Behavioral Health Update (for members of NAPHS & the American Hospital Association) - February 2018
NAPHS Release: Sarah A. Wattenberg Joins NAPHS as Director of Quality and Addiction Services
NAPHS Releases Policy Brief on IMD Exclusion
NAPHS Drafts Opioid Crisis White Paper
NAPHS release: "Jessica Zigmond Joins NAPHS as Director of Communications"
NAPHS release: "Scott Dziengelski Joins NAPHS as Director of Policy and Regulatory Affairs"
NAPHS release: "Julia E. Richardson Joins NAPHS as Director of Advocacy and Senior Counsel"
NAPHS release: "Rep. Tim Murphy (R-PA) Receives 'Mental Health Champion Award' from National Association of Psychiatric Health Systems"
NAPHS release: "Sen. Christopher Murphy (D-CT) Receives 'Mental Health Champion Award' from National Association of Psychiatric Health Systems"
NAPHS ad as seen in Politico and Roll Call titled "Helping Americans with mental and substance use conditions is important to overall health andto our economy. Congress agreed....Save lives, families, and communities with behavioral health."
HHS/SAMHSA final rule: "Confidentiality of Substance Use Disorder Patient Records"
HHS/SAMHSA proposed rule: "Confidentiality of Substance Use Disorder Patient Records"
Partnership to Amend 42 CFR Part 2 release: "SAMHSA Final Rule Well Intended, Falls Short; Coalition to Urge Congress to Take Next Steps"
NAPHS release: "Shawn Coughlin Joins NAPHS as Executive Vie President for Government Relations and Public Policy"
NAPHS comment letter to CMS regarding OPPS final rule with comment period ("Medicare Program: Hospital Outpatient Prospective Payment...Systems and Quality Reporting Programs;...etc."). Includes comments on 20-hour-per-week partial hospitalization requirement.
HHS/OIG final rule: "Medicare and State Health Care Programs: Fraud and Abuse; Revisions to the Safe Harbors Under the Anti-Kickback Statute and Civil Monetary Penalty Rules Regarding Beneficiary Inducements"
NAPHS statement on House passage (392-26) of mental health reform and addiction funding as part of the 21st Century Cures Act
U.S. Surgeon General Issues Landmark Report: "Facing Addiction in America: A Surgeon General’s Prevention Report on Alcohol, Drugs, and Health." See news release.
CMS final rule: "Medicare Program: Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY17..." (including Psychiatric Collaborative Care). Also see CMS news release and blog, 11.18.16 correction, and 12.29.16 correction.
CMS final rule with comment period: "Medicare Program: Hospital Outpatient Prospective Payment...Systems and Quality Reporting Programs;...etc." (NOTE: partial hospitalization section begins on p.79678). Also see CMS release and fact sheet.
PIC release: "Parity Implementation Coalition Applauds Release of White House Parity Task Force Recommendations"
Joint statement (43 organizations) on release of Mental Health and Substance Use Disorder Parity Task Force report
SAMHSA/HHS final rule: "Medication Assisted Treatment for Opioid Use Disorders Reporting Requirements"
NAPHS Briefing: "Just-published final rule modernizes TRICARE mental health benefits"
NAPHS comment letter on proposed rule on Hospital Outpatient Prospective Payment System (OPPS)
NAPHS statement: "Death of Longtime NAPHS Advocate Mike Bromberg Is a Loss for the Behavioral Health Field"
CMS proposed rule: "Medicare Program: Hospital Outpatient PPS and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs;....EHR Incentive Programs; Payment to Certain Off-Campus Outpatient Departments of a Provider; Hospital Value-Based Purchasing Program" (NOTE: partial hospitalization section begins on p.45667)
Comprehensive Addiction and Recovery Act, S.524, passes Senate and House; goes to President for signature. See a summary of key provisions. Becomes law (P.L.114-198) on 7.22.16.
HHS/ASPE Request for Information: "Opioid Analgesic Prescriber Education and Training Opportunities to Prevent Opioid Overdose and Opioid Use Disorder"
NAPHS statement: "NAPHS Applauds House Passage of Legislation to Address Nation's Mental Health Crisis; Urges Congress to Pass Comprehensive Reform Now"
CMS proposed rule: "Medicare & Medicaid: Hospital & Critical Access Hospital Changes to Promote Innovation, Flexibility, and Improvement in Patient Care" (proposed changes to Hospital CoPs)
NAPHS statement: "NAPHS Applauds House Energy and Commerce Committee's Markup of Legislation to Address Nation's Mental Health Crisis; Urges Congress to Pass Comprehensive Reform"
IMPORTANT UPDATE: CMS delays data-collection of 3 IPFQR measures (metabolic screening and 2 transition-of-care measures) until 1/1/17
Department of Labor/HHS fact sheet: "Warning Signs – Plan or Policy Non-Quantitative Treatment Limitations (NQTLs) that Require Additional Analysis to Determine Mental Health Parity Compliance"
NAPHS, AHA, FAH, NRI joint letter to CMS seeking a delay in implementation of two new IPFQR transition of care measures (#0647, #0648) and the Screening for Metabolic Disorders measure (not NQF-endorsed)
Labor Department final rule on overtime for executive, administrative, & professional employees. Also see "Time-Limited Non-Enforcement Policy,” FAQs on nonenforcement policy, and fact sheet on overtime in non-profit sector.
Medicare Learning Network Matters article (MM9522): "Clarification of Inpatient Psychiatric Facilities (IPF) Requirements for Certification, Recertification and Delayed/Lapsed Certification and Recertification"
CMS final rule (including a provision giving MCOs flexibiiity on IMD exclusion--p.27555-27563): "Medicaid & CHIP Programs; Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability." Also see CMS fact sheets, 7.20.16 correcting amendment, 1.3.17 correcting amendment, and 3.6.17 correcting amendment.
Parity Implementation Coalition release: "Parity Implementation Coalition Applauds Release of Clarifying Guidance on Plan Disclosure Requirements of the Federal Parity Law"
Departments of Labor, Treasury, and HHS: "FAQs about Affordable Care Act Implementation Part 31, Mental Health Parity Implementation...etc." (See Q8-Q11 on parity disclosure and more)
Medicare Learning Matters Special Edition Article (SE1607): "Enforcement of the Partial Hospitalization Program (PHP) 20 Hours per Week Billing Requirement". [Also see 7.7.16 suspension of July 1, 2016, implementation of code edits.]
CMS final rule: "Medicaid and Children’s Health Insurance Programs (CHIP): The Application of Mental Health Parity (MHPAEA) Requirements to Coverage Offered by Medicaid Managed Care Organizations, CHIP, and Alternative Benefit Plans." Also see a fact sheet, FAQs, and a CMS news release.
Joint Commission Sentinel Event Alert (#56): "Detecting and treating suicide ideation in all settings"
Department of Labor "Report to Congress: Improving Health Coverage for Mental Health and Substance Use Disorder Patients, Including Compliance with the Federal Mental Health and Substance Use Disorder Parity Provisions"
HHS/Labor/SAMHSA consumer pamphlet: "Parity of Mental Health and Substance Use Benefits with Other Benefits: Using Your Employer-Sponsored Health Plan to Cover Services."
Year-End Report for 2015: "Mental Health and Addiction Treatment in a New National Spotlight" by 2015 Board Chair Lisa Shea, M.D.
NAPHS release: "NAPHS Applauds Final Passage of Bipartisan Legislation To Extend and Expand the Medicaid Emergency Psychiatric Demonstration Project; Bill Next Goes to President for Signature." [NOTE: Signed into law 12.11.15 as P.L.114-97.]
House bill (H.R.3681) introduced to extend and expand the Medicaid Emergency Psychiatric Demonstration Project
NAPHS release: "NAPHS Applauds Passage of Senate Legislation (S.599) To Extend and Expand the Medicaid Emergency Psychiatric Demonstration Project"
NAPHS comment letter on proposed Medicare hospital outpatient PPS/partial hospitalization program (OPPS/PHP) rates for CY16
CMS final rule: "Medicare Program; Inpatient Psychiatric Facilities Prospective Payment System-Update for Fiscal Year Beginning October 1, 2015 (FY16)" (including IPF Quality Reporting measures)
NAPHS release: "NAPHS Applauds Introduction of Senate Legislation [the Mental Health Reform Act] to Address Nation’s Mental Health Crisis; Urges Congress to Pass Comprehensive Reform." See fact sheet from Sens. Murphy and Cassidy.
CMS Center for Medicaid and CHIP Services letter to state Medicaid directors: "Re: New Service Delivery Opportunities for Individuals with a Substance Use Disorder" (SMD #15-003)
NAPHS comment letter to CMS on IMD exclusion provision in proposed rule on "Medicaid & Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, etc."
NAPHS statement on Helping Families in Mental Health Crisis Act, H.R. 2646 ("NAPHS Commends Rep. Tim Murphy for Bipartisan Reintroduction of Legislation to Address the Nation’s Mental Health Emergency"), See fact sheet on bill.
NAPHS release: "President’s FY16 Budget Tackles Lingering Discrimination; NAPHS Applauds Proposal to Eliminate the Medicare 190-Day Lifetime Limit, Urges Action to Address Discrimination in Medicaid"
Parity Implementation Coalition news release: "Parity Implementation Coalition Seeks Federal Action on Parity in Response to 60 Minutes Report." Watch 60 Minutes.
CMS final rule on the Medicare outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY15.
NAPHS comment letter to CMS proposed rule on "Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers"
NAPHS release: "Millions of Disabled and Poor Americans Encounter Discrimination When They Face Mental or Addictive Disorders, Says NAPHS; NAPHS Applauds House Oversight Hearing on Challenges Facing Families in Mental Health Crisis."
NAPHS letter submitted to House Energy and Commerce Oversight Committee hearing on “Where Have All the Patients Gone? Examining the Psychiatric Bed Shortage.”
NAPHS release: “There is no health without mental health,”says NAPHS Board. Board urges Congress to 1) end discrimination; 2) fix gaps in the mental health and addiction treatment system; and 3) support health information technology funding.
NAPHS comment letter on "HIPAA Privacy Rule and the National Instant Criminal Background Check System (NICS)"
HHS guidance: "HIPAA Privacy Rule and Sharing Information Related to Mental Health" (including frequently asked questions)
NAPHS statement: "NAPHS Applauds Rep. Tim Murphy for Introduction of Comprehensive Mental Health Reform Legislation; Dialogue on Tough Challenges Will Help Advance Policy Changes"
CMS final rule on Medicare Hospital Outpatient Prospective Payment System (including CY14 partial hospitalization rates). See pages 75045-75054.
Order a recording of a special training call on "Reporting SUB-1 (Alcohol Use Screening) in the IPFQR." Also download materials (files are large; please allow time for each to open): 1) Joint Commission PowerPoint; 2) Michael Miller, M.D., PowerPoint; 3) Eric Goplerud PowerPoint; 4) SBIRT Mentor brochure. Also see 5) the Telligen IPFQR newsletter. After the training, please complete 6) an online evaluation.
Final rule on federal parity law (the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008)
Departments of Labor, HHS, and Treasury: "FAQS About ACA (Part XVII) and Parity Implementation"
HHS study: "Consistency of Large Employer and Group Health Plan Benefits with Requirements of the Paul Wellstone annd Pete Domenici Mental Health Parity and Addiction Equity Act"
CMS final rule: "Medicare Program: Conditions of Participation (CoPs) for Community Mental Health Centers"
Department of Defense final rule: "TRICARE; Removal of the Prohibition To Use Addictive Drugs in the Maintenance Treatment of Substance Dependence in TRICARE Beneficiaries"
Behavioral Health Information Technology Coalition (BHITC) comment letter responding to Senate Finance Committee open letter seeking input on how to improve the US mental health system
CMS final rules: "Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals...and FY2014 Rates; Quality Reporting Requirements for Specific Providers; ....etc." (See pages 50887-50901 for IPF quality reporting section.) Also see 7.30.14 correcting amendment.
Coalition for Whole Health (CWH): Toolkit for state-level advocates working on implementation and oversight of the Affordable Care Act’s (ACA’s) essential health benefits, parity, and network adequacy protections. See an overview of key issues and short guides for working with state legislatures and insurance commissioners.
CMS Notice: "Medicare Program; Inpatient Psychiatric Facilities Prospective Payment System - Update for Fiscal Year Beginning October 1, 2013 (FY 2014)."
Behavioral Health IT Coalition release: “Mental Health and Addiction Services Organizations Applaud Rep. Murphy & Rep. Barber for Introducing the Behavioral Health Information Technology Act” (H.R.2957)
CMS/HHS final rule: "Medicaid and Children’s Health Insurance Programs: Essential Health Benefits in Alternative Benefit Plans, Eligibility Notices, Fair Hearing and Appeal Processes, and Premiums and Cost Sharing; Exchanges: Eligibility and Enrollment"
NAPHS comment letter to CMS: "Medicare: ....Quality Reporting Requirements for Specific Providers (CMS-1599-P)"
CMCS-MMCO-CM Informational Bulletin: "Payment of Medicare Cost Sharing for Qualified Medicare Beneficiaries (QMBs)." Tells states that they “have a legal obligation to reimburse providers for any Medicare cost sharing due for QMBs according to the state’s CMS-approved Medicare cost-sharing payment methodology.”
NAPHS comment letter on HHS Notice of Proposed Rulemaking on “HIPAA and the National Instant Criminal Background Check System”
CMS issues informational bulletin on EPSDT.
Design Guide for the Built Environment of Behavioral Healthcare Facilities authors receive NAPHS Quality Award on 10th anniversary of the publication
Office of Personnel Management final rule establishing standards for the Multi-State Plan Program, which will offer at least two multi-state plans on each state insurance exchange.
HHS interim final rule: "ACA; Amendments to the HHS Notice of Benefit and Payment Parameters for 2014"
NAPHS White Paper: Responding to the Newtown Tragedy: A White Paper on Behavioral Health as a Partner in the Solution
HHS final rule on ACA "Health Insurance Market Rules; Rate Review."
Joint statement from NAMI and NAPHS on the Medicare 190-day lifetime limit. Presented to the House Ways & Means Health Subcommittee hearing "Examining Traditional Medicare's Benefit Design."
NAPHS comment letter to OIG on "Solicitation of New Safe Harbors and Special Fraud Alerts"
HHS final rule: Standards related to essential health benefits (published in 2.25.13 Federal Register)
Mental Health Liaison Group letter in support of Mental Health First Aid Act (S.153/H.R.274)
NAPHS statement on release of essential health benefits final rule
ASPE Research Brief: "Affordable Care Act will expand mental health and substance use disorder benefits and parity protections for 62 million Americans"
NAPHS letter in support of Mental Health First Aid Act (S.153 / H.R. 274)
NAPHS comment letter on Measure Applications Partnership Pre-Rulemaking Draft Report
HHS final rule: "Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules"
Mental Health Liaison Group (MHLG) letter to President Obama: Recommendations for "reducing violence and accessing effective mental health care"
NAPHS / NAMI ad to the President and Congress (as seen in Politico): "Thank you...for committing to fully implementing the Mental Health Parity and Addiction Equity Act this year."
NAPHS statement: "NAPHS applauds commitment by President Obama to issue final parity rules"
President Obama issues a plan to reduce gun violence and takes executive actions committing to (among other things) issuing a final parity rule, Medicaid guidance on parity, and guidance on essential health benefits and parity requirements within Affordable Care Act exchanges. Also see a letter to healthcare providers.
OIG Report: "Vulnerabilities in CMS's and Contractors' Activities To Detect and Deter Fraud in Community Mental Health Centers" (OEI-04-11-00101)
NAPHS letter to Vice President Biden on Newtown Task Force; NAPHS calls for a focus on coverage, access, and resources.
Coalition for Whole Health (CWH) comments on essential health benefits' proposed rule
NAPHS comment letter on essential health benefits proposed rule
Parity Implementation Coalition comment letter on essential health benefits proposed rule.
NAPHS ad as seen in Politico: "It's time to address the need for access to all levels of behavioral health care in a final parity rule."
NAPHS statement on the shooting tragedy in Sandy Hook, CT
CMS: Frequently Asked Questions on Exchanges, Market Reforms and Medicaid. Also see a letter from HHS Secretary Sebelius to governors outlining additional information to help guide their work implementing the Affordable Care Act.
SAMHSA final rule: Opioid Drugs in Maintenance and Detoxification Treatment of Opiate Addiction; Proposed Modification of Dispensing Restrictions for Buprenorphine and Buprenorphine Combination as Used in Approved Opioid Treatment Medications
Center for Medicaid & CHIP Services Informational Bulletin: "Coverage and Service Design Opportunities for Individuals with Mental Illness and Substance Use Disorders"
CMS' Center for Medicaid and CHIP Services Informational Bulletin (guidance on the mechanisms states may use to reimburse the cost of medical care for children residing in psychiatric hospitals or PRTFs)
HHS proposed rule on ACA "Standards Related to Essential Health Benefits, Actuarial Value, and Accreditation." EHBs include "mental health and substance use disorder services, including behavioral health treatment" as one of the 10 core essential health benefits. Also see HHS fact sheet.
CMS final rule with comment period: "CMS-1589-FC: Medicare: Hospital Outpatient Prospective Payment System..." (including CY13 partial hospitalization rates, pages 68404-68418).
Appendices and other details for CMS-1589-FC are also online
CMS final rule on quality reporting requirements for inpatient psychiatric facilities (see pages 53644-53680). [View]
ICD-10 compliance deadline delayed to October 1, 2014. See HHS news release. [View]
OIG report on "Questionable Billing by Community Mental Health Centers" [View]
HHS interim final rule: "Administrative simplification: Health care electronic funds transfers and remittance advice transactions" [View]
Mental Health Liaison Group (MHLG) ad on demonstration programs for dual-eligibles (as seen in Politico): "Living with mental and addictive disorders is hard enough...don't make it worse for us" [View]
CMS proposed rule on the Medicare outpatient prospective payment system/partial hospitalization program (OPPS/PHP) rates for CY13 [View]
CMS notice: "Disproportionate Share Hospital Allotments and Institutions for Mental Diseases Disproportionate Share Hospital Limits for FYs 2010, 2011, and Preliminary FY12 DSH Allotments and Limits " [View]
HHS final rule: "Patient Protection & Affordable Care Act: Data collection to define essential health benefits; Recognition of entities for the accreditation of Qualified Health Plans" [View]
Mental Health Liaison Group (MHLG) release: "Mental health groups raise concerns about the current structure of dual-eligible demonstrations." Also see a MHLG letter to the Senate Special Committee on Aging
Department of Labor: Updated "Self-compliance tool for Part 7 of ERISA: HIPAA and other healthcare-related provisions (including mental health parity)" [View]
Medicare Payment Advisory Commission (MedPAC) letter to CMS on dual-eligible demonstrations, recommending, among other things, limiting the demonstrations to only a few states [View]
NAPHS statement on introduction of H.R.6043, the Behavioral Health Information Technology Act of 2012 [View]
NAPHS comment letter to CMS on psychiatric inpatient quality reporting measures [View]
Mental Health Liaison Group letter to CMS on concerns related to dual-eligible demonstrations as they impact individuals with mental illness [View]
MedPAC chapter (Section 6) on specialty inpatient psychiatric facilities (from A Data Book: Health Care Spending and the Medicare Program) [View]
MedPAC Chapter 3 on dual eligibles (from A Data Book: Health care spending and the Medicare Program)
Kaiser Commission on Medicaid & the Uninsured: "Geographic Variation in Dual-Eligible Enrollment" (by state) [View]
CMS final decisions on the recommendations of the Hospital Outpatient Payment Panel on supervision levels for select services (also see 5/18/12 NAPHS comment letter) [View]
NAPHS comment letter on CMS' preliminary decisions on the recommendations of the Hospital Outpatient Panel on Supervision Levels for Select Services
CMS final rule: "Medicare and Medicaid Programs: Reform of Hospital and Critical Access Hospital Conditions of Participation" [View]
CMS final rule: "Medicare and Medicaid Programs: Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction" [View]
CMS proposed rule on psychiatric inpatient quality reporting measures. See pages 28105-28116 in "Medicare Program: Hospital Inpatient PPS for Acute Care Hospitals and Long-Term Care Hospital PPS and FY13 Rates; Hospitals' Resident Caps for Graduate Medical Education Payment Purposes; Quality Reporting Requirements for Specific Providers and for Ambulatory Surgical Centers" [View]
Department of Labor Employee Benefits Security Administration: Frequently Asked Questions: "Understanding Implementation of the Mental Health Parity and Addiction Equity Act of 2008" [View]
CMS final rule: "Medicare & Medicaid: Changes in Provider and Supplier Enrollment, Ordering and Referring, and Documentation Requirements; and Changes in Provider Agreements" (including use of NPI) [View]
HHS proposed rule: "Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets" [View]
HHS proposed rule: "Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets" [View]
NAPHS comment letter to CMS on EMTALA application to specialized capabilities hospitals [View]
HHS final rule (and interim final rule for some sections): "Affordable Care Act: establishment of exchanges and qualified health plans; exchange standards for employers" (also see 5.29.12 corrections)
CMS final rule (and interim final rule for some sections): "Medicaid Program: eligibility changes under the Affordable Care Act of 2010" [View]
NAPHS comment letter and position paper on dual-eligible demonstrations sent to CMS Medicare-Medicaid Coordination Office (in response to request for feedback on Massachusetts dual-eligible demonstration). [NOTE: Check periodically online to view additional state demonstrations as they become available for comment.]
CMS release: "Affordable Care Act Demonstration to Expand Access to Emergency Psychiatric Care; New Demonstration Program to Help States Improve the Quality of Care for Patients with Psychiatric Emergency." Also see additional information.
CMS final rule: "Medicaid Program: Review and Approval Process for Section 1115 Demonstrations" [View]
NAPHS comment letter to HHS OIG on "Solicitation of New Safe Harbors and Special Fraud Alerts" with recommendations on complimentary transportation [View]
HHS Frequently Asked Questions on essential health benefits under the Affordable Care Act [View]
CMS proposed rule: "Medicare Program: Reporting and Returning of Overpayments." Also see 2/14/12 CMS release: "Affordable Care Act Gives CMS New Authority To Recover Overpayments From Providers and Suppliers More Quickly"
Parity Implementation Coalition applauds new URAC parity standards [View]
CMS request for comments: "Medicare Program; EMTALA Applicability to Hospital Inpatients and Hospitals with Specialized Capabilities" [View]
NAPHS comment letter to HHS on "Essential Health Benefits Bulletin" [View]
HHS interim final rule: "Administrative Simplification: Adoption of Standards for Health Care Electronic Funds Transfer (EFTs) and Remittance Advice" [View]
HHS final notice: "Medicaid Program: Initial Core Set of Health Care Quality Measures for Medicaid Eligible Adults" [View]
NAPHS comment letter to CMS on proposed rule on "Reform of Hospital and Critical Access Hospital Conditions of Participation" [View]
HHS Essential Health Benefits Bulletin outlining proposal to give states flexibility in implementing essential health benefits. Comments are due 1/31/12. Also see an ASPE Research Brief on "Comparing Benefits in Small Group Products and State and Federal Employee Plans" and a fact sheet on individual market coverage.
GAO Letter Report: "Foster Children: HHS Guidance Could Help States Improve Oversight of Psychotropic Prescriptions" (GAO-12-201) [View]
CMS final rule on "Patient Protection & Affordable Care Act; Establishment of Consumer Operated and Oriented Plan (CO-OP) Program" [View]
CMS final rule on "Medical Loss Ratio Requirements Under the Patient Protection and Affordable Care Act." Also see interim final rule on "Medical Loss Ratio Rebate Requirements for Non-Federal Governmental Plans."
Frequently Asked Questions on the Medicaid RAC Program [View]
CMS notice: "Medicare Program; Advanced Payment Model" to test whether pre-paying a portion of future shared savings will increase participation or savings in the Medicare Shared Savings Program. Also see http://www.innovations.cms.gov/initiatives/aco/advance-payment/index.html for ongoing updates and deadlines.
NAPHS comment letter to CMS on proposed rule (with extension of comment period) on "Establishment of Exchanges and Qualified Health Plans"
FTC/DOJ final policy statement: "Statement of Antitrust Enforcement Policy Regarding ACOs Participating in the Medicare Shared Savings Program" [View]
Institute of Medicine (IOM) consensus report: Essential Health Benefits: Balancing Coverage and Cost [View]
CMS final rule: "Medicaid Program: Recovery Audit Contractors" [View]
CMS Integrated Care Resource Center to help states learn about best practices for delivering coordinated health care to Medicaid’s high-need, high-cost beneficiaries (including dual eligibles) [View]
NAPHS statement on introduction of H.R.2783, the Medicare Mental Health Inpatient Equity Act (to eliminate 190-day lifetime limit). Also see Mental Health Liaison Group letter of support for H.R.2783 (56 organizations).
Kaiser Family Foundation Policy Brief: "Proposed Models to Integrate Medicare and Medicaid Benefits for Dual Eligibles: A Look at the 15 State Design Contracts Funded by CMS" [View]
NAPHS comment letter: "Medicare and Medicaid Programs: Opportunities for Alignment Under Medicaid and Medicare" [View]
NAPHS comment letter to CMS: Medicare Shared Savings Program: Accountable Care Organizations (ACOs) [View]
Final notice: "Medicare and Medicaid: Approval of the Joint Commission for Deeming Authority for Psychiatric Hospitals" [View]
Summary of behavioral health provisions in The Patient Protection and Affordable Care Act (Public Laws 111-148, 111-152) [View]