ABHW 2014 Public Policy Agenda
ABHW has developed its 2014 public policy agenda, consisting of topics of importance to its member companies. These issues include:
- Behavioral Health Information Technology
- 42 CFR Part 2
- Affordable Care Act Implementation
- Mental Health Parity and Addiction Equity Act Implementation
Fewer than half of behavioral health providers possess fully implemented Behavioral Health Information Technology in the form of Electronic Health Record (EHR) systems. When Congress passed the HITECH Act in 2009, it left out behavioral health providers. On average, IT spending in behavioral health organizations represents 1.8% of total operation budgets – compared with 3.5% of total operating budgets for general health care services. ABHW member companies try to coordinate behavioral health care with an individual’s medical care and use clinical outcomes to help measure the effectiveness of the consumer’s treatment. EHRs help facilitate integrated/coordinated care, enhance e-prescribing, and track clinical outcomes. These benefits are lost if behavioral health providers are behind on EHR implementation. We are supportive of the following legislation that has been introduced in the U.S. Senate and House of Representatives to extend health information technology assistance eligibility to more mental health and substance use disorder professionals and facilities:
- S. 1517, the Behavioral Health Information Technology Act, which would authorize behavioral and mental health professionals, substance abuse professionals, psychiatric hospitals, certain community mental health centers, and residential or outpatient mental health or substance abuse treatment facilities to qualify for financial incentives for meaningful use of EHRs.
- S. 1685, the Behavioral Health Information Technology Coordination Act, which would authorize psychiatric hospitals, community mental health centers, clinical psychologists, and substance use treatment providers to qualify for financial incentives for meaningful use of EHRs. This legislation includes a budget offset.
Telehealth has been proven to drive important advancements for our patients, but the fact that each state has its own eligibility guidelines and licensure requirements prevents Medicare and Medicaid recipients from obtaining the care they need. At least 40 states provide Medicaid reimbursement for telehealth. Medicare reimburses for telehealth at the same rate as a face-to-face visit and reimburses a set amount per session for the staff person presenting with the patient, but it imposes major restrictions on the use of telehealth. These restrictions are geography-based, facility-based, and procedure-based. Telehealth has the ability to reach a broader range of behavioral health consumers, including children and adolescents who appreciate the use of technology when communicating with their behavioral health care providers, and patients who reside in areas where there is a shortage of behavioral health providers. It also helps provide access to elderly patients who may have difficulty leaving their homes to travel to an appointment. Reforming the barriers above would improve access to and quality of care for people with behavioral health needs. Related legislation we are following and for which we are advocating include:
- H.R. 3306, the Telehealth Enhancement Act, which would change the definition of an “originating site”, attempting to break down geographic and facility barriers to Medicare patients.
- H.R. 3077, the TELE-MED Act, which would permit certain Medicare providers licensed in one state to provide telehealth services to Medicare beneficiaries in a different state.
- H.R. 3750, the Telehealth Modernization Act, which would promote the provision of telehealth by establishing a federal standard for telehealth.
42 CFR Part 2 (Part 2) protects client-identifying information that would reveal a client as an alcohol or drug client, either directly or indirectly. Part 2 was created after Congress recognized that the stigma associated with substance use disorders and the fear of prosecution deterred people from entering treatment. While a laudable goal, these special protections create barriers to integration of behavioral and physical health, such as: inhibiting electronic exchange of health information, reducing the effectiveness of clinical reports to physicians, and delaying data transmission to providers. Individuals with substance use disorders will often go to different providers so that they can obtain multiple prescriptions for medications to which they are addicted; without access to a patient’s record, this behavior is hard to detect and treat. We seek the alignment of Part 2 with the HIPAA privacy rule to allow transmission of Part 2 data without written authorization for treatment, payment, and operations purposes.
ABHW is advocating for Affordable Care Act policies and regulations that reflect the needs of the behavioral health community and specialty behavioral health organizations. We are working to identify opportunities to improve quality and access by addressing provider shortage issues in a variety of ways, including the use of peer service providers and telehealth. ABHW member companies provide behavioral health coverage to enrollees in Medicaid expansion, Health Insurance Marketplaces, and duals demonstrations. ABHW works with its member companies to ensure that behavioral health issues are appropriately addressed in these different programs.
We have also been an active supporter of mental health parity since the early 1990s. In 2014 we will be assisting our member companies in interpreting the Mental Health Parity and Addiction Equity Act (MHPAEA) final rule, addressing the implementation issues associated with the final rule, and seeking further clarification and consistent federal and state implementation.
HEALTHCARE INTEGRATION IN THE ERA OF THE AFFORDABLE CARE ACT
Changes are occurring across the healthcare landscape, with a significant focus on integration of behavioral and physical health. This paper is intended to help inform these efforts by focusing on the long history Association for Behavioral Health and Wellness...[More]
ABHW Press Release to House Leadership Over AHCA Concerns (March 23, 2017)
ABHW Comment Letter to House Leadership on ACHA (March 22, 2017)
ABHW Press Release on Confirmation of New HHS Secretary Price and CMS Administrator Verma (March 17, 2017)
ABHW Comment Letter to Rep Murphy (March 10, 2017)
ABHW Comment Letter on Market Stabilization Prop Rule (March 8, 2017)
ABHW Press Release on SNPRM Part 2 Comment Letter (February 17, 2017)
ABHW SNPRM Comment Letter to SAMHSA on Confidentiality (February 17, 2017)
ABHW Summary of 42 CFR Part 2 Final Rule and SNPRM (February 1, 2017)
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)
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