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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:


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:

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:

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.




Behavioral health is complex. Untreated behavioral health conditions, including both mental health and substance use disorders, have a significant impact on individuals, families, friends, and employers. Individuals with mental health conditions and/or substance use disorders need access to evidence-based services - the care that, based on scientific research, has been shown to...


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January 31, 2018 SAMHSA Listening Session: Oral Comments on Behalf of ABHW and the Partnership to Amend 42 CFR Part 2.

October 26, 2017 ABHW Statement On The Trump Administration's Opioid Announcement.

October 20, 2017 Statement of Pamela Greenberg, MPP, President and CEO, Association for Behavioral Health and Wellness, Before the President’s Commission on Combating Drug Addiction and the Opioid Crisis.

October 18, 2017 Media Alert – Congressional Briefing, Using Health IT to Combat the Opioid Crisis.

October 16, 2017 ABHW Letter of Support on the Partnership to Amend 42 CFR Part 2.

October 13, 2017 Association for Behavioral Health and Wellness CEO to Speak at White House Opioid Crisis Commission Meeting.

October 12, 2017 ABHW CEO to Chair Payer Behavioral Health Conference in Washington, DC.

September 26, 2017 Health Care Coalition Lauds Manchin and Capito’s “Legacy Act”.

September 26, 2017 ABHW Applauds Senators Manchin and Capito’s “Legacy Act” in Honor of Jessie Grubb.

September 22, 2017 Graham-Cassidy Health Care Bill is Unacceptable.

September 12, 2017 FAQ About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 38.

September 8, 2017 Media Alert – ABHW is pleased to present a briefing on the role of U.S.behavioral health plans in addressing the opioid epidemic.

August 10, 2017 Insurer Industry Group Commends President’s Declaration of National Emergency Over Opioid Epidemic.

August 1, 2017 ABHW Supports Steps Taken by White House Commission on Opioids.

July 28, 2017 42 CFR Part 2 Coalition Applauds Bipartisan Bill to Strengthen Addiction Treatment.

July 28, 2017 ABHW Applauds Congressman Murphy’s Bipartisan Bill to Strengthen Addiction Treatment.

July 27, 2017 ABHW Comments to the Opioid Commission.

July 27, 2017 ABHW Written Comments for HHS Listening Session on Strategies for Improving Parity for Mental Health and Substance Use Disorder Coverage.

July 12, 2017 ABHW President and CEO to Speak at 2017 Government Health Care Congress.

June 26, 2017 ABHW Letter in Support of the Nomination of Elinore F. McCance-Katz, MD, PhD, for Assistant Secretary for Mental Health and Substance Use.

May 23, 2017 ABHW Letter to Chairman Hatch on Health Care Reform Process in the Senate.

May 4, 2017 Press Release: ABHW Issues Statement in Wake of House Passage of AHCA.

May 2, 2017 ABHW Letter to House Leadership on AHCA and MacArthur Amendment.

April 26, 2017 Press Release: ABHW to Chair Inaugural Payer-Provider Behavioral Health Management Summit.

April 25, 2017 Press Release: ABHW Recommends Improvements to Medicare Advantage Program.

March 30, 2017 Press Release: ABHW Welcomes White House Commission on Opioids.

March 23, 2017 ABHW Letter to House Leadership Over AHCA Concerns.

March 22, 2017 ABHW Letter to House Leadership on ACHA.

March 17, 2017 ABHW Press Release on Confirmation of New HHS Secretary Price and CMS Administrator Verma.

March 10, 2017 ABHW Comments to Rep Murphy.

March 8, 2017 ABHW Comment Letter on Market Stabilization Prop Rule.

February 17, 2017 ABHW Press Release on SNPRM Part 2 Comment Letter.

February 17, 2017 ABHW SNPRM Comment Letter to SAMHSA on Confidentiality.

February 1, 2017 ABHW Summary of 42 CFR Part 2 Final Rule and SNPRM.



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