW Expands Advocacy Team with Key New Hires. 
  • April 4, 2019 ABHW Submits Comment Letter to MACPAC on IMD Study.
  • April 11, 2019 ABHW CEO to Keynote 16th Annual World Health Care Congress.
  • April 3, 2019 Partnership to Amend 42 CFR Part 2 Applauds Bipartisan Bills to Strengthen Addiction Treatment.
  • February 15, 2019 ABHW Year in Review 2018
  • February 14, 2019 Press Briefing: Efforts to Align Treatment of Substance Use Records with HIPAA Continue.
  • February 12, 2019 ABHW Submits Comments to Improve Coordinated Care Through HIPAA.
  • February 12, 2019 Health Care Coalition Submits HIPAA Rules Comments To Improve Coordinated Care.
  • January 28, 2019 Partnership to Amend 42 CFR Part 2 Comments on Reducing Regulatory and Administrative Burden Relating to Health IT and EHRs.
  • November 30, 2018 Partnership to Amend 42 CFR Part 2 Urges Congress to Act on 42 CFR Part 2 Reform in Light of New CDC Report.
  • October 3, 2018 ABHW Mental Health and Substance Use Disorder Parity Declaration.
  • October 1, 2018 ABHW to Chair Inaugural Behavioral Health Policy Summit in Washington DC, October 15, 2018.
  • September 26, 2018 Partnership to Amend 42 CFR Part 2 Disappointed in Omission of Enhanced Access and Privacy Provisions from Senate Opioid Package.
  • September 26, 2018 ABHW Pleased with Opioid Bill, Yet Concerns Remain Over Care Coordination and Confidentiality.
  • September 25, 2018 ABHW Announces Addition of New Member, Magellan Health.
  • September 17, 2018 Partnership to Amend 42 CFR Part 2 Disappointed in Exclusion of Privacy and Confidentiality Provisions from Senate Opioid Package.
  • September 17, 2018 ABHW Pleased with Passage of Opioid Legislation yet Disappointed in Exclusion of Enhanced Privacy Protections.
  • June 25, 2018 ABHW Submits Comments on Mental Health Parity.
  • June 20, 2018 Partnership to Amend 42 CFR Part 2 Passage of H.R. 6082 – The Overdose Prevention and Patient Safety Act.
  • June 20, 2018 ABHW Applauds Overwhelming Bipartisan Passage of H.R. 6082 – The Overdose Prevention and Patient Safety Act.
  • May 18, 2018 Partnership to Amend 42 CFR Part 2 Applauds Bipartisan Passage of H.R. 5795, The Overdose Prevention and Patient Safety Act.
  • May 18, 2018 ABHW President and CEO, Pamela Greenberg, to Speak at Congressional Briefing on Opioids.
  • May 17, 2018 ABHW Pleased Bipartisan Opioid Bill Passes Energy and Commerce Committee.
  • May 9, 2018 ABHW and AbleTo Release White Paper on the benefits of Telebehavioral Health Care.
  • April 24, 2018 ABHW Applauds HELP Committee Passage of The Opioid Crisis Response Act of 2018.
  • April 23, 2018 Stakeholders Urge Congress to Include Protections in Opioid Package.
  • April 11, 2018 Industry Groups Urge Senate HELP Committee to include Protections in Opioid Package.
  • April 5, 2018 Industry Group Applauds Senate HELP Committee on Opioid Package and Urges Inclusion of the Protecting Jessica Grubb’s Legacy Act.
  • March 15, 2018 ABHW Responds to Ways and Means Committee RFI on Opioid Epidemic Solutions.
  • March 1, 2018 ABHW President and CEO Set to Attend White House Opioid Summit.
  • February 22, 2018 ABHW Responds to Request for Information Regarding Efforts to Address Opioid Epidemic.
  • February 16, 2018 ABHW Floats Recommendations to Senate Finance Committee in Effort to Combat Opioid Epidemic.
  • January 30, 2018 Association for Behavioral Health and Wellness to Speak at SAMHSA Listening Session on 42 CFR Part 2.
  • January 24, 2018 ABHW Congratulates Azar on Confirmation as New HHS Secretary.
  • January 3, 2018 ABHW Statement on SAMHSA’s Final Rule on 42 CFR Part 2.
  • December 14, 2017 ABHW Statement on the Interdepartmental Serious Mental Illness Coordinating Committee Report.
  • November 6, 2017 Partnership to Amend 42 CFR Part 2 Supports New OPPS Act Lead Cosponsor.
  • November 3, 2017 ABHW Statement on The President’s Opioid Commission’s Final Report.
  • October 26, 2017 ABHW Statement On The Trump Administration’s Opioid Announcement.
  • October 18, 2017 Media Alert – Congressional Briefing, Using Health IT to Combat the Opioid Crisis.
  • October 13, 2017 Association for Behavioral Health and Wellness CEO to Speak at White House Opioid Crisis Commission Meeting.
  • October 12, 2017 ABHW CEO to Chair Payer Behavioral Health Conference in Washington, DC.
  • September 26, 2017 Health Care Coalition Lauds Manchin and Capito’s “Legacy Act”.
  • September 26, 2017 ABHW Applauds Senators Manchin and Capito’s “Legacy Act” in Honor of Jessie Grubb.
  • September 22, 2017 Graham-Cassidy Health Care Bill is Unacceptable.
  • September 8, 2017 Media Alert – ABHW is pleased to present a briefing on the role of U.S.behavioral health plans in addressing the opioid epidemic.
  • August 10, 2017 Insurer Industry Group Commends President’s Declaration of National Emergency Over Opioid Epidemic.
  • August 1, 2017 ABHW Supports Steps Taken by White House Commission on Opioids.
  • July 28, 2017 42 CFR Part 2 Coalition Applauds Bipartisan Bill to Strengthen Addiction Treatment.
  • July 28, 2017 ABHW Applauds Congressman Murphy’s Bipartisan Bill to Strengthen Addiction Treatment.
  • July 12, 2017 ABHW President and CEO to Speak at 2017 Government Health Care Congress.
  • June 23, 2017 ABHW Issues Statement on Senate Health Care Bill.
  • May 4, 2017 ABHW Issues Statement in Wake of House Passage of AHCA.
  • April 26, 2017 ABHW to Chair Inaugural Payer-Provider Behavioral Health Management Summit.
  • April 25, 2017 ABHW Recommends Improvements to Medicare Advantage Program.
  • March 30, 2017 ABHW Welcomes White House Commission on Opioids.
  • March 23, 2017 ABHW Sends Letter to House Leadership Over AHCA Concerns.
  • March 17, 2017 ABHW Comments on Confirmation of New HHS Secretary Price and CMS Administrator Verma.
  • February 17, 2017 ABHW Comments on SNPRM Part 2.
  • January 6, 2017 Tiffany Huth Joins ABHW as Director of Public Affairs.

Privacy and Confidentiality

  • May 6, 2021 Proposed Modifications to the HIPAA Privacy Rule to Support and Remove Barriers to Coordinated Care and Individual Engagement NPRM [RIN 0945-AA00].
  • April 28, 2020 Health Care Coalition Urges HHS to Issue Privacy and Confidentiality Rule.
  • March 2, 2020 The Partnership to Amend 42 CFR Part 2 Applauds Senators Capito and Manchin for the Reintroduction of the Protecting Jessica Grubb’s Legacy Act. 
  • October 25, 2019 ABHW Comments on Confidentiality of Substance Use Disorder Patient Records Proposed Rule (SAMHSA 4162-20).
  • October 25, 2019 Health Care Coalition Submits Comments to Modernize SUD Treatment Privacy Law and Enhance Coordinated Care and Safety.
  • March 1, 2019 Partnership to Amend 42 CFR Part 2 Letter to Chairman Alexander on Recommendations to Help Address America’s Rising Health Care Costs.
  • February 8, 2019 Request for Information on Modifying HIPAA Rules to Improve Coordinated Care.
  • February 8, 2019 Request for Information on Modifying HIPAA Rules to Improve Coordinated Care.
  • January 28, 2019 ABHW Comments on Draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs.
  • November 16, 2018 42 CFR Part 2 Stakeholder Letter to HELP Committee.
  • September 17, 2018 Over 150 Organizations Urge Congress to Modernize Part 2 in Opioid Package.
  • May 18, 2018 Health Care Coalition Applauds Bipartisan Passage of H.R. 5795, The Overdose Prevention and Patient Safety Act.
  • May 17, 2018 ABHW Pleased Bipartisan Opioid Bill Passes Energy and Commerce Committee.
  • April 23, 2018 Partnership to Amend 42 CFR Part 2 Comment Letter to House E&C Committee on Opioid Package.
  • April 23, 2018 Partnership to Amend 42 CFR Part 2 Comment Letter to Senate HELP Committee on the Opioid Crisis Response Act of 2018, S.2680.
  • April 11, 2018 ABHW Letter of support for H.R. 3545, the Overdose Prevention and Patient Safety Act (OPPS Act).
  • January 31, 2018 SAMHSA Listening Session: 42 CFR Part 2 Oral Comments on Behalf of ABHW and the Partnership to Amend 42 CFR Part 2.
  • October 26, 2017 Partnership to Amend 42 CFR Part 2 Supports New OPPS Act Lead Cosponsor.
  • July 28, 2017 The Partnership Letter of Support Murphy’s Bill.
  • May 3, 2017 The Partnership to Amend 42 CFR Part 2 Letter to President’s Opioid Commission.
  • February 17, 2017 ABHW SNPRM Comment Letter to SAMHSA on Confidentiality.
  • December 21, 2015 ABHW Paper on 42 CFR Part 2 – Now is the Time to Strengthen Protection of Substance Use Records by Revisiting the Substance Use Privacy Law.

Publications

  • ABHW Paper – Behavioral Health Organizations Current and Future Approaches to Addressing the U.S. Opioid Crisis (May 2016)
  • ABHW Comments on the notice of proposed rulemaking on Medication Assisted Treatment for Opioid Use Disorders (May 27, 2016)
  • ABHW and Diverse List of Health Care Stakeholders Letter to House Leadership calling attention to the importance of amending 42 CFR Part 2 (May 10, 2016)
  • ABHW Interview on 42 CFR Part 2 (April 27, 2016)
  • ABHW Editorial on 42 CFR Part 2 (April 11, 2016)
  • ABHW Press Release: ABHW and Diverse List of Health Care Stakeholders want HIPAA Standard to Apply to Substance Use Records (April 11, 2016)
  • ABHW and Diverse List of Health Care Stakeholders Comments: on the notice of proposed rulemaking on the Confidentiality of Substance Use Disorder Patient Records, 42 CFR Part 2 (April 11, 2016)
  • ABHW Comments: on the notice of proposed rulemaking on the Confidentiality of Substance Use Disorder Patient Records, 42 CFR Part 2 (April 11, 2016)
  • ABHW Press Release: ABHW Supports Changes to Outdated Substance Use Disorder Privacy Regulation (February 5, 2016)
  • ABHW Paper: on 42 CFR Part 2 – Now is the Time to Strengthen Protection of Substance Use Records by Revisiting the Substance Use Privacy Law (December 21, 2015)
  • ABHW Press Release: on 42 CFR Part 2 – All ABHW Wants for Christmas are Changes to the Substance Use Privacy Law (December 21, 2015)
  • ABHW Paper: on Healthcare Integration in the Era of the Affordable Care Act (August 5, 2015)
  • ABHW Press Release: ABHW Released Report Demonstrating Critical Role Managed Behavioral Healthcare Organizations Play in the Integration of Behavioral and Physical Health (August 5, 2015)
  • ABHW Press Release: on the Institute of Medicine (IOM) report on Psychosocial Interventions for Mental and Substance Use Disorders (July 14, 2015)
  • ABHW Comments on SAMHSA’s Peer Core Competencies: ABHW is pleased to see a comprehensive list of essential core competencies required by peer providers. (May 21, 2015)
  • ABHW Press Statement: ABHW Mourns Loss of Robin Williams (August 12, 2014)
  • Stamp Out Stigma highlighted in Behavioral Healthcare, MBHOs Launch Anti-Stigma Campaign for MI and SUD (May 22, 2014)
  • ABHW Press Release: ABHW Applauds Reps. Peters and Miller for Introducing National Mental Health No Stigma Week Resolution (May 14, 2014)
  • ABHW Press Release: ABHW Launches Stamp Out Stigma Campaign to Reach 1 Million People in 2014 (April 2, 2014)
  • Final Parity Rule Provides New Guidance for ABHW Members – The Association for Behavioral Health and Wellness (ABHW) issued the following statement today in response to the release of the final Mental Health Parity and Addiction Equity Act (MHPAEA) regulations this morning. (November 8, 2013)
  • ABHW letter to the Senate Finance Committee in response to the Committee’s request for information from the mental health community on how to improve the mental health system in the United States (September 30, 2013)
  • ABHW Press Release: ABHW President and CEO Participates in Historic White House Conference on Mental Health, Applauds National Dialogue (June 3, 2013)
  • ABHW Article in Behavioral Healthcare, ABHW endorses effectiveness of peers and peer support services – MBHO group suggests action to expand the use of peers in behavioral health treatment nationwide (March 28, 2013)
  • ABHW Statement on Health Care Cost Institute report, The Impact of the Mental Health Parity and Addiction Equity Act on Inpatient Admissions (February 27, 2013)
  • ABHW Report on Peer Support Services. A Valuable Component of Behavioral Healthcare (January 28, 2013)
  • ABHW Response on Request for Information Regarding Health Care Quality for Exchanges (December 26, 2012)
  • ABHW Comment Letter on Patient Protection Affordable Care Act; Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation (December 26, 2012)
  • Mental Health Weekly article on ABHW Support for Million Hearts Campaign (August 6, 2012)
  • Joint Paper: Preserve Specialty Behavioral Health Option for the Dual Eligible Population(July 2012)

Telehealth

  • October 5, 2020 ABHW Comments on the Centers for Medicare and Medicaid Services’ (CMS) Electronic Prescribing of Controlled Substances (EPCS) Request for Information (RFI).
  • February 14, 2020 ABHW Comments on the Federal Communications Commission’s Implementation of the National Suicide Hotline Improvement Act of 2018.
  • April 1, 2019 ABHW Comments to Congress in Response to Their Request for Information Regarding Comprehensive Telehealth Legislation. 
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