Alignment for Progress: A National Strategy for Mental Health and Substance Use Disorders
It’s time for a meaningful national conversation about mental health and substance use care. We must remove the barriers to equitable and available coverage for these conditions so people can get the help they need.
Welcome To The National Strategy
Want to understand more about the importance of building a National Strategy for Mental Health & Substance Use Disorders?
How Content Is Organized and How Best to Search/Sort the Recommendations
The National Strategy recommendations are organized by category, with impacted populations and topical areas providing additional nuance and the ability to narrow a search. We have also included the option to search recommendations by the relevant House and Senate committees of jurisdiction.
Recommendation Selection Methodologies and Criteria
After conducting a thorough review of the federal policy landscape, The Kennedy Forum team created this first-of-its-kind compilation of policy recommendations needed to transform our mental health and substance use systems. The recommendations have been sourced and vetted from numerous organizations, advocates, and experts across the country in order to capture a robust set of recommendations for lawmakers and federal agencies to act on.
All National Strategy Recommendations
These featured recommendations are highlighted based on their importance in beginning the national movement towards better care for everyone.
Limit use of restrictive housing
The Department of Justice (DOJ) should establish policies to ensure the limited use of restrictive housing. Restrictive housing should never be implemented for incarcerated individuals with mental health and substance use disorders (MH/SUD).[1]
Restrictive housing, which includes solitary confinement, separates an incarcerated person from all forms of contact with others. For the increasing number of incarcerated people with a mental health or substance use disorder (MH/SUD), restrictive housing is deeply harmful and can lead to the deterioration of individuals’ conditions.[2] According to the Department of Justice (DOJ), 29 percent of incarcerated people in prisons and 22 percent in jails with symptoms of serious psychological distress have been subjected to restrictive housing.[3] There is also an increased risk of suicide or self-injury for incarcerated people placed in restrictive housing, regardless of whether the individual previously had an MH/SUD.[4] Spending time in restrictive housing is likely to result in anxiety, anger, sleep issues, and disorientation.[4] To mitigate increased risks, policies around restrictive housing need to be reevaluated and updated.[1]
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Extend the National Health Service Corps
Congress should amend 42 U.S.C. § 254e(a)(2) to extend and fund the National Health Service Corps (NHSC) to include Veterans’ Health Administration facilities and clinics by explicitly including those facilities and clinics under the definition of the term “medical facility.” [1][2]
The National Health Service Corps (NHSC) includes medical, dental, and mental health and substance use disorder (MH/SUD) providers who receive scholarships or loan repayment assistance in return for providing services within communities at eligible facilities in Health Professional Shortage Areas (HPSAs).[3][4][5] Currently, any clinic that provides care to Veterans or active military personnel is ineligible for NHSC support, even if the facilities are in a HPSA.[5] Over 456,000 active military and 5.2 million Veterans have experienced a mental MH/SUD).[6][7] Many face major barriers to care[8], including a shortage of health professionals at Veterans Health Administration (VHA) facilities and a lack of crisis intervention services.[9][10] To improve access to MH/SUD treatment for military personnel, VHA facilities and clinics should be included as a “medical facility” for the NHSC loan repayment programs.[1][2]
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Incentivize CCBHCs and FQHCs to encourage care integration
Congress should incentivize Certified Community Behavioral Health Clinics (CCBHCs) and Federally Qualified Health Centers (FQHCs) to strengthen mental health and substance use disorder (MH/SUD) and primary care integration through a voluntary integration bonus payment.[1] FQHCs and CCBHCs should be allowed to same-day bill to encourage integration.[2][3]
Formal, fully integrated partnerships between FQHCs and CCBHCs can empower both physical and MH/SUD providers to deliver a more comprehensive range of services and improve care delivery.[1][4] CCBHCs were first deployed by the Department of Health and Human Services (HHS) as a demonstration program in eight states to improve access to MH/SUD care at the community level, and have since been expanded to over 46 states and U.S. territories with over $120 million in funding made available.[5][6]
In 2016, HHS created a voluntary quality bonus payment for CCBHCs that meet certain state-determined performance requirements and federally required performance objectives.[8] However, these requirements do not reflect integration and do not apply to FQHCs, removing incentives for FQHCs to pursue integration.[1] Congress should encourage formal partnerships and increased integration between CCBHCs and FQHCs through a voluntary integration bonus program. Additionally, to further improve integration, FQHCs and CCBHCs should be allowed to bill for both physical and MH/SUD services on the same day, which is referred to as same-day billing.[7] Several explicit Medicaid policies prohibit billing for MH/SUD and physical health services on the same day.[7] Congress should amend rules to allow same-day billing for MH/SUD and physical health services to empower providers to increase care integration.
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Levy excise taxes on plans violating the federal parity law
The U.S. Department of Treasury should exercise its existing authority under 26 U.S.C. § 4980D to levy excise taxes on health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA).[1]
MHPAEA requires equity in coverage between mental health and substance use disorder (MH/SUDs) and medical/surgical benefits.[2][3] When passed in 2008, the MHPAEA applied only to group health plans and group health insurance.[2][3] However, in 2010, the Affordable Care Act amended the law to include the individual health insurance market.[2][3] While the MHPAEA has significantly improved access to MH/SUD coverage for millions of Americans, the Department of Labor, in coordination with state regulators, has uncovered numerous health plans in violation of MHPAEA.[4] Everyone deserves equal coverage of mental health and addiction treatment services, and the Department of Treasury’s failure to use its existing authority has weakened the ability to enforce the law.[5] It should utilize its existing authority to levy taxes on plans in violation of the MHPAEA.[1][3]
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Encourage the use of the P-COAT alternative payment model
The Centers for Medicare and Medicaid Services (CMS) should encourage the use of the Patient-centered Opioid Addiction Treatment (P-COAT) alternative payment model, which is designed to improve outcomes and reduce spending for opioid addiction by using three bundled payments: 1) Patient Assessment and Treatment Planning bundle; 2) Initiation of Medication-Assisted Treatment (MAT) bundle; and 3) Maintenance of MAT bundle.[1]
Medications for Opioid Use Disorder (MOUD), particularly when coupled with therapy and support services (collectively often referred to Medication-Assisted Treatment, or MAT) has been effective in treating opioid use disorder (OUD), but cost can be a barrier to accessing treatment.[2][3] Siloed healthcare can also be a barrier for people to obtain the treatment they need. Patients with OUD who are not treated effectively with MAT can add billions of collars in costs to the healthcare system (e.g. increased frequency of emergency department visits and preventable hospital admissions.[4] Medicare is currently the only insurance that offers a bundled payment option for opioid treatment programs (OTP) that helps coordinate and connect care for patients with OUD.[5] The Patient-centered Opioid Addiction Treatment (P-COAT) payment model is designed to improve treatment outcomes with coordinated care, control costs, and ensure appropriate reimbursement rates through bundled payments.[4] There are three bundles, including Patient Assessment and Treatment Planning, Initiation of MAT, and Maintenance of MAT. Each is a payment focused on the different components of OUD treatment covering evaluation and diagnosis, initial outpatient MAT and support services, and ongoing treatment.[6] P-COAT should be used as alternative payment model for OUD treatment to enhance care coordination, improve health outcomes, and lower costs. [1]
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Fund the Residential Substance Abuse Treatment program
Congress should increase appropriations for the Residential Substance Abuse Treatment (RSAT) program established by 34 U.S.C. § 10421 and amend 34 U.S.C. § 10422 so grant awards are contingent upon the use of medication-assisted treatment (MAT).[1]
The Residential Substance Abuse Treatment (RSAT) program includes grants to state, local and tribal prisons and jails to provide mental health and substance use disorder (MH/SUD) treatment and resources to incarcerated adults and youth.[2] To receive funding, grant recipients must provide aftercare services to individuals who participate in MH/SUD treatment and services while incarcerated.[3] These services include education, job training, and peer, self-help, and half-way house programs.[4] The “Residential Substance Use Disorder Treatment Act,” as introduced in the 118th Congress, expands residential SUD treatment programs under RSAT to include the use of medication-assisted treatment (MAT).[5] In addition to aftercare services, eligibility for grants made through the RSAT program should be contingent upon the use of MAT.[1][6]