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Members of NHCBHA’s Executive Committee and NHCBHA Executive Director Roland Lamy participated in Hill Day earlier in June, meeting with Senator Kelly Ayotte in her Washington DC office. NHCBHA presented these 6 issue areas for discussion with Sen. Ayotte and staff from NH’s other three Congressional offices.
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| 1. New US Department of Labor Regulation Updating the Fair Labor Standard Act’s Minimum Wage and Overtime Pay Protections
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| This new rule will impose significant financial and administrative burdens on NH’s non-profit CMHCs and could lead to staff layoffs and cuts in direct services provided to adults and children with serious mental illnesses.
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| 2. Workforce Investment
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| Access to tuition relief for clinicians, through enhanced loan repayment, scholarship and loan programs, would help increase the numbers of mental health professionals. The Health Professional Shortage Areas (HPSAs) designated by HRSA should be expanded to allow access to loan repayment, scholarship and loan programs for all NH counties.
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Senator Ayotte meets with representatives from the NH Community Behavioral Health Association during the National Council for Behavioral Health’s Hill Day in June 2016. Pictured starting from the left are Roland Lamy, Ex. Dir., NHCBHA; Suellen Griffin, Ex. Dir., West Central Behavioral Health; Senator Kelly Ayotte; Jay Couture, Ex. Dir., Seacoast Mental Health Center; Peter Evers, Ex. Dir., Riverbend Community Mental Health.
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| 3. Enhanced Nurse Practitioner Authority
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| Allowing APRNs to sign treatment plans will help CMHCs in areas where there are not enough psychiatrists on staff, which is most of NH. NHCBHA recommends that Congress change Medicare law to make coverage of nurse practitioner services consistent with coverage of physician services. With the crisis of opiate addiction and overdose deaths in NH, it would improve access to care, and likely save lives, if APRNs were given the ability to become certified to prescribe Suboxone for the Medically Assisted Treatment of Substance Use Disorders.
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| 4. Updating CMS Rules
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| The CMS requirement that a supervising physician is physically in the office suite for incident to services should be eliminated so that CMHC staff can provide care to patients within the purview of their scope of services. This requirement drives up the cost of care by requiring a physician’s presence when it is not necessary for the provision of care, and restricts access to care when providers are unable to staff in a manner that allows for physician presence during all incident to services provided by a CMHC.
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| 5. Certified Community Behavioral Health Clinics (CCBHC)
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| NHCBHA strongly supports the work of the National Council for Behavioral Health in seeking a new federal definition and standards for CCBHCs. These entities would receive reimbursement for the costs of providing services to individuals with mental health and substance use problems while meeting clearly defined national standards and oversight.
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| 6. Billing for Two Services on the Same Day
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CMS limits same-day billing for certain paired codes of services and practitioner types in behavioral health. This and other coding issues imposed by CMS rules result in administrative burdens and loss of Medicare reimbursements to CMHCs that are already struggling financially. The need to schedule services for complex cases across multiple days presents hardships to many of our consumers who struggle with transportation, given that NH does not have a statewide mass transit system.
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NHCBHA sincerely appreciates the time and attention Sen. Ayotte and the staffs of Sen. Shaheen, Rep. Guinta and Rep. Kuster gave to these issues on Hill Day, and we look forward to working with them to find practical and timely solutions. For more information on any of these issues, please contact us at (603) 225-6633 or info@helmsco.com.
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