Advocacy
Voice.
Integration of behavioral and physical health is critical to treat the whole person and enhance a practitioner’s ability to effectively prevent fragmentation between behavioral health and medical care, and improve overall quality of care.
The Association for Behavioral Health and Wellness member companies bring substantial expertise and valuable capabilities to the current focus on integration, including robust knowledge and experience with mental health and substance use disorders; a person-centered focus on recovery; strong informatics and data analytics; and familiarity with preventative and collaborative models of care.
ABHW supports policies and regulations to ensure member companies can continue to increase quality, manage costs, and promote wellness for the 200 million people served by our members. View our policy priorities.
ABHW member companies are employing innovative approaches and effective use of technology and clinical decision guidelines to ensure that patients receive the care they need when they need it, achieving better health outcomes while protecting the system from waste, fraud and abuse. Health plans are seeing to it that dollars invested in behavioral health care and substance use disorder are having an optimal impact on population health.
Telehealth and Health Information Technology (HIT)
Expanding access to telehealth services is a priority for ABHW and its member companies.
Telehealth services have been proven to drive important advancements for patients, expand access to care, improve health outcomes, reduce the inappropriate use of psychotropic medications, overcome the stigma barrier, and cut costs. Given that approximately 25 percent of the adult population in the United States is reported to have a mental illness, and the fact that there is a growing shortage of behavioral health providers to respond to this significant need for service, the expansion of telehealth is critical.
The rising opioid crisis in our country provides even more of a reason to grant appropriate access to mental health and substance use disorder treatment. Now more than ever, the U.S. government is looking to expand and improve access to telebehavioral health services. The CONNECT for Health Act is just one example of federal bills that ABHW advocates for that are intended to promote access to telehealth services to provide evidence-based quality health care to our most vulnerable citizens.
ABHW supports the use of telebehavioral health where appropriate and advocates for the lifting of barriers that prevent its advancement and use.
Mental Health and Substance Use Disorders
Our nation is in the midst of an unprecedented opioid epidemic.
More people died from drug overdoses in 2015 than in any year on record, and the majority of drug overdose deaths (more than 6 out of ten) involved an opioid. BHOs play an important role in access to and delivery of treatment for opioid dependence.
ABHW works with Congress, federal agencies, the President’s Commission on Combating Drug Addiction and the Opioid Crisis, and other organizations to enact and improve policies that with help address the opioid epidemic.
Privacy and Confidentiality
The Confidentiality of Alcohol and Drug Abuse Patient Records regulations, 42 CFR Part 2, was designed to facilitate health integration and information exchange within new health care models while continuing to protect the privacy and confidentiality of patients seeking treatment for substance use disorders.
ABHW members successfully advocated for aligning substance use disorder privacy protections with the Health Insurance Portability and Accountability Act (HIPAA) for treatment, payment, and health care operations in an effort to provide patients with safe, coordinated, and informed care.
ABHW is the founder and chair of the Partnership to Amend 42 CFR Part 2 (Partnership). The Partnership is a coalition of 50 organizations representing stakeholders from across the health care spectrum and successfully aligned Part 2 with the treatment, payment, and health care operations language in HIPAA to ensure appropriate access to patient information essential for providing whole-person care. Read more about the Partnership here.
Medicare and Medicaid
ABHW supports policies that ensure access to medically necessary, evidence-based behavioral treatment for the medicaid population.
Medicaid accounts for about 26 percent of behavioral health spending and is the largest source of funding for the country’s public mental health system. One in five individuals out of Medicaid’s nearly 70 million patients have a MH/SUD diagnosis. The Medicaid expansion program has provided coverage to persons with MH/SUD who might not otherwise had access to care; and it has led to significant increases in coverage and access to services, better care and state savings.
Parity
The Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) requires group health plans and insurers that offer mental health and substance use disorder benefits to provide coverage that is comparable to coverage for general medical and surgical care.
ABHW member companies have long believed that it is important for financial and treatment coverage in health insurance policies to be equal between behavioral and physical medical health care.
ABHW was a strong advocate for passage of MHPAEA and remains critically involved with its member companies and regulators in the implementation of this landmark legislation.
Health Care Reform
Behavioral health is an integral part of whole health and a critical part of the costs of the health care system.
In January 2017, approximately 1.8 million of the 21 million people covered under the Affordable Care Act (ACA) were receiving mental health (MH) services and subsidies; approximately 1.25 million people with serious mental disorders, and about 2.8 million Americans with a substance use disorder (SUD).
ABHW supports the following provisions that ensure persons with MH/SUD maintain comprehensive coverage for medically necessary services: 1) Continuing coverage, including comprehensive behavioral health benefits, for individuals currently eligible for Medicaid and Medicaid expansion; 2) Inclusion of MH/SUD as a covered benefit; and 3) Requiring financial and treatment limits to be comparable between behavioral and physical health.
Comment Letters
- May 27, 2025 ABHW Comments on the Elimination of Anticompetitive Regulations in Behavioral Health; Docket No. ATR-2025-0001.
- April 3, 2025 ABHW Comments on Potential Privacy Issues Involved in Georouting Text to 988 under the Federal Communications Commission’s (FCC) Implementation of the National Suicide Hotline Act of 2018, Third Further Notice of Proposed Rulemaking (FNPR).
- March 31, 2025 ABHW Comments on the Reauthorization of the Substance Use Disorder Prevention That Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act).
- March 21, 2025 ABHW Submits Comments to the Substance Abuse and Mental Health Services Administration (SAMHSA) on the Draft of the Mobile Crisis Team (MCT) Toolkit
- 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.