ABHW COMMENTS ON ADDICTION AS CHRONIC DISEASE

Recommendations to HHS Focus on High-Quality Care

WASHINGTON, D.C. – The Association for Behavioral Health and Wellness (ABHW) has provided recommendations to the U.S. Department of Health and Human Services (HHS) in response to the Department’s Request for Comment on the Chronic Disease of Addiction.

In comments submitted to Secretary Robert F. Kennedy, Jr., on July 2, 2026, ABHW shared its concerns that the state of behavioral health in America remains a national crisis, with one in five Americans experiencing a mental health (MH) condition, and one in six experiencing a substance use disorder (SUD), each year. The Association’s recommendations focus on ensuring that individuals receive high-quality care that produces measurable improvements in health, functioning, and long-term recovery.

“We appreciate HHS for recognizing substance use disorder and mental health as chronic diseases and for seeking stakeholder input through this Request for Information,” said Debbie Witchey, MHA, President and CEO of ABHW. “The Administration has an important opportunity to strengthen federal policies that expand access to evidence-based prevention, treatment, and recovery services while advancing the research needed to better understand addiction and improve long-term outcomes.”

An Evidence Basis for High-Quality Care and Improved Outcomes

ABHW encourages prioritizing evidence-based treatment, recovery-oriented systems of care, workforce modernization, quality measurement, and accountability for treatment outcomes. While expanding access remains critically important, federal policy should increasingly focus on ensuring that individuals receive high-quality care that produces measurable improvements in health, functioning, and long-term recovery.  Some of these high-quality treatments include expanding access to evidence-based substance use disorder (SUD) medications such as medications for opioid use disorder and medications for alcohol use disorder. Further, ABHW supports expanding use of the Collaborative Care Model for MH and SUD treatment.

Other ABHW recommendations:

  • Expanded access to evidence-based medications to treat SUD
  • Safe harbors for contingency management programs
  • Expanded integration of behavioral and physical health care
  • Preservation of telehealth flexibilities
  • Stronger quality standards and accountability for SUD treatment providers and residential SUD treatment
  • Establishing a core set of behavioral health outcome measures
  • Advanced data interoperability

Additionally, ABHW believes that increased federal investment in research is needed to better understand the behavioral health impacts of gambling addiction and screen time and to guide evidence-based prevention, treatment, and recovery efforts.

“As HHS considers policies to address behavioral health conditions, it is critical to prioritize evidence-based treatment, recovery-oriented systems of care, workforce modernization, quality measurement, and accountability for treatment outcomes,” said Witchey. “Expanding access to care remains essential, but we also need to ensure that individuals receive high-quality treatment that leads to measurable improvements in health, daily functioning, and long-term recovery.”

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ABOUT THE ASSOCIATION FOR BEHAVIORAL HEALTH AND WELLNESS

ABHW is the leading health plan association working to improve access and quality of care for mental health and substance use disorders. ABHW’s members include national and regional health plans who care for approximately 200 million people. Together, we work to reduce stigma and advance federal policy on mental health and substance use disorder care. ABHW member companies include Aetna Behavioral Health, Elevance Health, Centene Corporation, Evernorth, a Cigna company, Health Care Service Corporation, Kaiser Permanente, Lucet, Magellan Health, Molina Healthcare, Optum, and PerformCare, a subsidiary of AmeriHealth Caritas. To learn more, visit www.abhw.org and follow us on BlueSky and LinkedIn.

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