Substance use disorders (SUD) and overdose deaths remain a serious public health concern: prevalence rates, particularly opioids and fentanyl, and the provisional data on drug overdose deaths continue to climb. These statistics underscore the importance of prevention and treatment for individuals with SUD in the United States. Additionally, these alarming trends emphasize the crucial role of policy-making in tackling these complex issues.
As we kick-off 2024, there are encouraging policy development that are pivotal in addressing these challenges. Notably, one initiative focuses on promoting Medications for Opioid Use Disorder (MOUD) in Federally Qualified Health Centers (FQHCs). Another involves updates to Opioid Treatment Program (OTP) standards and regulations, and lastly, significant changes are being implemented in the Medicare program aimed at addiction treatment.
Last November, the Centers for Medicare & Medicaid Services (CMS) published the final rules for the Physician Fee Schedule (PFS) and Outpatient Prospective Payment System (OPPS) for Calendar Year (CY) 2024. These rules introduced new coverage options designed to significantly impact the treatment of SUD, particularly opioid use disorder (OUD), potentially improving outcomes and accessibility of care.
FIVE KEY MEDICARE RULE CHANGES:
1. Accessible Providers: The inclusion of marriage and family therapists (MFTs) and mental health counselors (MHCs) has the potential to bring approximately 200,000 new counselors into the system. This expansion will help increase access to qualified professionals for SUD and mental health treatment.
2. Telehealth Services: The permanent extension of some telehealth policies for mental health and OUD treatment will continue to make treatment more accessible, especially for those who face difficulties in accessing in-person services. The ability to receive video or audio-based treatment in homes and other locations, previously limited to designated facilities, is a significant step towards expanding access to care.
3. Intensive Outpatient Services (IOP): Medicare will now cover IOP services, which will address a significant gap in the continuum of SUD treatment, offering a middle ground between inpatient hospitalization and less intensive outpatient programs. The availability of IOP in settings like hospital outpatient departments, community mental health centers, and opioid treatment programs, marks an important expansion of comprehensive care options.
4. Rates and Billing Flexibilities: The increase in reimbursement rates, including psychotherapy codes and office-based SUD treatment codes, acknowledges the importance of appropriately valuing mental health and SUD services. Billing flexibilities and the creation of new codes are projected to increase the number of providers willing to deliver crisis services and address issues of access and availability of these services.
5. Social Determinants of Health: There are new service codes for peer support specialists and community health workers designed to address social determinants of health (SDOH). These new service codes, namely community health integration (CHI) and principal illness navigation (PIN), will enable practitioners to collaborate with community-based organizations employing peers and community health workers. This is a step towards integrating broader social support and health-related social needs into direct patient care.
The other two initiatives also represent a paradigm shift in how we address OUD. The Center for Health Care Strategies (CHCS) released in January a report: Opportunities to Promote Medications for Opioid Use Disorder in Federally Qualified Health Centers, focused on enhancing the use of medication-assisted treatment (MAT) for opioid use disorder (OUD) in Federally Qualified Health Centers (FQHCs). The report emphasizes the importance of integrating MAT into primary care settings to improve access and outcomes for individuals with OUD. This approach would further enhance access to treatment and reduce the stigma often associated with OUD treatment. By implementing MAT, FQHCs can offer comprehensive care that includes both medication and psychological support, greatly enhancing treatment efficacy. The report highlights various strategies and best practices for implementing MAT in FQHCs, including workforce development, policy support, and collaborative care models.
In February, Substance Abuse and Mental Health Services Administration (SAMHSA), published the final revisions to the federal regulations that address opioid use disorder (OUD) treatment standards, as well as opioid treatment program (OTP) accreditation and certification standards. The Medications for the Treatment of Opioid Use Disorder final rule is a game-changer in the field of OUD treatment, including making certain flexibilities permanent post-COVID-19 and expanding access to care and evidence-based treatment for OUD. The rule also removes specific language and rules pertaining to the Drug Addiction and Treatment Act (DATA) Waiver, aligned with recent legislative changes. These final rules mean a more adaptable, person-centered approach to OUD treatment, ensuring that more individuals can receive the help they need in a manner that suits their specific circumstances.
These changes, in addition to some of the other recent trends I wrote about last month: Revolutionizing Healthcare: The Future of Integrated Care for All, represent a significant shift at the policy level in how we approach behavioral health and SUD treatment, emphasizing increased access, flexibility, and a more integrated, holistic approach to care. These represent steps in the right direction in better addressing the challenges posed by the opioid crisis and the heightened need for increased access to behavioral health supports, services and treatment. All these new initiatives should serve as a beacon of hope in our continued efforts to address the mental health and opioid crises, offering more effective, compassionate, and comprehensive strategies.
RESOURCES:
ASAM (www.asam.org)
CMS (www.cms.gov)
The National Law Review (www.natlawreview.com)
The Pew Charitable Trusts (www.pewtrusts.org)
Commonwealth Fund (www.commonwealthfund.org)
National Institute on Drug Abuse (NIDA) continues to monitor the prevalence and trends of drug use in the United States, providing valuable insights into the evolving landscape of substance use and its consequences. Their resources cover a range of topics, including drug use trends, emergency room data, prevention and treatment programs, and research findings.
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