Joel E. Miller
Immediate Past Chair
National Coalition on Mental Health and Aging
April 2023
INTRODUCTION
The White House appears to be doubling down on its behavioral health efforts in its new 2023-2024 federal government budget proposal. The proposed budget aims to grow the behavioral health workforce, increase access to services – including crisis care – and advance mental health research. In response to the current behavioral health crisis, the President’s national mental health strategy aims to strengthen system capacity, connect more Americans to care, and create a continuum of support through the investment in the provision of equitable, evidence-based mental health services.
The proposed reforms to transform behavioral health care in the Biden budget include:
- For Medicare, lowers patients’ costs for mental health services, requires parity in coverage between behavioral health and medical benefits, and expands coverage for behavioral health providers.
- Provides investments in the behavioral health workforce, youth mental health treatment, Certified Community Based Behavioral Health Clinics, Community Mental Health Centers, and mental health research.
- Invests in the 988 Suicide and Crisis Lifeline.
- Accelerates mental health research for promising new treatments and enhanced precision and implementation of existing treatments.
- For private health insurance, expands coverage of mental health benefits and strengthens the network of behavioral health providers.
Here are the detailed provisions in the proposed White House’s federal budget pertaining to behavioral health policies by federal agency and program activity:
MEDICARE MENTAL HEALTH POLICIES
Apply the Mental Health Parity and Addiction Equity Act to Medicare
Unlike most private and employer-based insurance and Medicaid plans, Medicare is not subject to the 2008 Mental Health Parity and Addiction Equity Act (the Act),
Complemented by additional proposals to improve behavioral health benefits in Medicare, the Biden budget proposal would ensure that the parity requirements of the Act apply to the mental health and substance use disorder benefits offered by Medicare Advantage plans so that enrollees do not face greater limitations on reimbursement or access to care relative to medical and surgical benefits.
Eliminate the 190-day Lifetime Limit on Psychiatric Hospital Services
Under current law, once an individual receives Medicare benefits for 190-days of care in a psychiatric hospital during their lifetime, no further benefits of that type are available to that individual. The proposed budget would eliminate the lifetime limit on psychiatric hospital services serves to improve parity between Medicare mental health and physical health coverage It also increases the overall availability of inpatient psychiatric hospital services.
Revise Criteria for Psychiatric Hospital Terminations from Medicare
Current law requires CMS to terminate psychiatric hospital participation in Medicare after six months of non-compliance with conditions of participation, even if the deficiency does not jeopardize patient health and wellbeing. The budget proposal gives CMS flexibility to allow a psychiatric hospital to continue receiving Medicare payments when deficiencies are not considered to immediately jeopardize the health and safety of its patients.
Modernize Medicare Mental Health Benefits
While the Consolidated Appropriations Act of 2023 added coverage for mental health counselors and marriage and family therapists, there remain gaps in Medicare mental health coverage and benefits.
The budget proposal would allow Medicare to identify and designate additional professionals who could enroll in Medicare such as peer support workers and certified addiction counselors. The proposal also establishes a Medicare benefit category for these professionals that authorizes direct billing and payment under Medicare for these practitioners; removes limits on the scope of services for which they can be paid by Medicare; and would allow these practitioners to bill Medicare directly for their mental health services for covered Part A qualifying Skilled Nursing Facility stays.
Require Medicare to Cover Three Behavioral Health Visits without Cost-Sharing
Medicare Part B includes coverage of behavioral health visits to a doctor, therapist, or other clinician for services generally received outside of a hospital, but the annual Part B deductible and coinsurance apply, with limited exceptions. The budget proposal would require Medicare to cover up to three behavioral health visits per year without cost-sharing when furnished by participating providers, beginning in 2025. [$1.5 billion in costs over 10 years]
In addition to the proposed policies identified, the CMS’ budget justification section of the document also identified the following policy initiatives:
Action Taken or To Be Taken
CMS is committed to ensuring that Medicare Advantage (MA) enrollees have access to provider networks sufficient to provide covered services, including access to behavioral health service providers. In the “Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications” proposed rule, CMS proposed to strengthen network adequacy requirements for access to behavioral health care, including Substance Use Disorder (SUD), in MA plans. Specifically, CMS proposes to add Clinical Psychologists, Licensed Clinical Social Workers, and Prescribers of Medication for Opioid Use Disorder as specialty types for which specific minimum standards are set and on which MA networks are evaluated. CMS finalized this proposal in the final rule.]
In this proposed rule, CMS is also proposing to amend general access to services standards to explicitly include behavioral health services; codify standards for appointment wait times for both primary care and behavioral health services; clarify that emergency medical services that must not be subject to prior authorization include behavioral health services to evaluate and stabilize an emergency medical condition; require that Medicare Advantage (MA) organizations notify enrollees when the enrollee’s behavioral health or primary care provider(s) are dropped midyear from networks; and require MA organizations to establish care coordination programs, including coordination of community, social, and behavioral health services to help move towards parity between behavioral health and physical health services and advance whole-person care. Also finalized in the final rule.
SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES ADMINISTRATION (SAMHSA) PROGRAMS
The FY 2024 President’s Budget provides $10.8 billion for SAMHSA, an increase of $3.3 billion above FY 2023 enacted. Building on recent historic gains, the proposed increases for SAMHSA will expand access to lifesaving behavioral health care and grow investments in crisis response, harm reduction, the behavioral health workforce, services to people experiencing homelessness, and recovery services.
Investing in Mental Health and Crisis Response
The FY 2024 budget provides $4.9 billion for SAMHSA’s mental health activities, an increase of $2.2 billion over FY 2023 enacted. The proposed investments will address suicide prevention, increase crisis response, and provide direct services to people experiencing homelessness.
9-8-8 and Behavioral Health Crisis Services
The FY 2024 budget proposals would build on the historic investments in suicide prevention made in FY 2023 and ensure the 9-8-8 and Behavioral Health Crisis Services program is accessible and tailored to all people seeking help. In FY 2024, SAMHSA would dedicate $836 million to the 9-8-8 and Behavioral Health Services program, an increase of $334 million over FY 2023 enacted. This budget would provide funds for a fully developed crisis response system that answers at any time or place, and for specialized services for LGBTQI+youth, services for Spanish speakers, invests significantly in local crisis centers, and would develop a national media campaign.
Mental Health Infrastructure
The budget would continue to invest in the nation’s mental health infrastructure, beginning with $1.7 billion for the Community Mental Health Block Grant, an increase of $645 million above FY 2023 enacted. This block grant provides flexible funding and supports stable and effective services for our nation’s most vulnerable populations.
The budget includes $553 million for the Certified Community Behavioral Health Clinics grant program, an increase of $168 million above FY 2023 enacted.
In support of the President’s call for transforming the delivery of mental health care, the budget includes a $2 billion mandatory Mental Health System Transformation Fund to expand access to mental health services through workforce development and service expansion, including the development of nontraditional health delivery sites, the integration of quality mental health and substance use care into primary care settings, and dissemination of evidence-based practices.
Address Overdose Epidemic and Support Recovery
The budget would provide $5.7 billion for substance use prevention and treatment activities, an increase of $1.3 billion over FY 2023 enacted, funding states and territories to increase access to treatment for substance use disorder, advance public-health interventions like naloxone, and expand recovery support services.
Harm Reduction
The budget proposes to provide $50 million for a harm reduction program to continue the initiative first created in the American Rescue Plan. The budget also proposes to increase access to naloxone by providing $78 million to the First Responder Training program, an increase of $22 million over FY 2023 enacted, and providing $28 million for grants to prevent overdose, an increase of $12 million above FY 2023 enacted.
The budget includes $2.7 billion for the Substance Use Prevention, Treatment, and Recovery Services Block Grant — an increase of $700 million over FY 2023 enacted.
The budget also includes $2 billion for the State Opioid Response grant program, a $425 million increase above FY 2023 enacted, to provide direct services to prevent, treat, and promote recovery from issues related to opioid misuse,
Building Capacity to Improve the Nation’s Behavioral Health
The budget would continue to support access to high-quality public health data regarding mental health and substance use.
Expanding and Diversifying the Behavioral Health Workforce
The budget includes $37 million for SAMHSA’s Minority Fellowship Programs, an increase of $17 million over FY 2023 enacted. Since the Fellowship began in 1973, the program has increased the number of culturally competent behavioral health professionals who teach, administer, conduct services research, and provide direct mental illness or substance use disorder treatment services for underserved minority populations. The proposed investment in this program will almost double the number of fellows and increase the number of trained providers to 6500.
HEALTH RESOURCES AND SERVICES ADMINISTRATION (HRSA) PROGRAMS
Behavioral Health Workforce Development
HRSA’s behavioral health workforce development programs train new behavioral health providers— including clinicians, peer support specialists, and others—and increase the number of providers practicing in areas of high demand throughout the country. The FY 2024 budget includes $387 million, which is $190 million above FY 2023 enacted, to train about 18,000 behavioral health providers to help respond to the mental health and substance use crisis currently affecting our country.
Supporting the Mental Health and Wellness of the Health Professions Workforce
The FY 2024 budget invests $25 million, in support of the Dr. Lorna Breen Act, for a new program to support the development of a culture of wellness in health care facilities including hospitals, rural health clinics, community health centers and medical professional associations.
Rural Opioids Response
Within the total for Rural Health, the budget invests $165 million for the Rural Communities Opioid Response Program, an increase of $20 million above the FY 2023 enacted. This increase will support the development and continuation of community-based grant programs and technical assistance that provide needed behavioral health, including Opioid Use Disorder and Substance Use Disorder services to rural residents.
Rural Behavioral Health Initiative
The budget for rural health includes $10 million for a new Rural Health Clinic Behavioral Health Initiative to expand access to mental health services in rural communities.
CENTERS FOR DISEASE CONTROL AND PREVENTION (CDC) PROGRAMS
Youth Mental Health Promotion and Treatment
The budget request includes $90 million, an increase of $52 million above FY 2023 enacted, for CDC’s What Works in Schools program. The program strengthens the integrated delivery of mental health promotion and treatment interventions to students and families across a range of care settings with a focus on Black and Hispanic youth, female students, and LGBTQI+ youth who experience disproportionately adverse mental health outcomes.
Suicide Prevention
The FY 2024 budget requests $80 million, an increase of $50 million above FY 2023 enacted, for the Suicide Prevention Program to expand CDC’s work to all 50 states, the District of Columbia, and 18 tribal and territorial communities, as well as other nongovernmental organizations and university research programs to reduce suicide.
NATIONAL INSTITUTES OF HEALTH (NIH) INITIATIVES
Combatting Overdose and Addiction
The budget includes over $1.8 billion within NIH for opioids, stimulant and pain research, Of this total, $1.2 billion would support ongoing research across the Institutes and Centers, while $636 million is allocated to the Helping to End Addiction Long-term (HEAL) Initiative. Founded in 2018, the HEAL initiative strives to address opioid addiction by developing new treatments and strategies to address both pain and opioid use disorder and advance healthy equity.
Innovating Mental Health Research and Treatment
The FY 2024 budget includes an increase of $200 million for the National Institute of Mental Health to support better diagnostics, improved treatments, and enhanced precision of care for mental health.
AGENCY FOR HEALTH CARE RESEARCH AND QUALITY (AHRQ)
The FY 2024 budget requests $5 million in new funding, which would allow AHRQ to conduct new research to better understand how to scale and spread existing “Local Integrated Care Network” models. Local Integrated Care Networks provide behavioral health support systems for primary care practices.
PRIVATE INSURANCE
This proposal provides $125 million in mandatory funding over five years for grants to states to enforce mental health and substance use disorder parity requirements. Any funds not expended by states at the end of five fiscal years would remain available to the HHS Secretary to make additional mental health parity grants. [$125 million in costs over 10 years]
Implications and Next Steps
The budget plan from the White House would significantly expand mental health workforce development programs through new initiatives offered by SAMHSA, HRSA, and CDC, and significantly increase funding for crisis and mobile services at the local level. These initiatives and others highlighted in this report, if enacted, would offer new opportunities for behavioral health providers to participate in several delivery systems and programs in the public and private sectors.
The FY 2024 budget process is still in its early phases, and there we will likely see several changes to the budget between now and the end of the calendar year. NCMHA will be closely monitoring the budget development process and reporting on progress in investments in older adult mental health programs.
Keep in mind that the budget negotiations between Congress and the White House will be caught up in the battle to raise the federal debt ceiling, so the country does not default on its payment obligations.
So stay tuned… as this is likely to be a messy Congressional budget-development process… again.