Medicaid Bump Act

H.Res. 1141 - Educator Mental Health Awareness Week Resolution H.Res. 1191 - Providing for consideration of the bill (H.R. 4176) to improve Federal population surveys by requiring the collection of voluntary, self-disclosed information on sexual orientation and gender identity in certain surveys, and for other purposes; providing for consideration of the bill (H.R. 5585) to establish the Advanced Research Projects Agency-Health, and for other purposes; providing for consideration of the bill (H.R. 7666) to amend the Public Health Service Act to reauthorize certain programs relating to mental health and substance use disorders, and for other purposes; and for other purposes. H.R. 623 - Gabriella Miller Kids First Research Act 2.0 H.R. 909 / S. 484 - Moms Matter Act H.R. 1384 / S. 445 - Mainstreaming Addiction Treatment (MAT) Act H.R. 1475/ S. 1795 - Pursuing Equity in Mental Health Act H.R. 2067 - MATE Act H.R. 2256/ S. 834 - Resident Physician Shortage Reduction Act of 2021 H.R. 2377 - Federal Extreme Risk Protection Order Act of 2021 H.R. 2376 - Excellence in Recovery Housing Act H.R. 2929 - Virtual Peer Support Act H.R. 3173/ S. 3018 - Improving Seniors Timely Access to Care Act of 2021 H.R. 3407/ S. 411 - MOMMAS Act H.R. 3447 - Permanency for Audio-Only Telehealth Act H.R. 3450/ S. 1727 - Medicaid Bump Act H.R. 3753/ S. 1962 - Parity Implementation Assistance Act H.R. 3771 - South Asian Heart Health Awareness Act of 2021 H.R. 4058/ S. 2061 - Telemental Health Care Access Act. H.R. 4122 / S. 3658 - Resident Education Deferred Interest (REDI) Act H.R. 4217 / S. 2779 - TRIUMPH for New Moms Act H.R. 4770 - Evaluating Disparities and Outcomes of Telehealth (EDOT) Act of 2021 H.R. 4944 - Helping Kids Cope Act of 2021 H.R. 5218 - Collaborate in an Orderly and Cohesive Manner Act H.R. 5585 - Advanced Research Project Agency-Health Act H.R. 6943 / S. 3635 - Public Safety Officer Support Act H.R. 7073 - Into the Light for Maternal Mental Health Act H.R. 7076 - Supporting Childrens Mental Health Care Access Act of 2022 H.R. 7116 - 988 Implementation Act of 2022 H.R. 7232 - 988 and Parity Assistance Act of 2022 H.R. 7233 - Keeping Incarceration Discharges Streamlined for Children and Accommodating Resources in Education Act or the KIDS CARES Act H.R. 7234 - Summer Barrow Prevention, Treatment, and Recovery Act H.R. 7235 / S.4301 - Substance Use Prevention, Treatment, and Recovery Services Block Grant Act of 2022 H.R. 7236 - Strengthen Kids Mental Health Now Act of 2022 H.R. 7237 - Reauthorizing Evidence-based and Crisis Help Initiatives Needed to Generate Improved Mental Health Outcomes for Patients Act of 2022 or the REACHING Improved Mental Health Outcomes for Patients Act of 2022 H.R. 7238 - Timely Treatment for Opioid Use Disorder Act of 2022 H.R. 7241 - Community Mental Health Services Block Grant Reauthorization Act H.R. 7248 - Continuing Systems of Care for Children Act H.R. 7249 / S. 3686 - Anna Westin Legacy Act of 2022 H.R. 7254 - Mental Health Justice and Parity Act of 2022 H.R. 7255 / S. 4271 - Garrett Lee Smith Memorial Reauthorization Act H.R. 7427 - To amend title XI of the Social Security Act to require CMI testing of incentive payments for behavioral health providers and certain other providers for adoption and use of certified electronic health record technology, and for other purposes. H.R. 7565 - NIH Improve Act H.R. 7649 - To direct the Secretary of Health and Human Services to open a public docket for the submission of public comments regarding factors that should be taken into consideration when reviewing a proposed modification to an approved risk evaluation and mitigation strategy, and for other purposes. H.R. 7666 - Restoring Hope for Mental Health and Well-Being Act of 2022 H.R. 7667 - Food and Drug Amendments of 2022 H.R. 7740 - Employee and Retiree Access to Justice Act of 2022 H.R. 7767 - Strengthening Behavioral Health Benefits Act H.R. 7845 - NIH Clinical Trial Diversity Act H.R. 7857 - Minority Fellowship Program Reauthorization Act of 2022 H.R. 7910 - Protecting Our Kids Act H.R. 8180 - Undertaking Needed Investments in Therapy, Education, and De-Escalation Act of 2022 H.R. 8229 - Telemental Health Parity Act S. 2938 - Bipartisan Safer Communities Act S. 4132 - Womens Health Protection Act S. 4170 - Mental Health Reform Reauthorization Act of 2022 S. 4306 - Improving Access to Behavioral Health Integration Act S. 4348 - Food and Drug Administration Safety and Landmark Advancements S. 4461 - Expanding Access to Mental Health Training Act S. 4448 - Suicide Prevention Act No legislation - Implementation of new REMS regulations

Client expense: $181,613 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Management & Budget (OMB), SENATE

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for H.R.7803 - Michelle Alyssa Go Act, which would amend title XIX of the Social Security Act to remove the exclusion from medical assistance under the Medicaid program of items and services for patients in an institution for mental diseases, and for other purposes. Advocated for use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant and acceptance of Medicaid by treatment grantees. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Advocated for closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Advocated for federal agency guidance on CAPTA reporting vs. notification requirements. Advocated for stronger network adequacy requirements for OTPS and addiction specialist physicians under Medicare Advantage Plans On April 4, ASAM and stakeholders sent a letter to the House Energy & Commerce Committee in support the "Mental Health Justice and Parity Act of 2022," under consideration at the Committee's April 5 hearing. The organizations asked the Committee to support the legislation that phases out "parity opt-outs" among self-funded state and local health plans. On May 10th, ASAM sent a letter to leadership of the U.S. House Committee on Energy and Commerce on H.R. 7666 - the Restoring Hope for Mental Health and Well-Being Act of 2022 (the Act), in advance of the Subcommittee on Healths legislative mark-up session on May 11th. In its letter, ASAM advocates for reducing complex barriers to addiction treatment, including eliminating the one-year requirement that an individual have an addiction to opioids to begin methadone treatment at an opioid treatment program (OTP), supporting provisions inspired by the Opioid Treatment Access Act (OTAA) - including revising who can determine the stability of a patient for take-homes to include a medical practitioner appropriately licensed by the State to prescribe or dispense controlled medications, - and codifying recent mobile methadone regulations into law. In its letter, ASAM also advocates for increased funding to support HRSAs Addiction Medicine Fellowship Program; adding addiction medicine to SAMHSAs Minority Fellowship Program grants, and adding addiction specialists to HRSAs Pediatric Mental Health Care Access grants. The letter concludes with a call for adding the MATE and MAT Acts to the Act. The MATE Act would condition the federal DEA registration to prescribe controlled medications on a one-time, flexible education requirement on the treatment of patients with substance use disorder. The MAT Act would eliminate the DATA 2000-waiver, a barrier to broader uptake of treatment for OUD with buprenorphine, a life-saving medication. On April 1, ASAM joined a coalition letter to the Department of Labor and HHS expressing concern about a recent decision from a three-judge panel of the U.S. Ninth Circuit Court of Appeals that threatens to have devastating effects on Americans ability to access medically necessary mental health and substance use disorder (MH/SUD) services covered by commercial health plans and requesting that the Departments of Labor and Health and Human Services file an amicus brief in this case to support en banc review before the entire Ninth Circuit. On May 11th, ASAM and other stakeholders sent a letter to U.S. House Energy and Commerce Committee leadership praising Section 321 of the Restoring Hope for Mental Health and Well-Being Act of 2022, which would sunset the ability of self-funded, non-federal governmental health care plans to opt-out of protections provided by the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. On June 3, ASAM joined a large coalition of public health, harm reduction, HIV, and hepatitis organizations in sending a letter urging Congress to appropriate $150 million in fiscal year 2023 towards the Centers for Disease Control and Preventions (CDC) Infectious Diseases and Opioid Epidemic Program. This letter garnered support from 334 organizations from all fifty states, DC, and Puerto Rico, and may be the largest display of support from community stakeholders for lifesaving harm reduction services and for ending the ban on the use of certain federal funding for syringes. On June 14th, ASAM joined a coalition letter regarding the FY 2023 Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations bill, urging House appropriators not to include provisions that would weaken FDAs authority over tobacco products. On June 27th, ASAM joined a Coalition of Whole Health letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure and Deputy Administrator Dr. Meena Seshamani, supporting a proposed Medicare rule that would establish a special enrollment period (SEP) for individuals formerly incarcerated and exempt those who enroll under the SEP from a Late Enrollment Penalty (LEP) and urging CMS to revise its current definition of in custody for Medicare to be consistent with the definition CMS uses for Medicaid.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Draft Legislation - IMD Medicaid (Napolitano) S. 586: NO PAIN Act H.R. 1551/S 584: Nutrition Counseling Aiding Recover for Eating Disorders Act H.R. 3450/S. 1727: Medicaid Bump Act H.R. 3447: Permanency for Audio Only Telehealth Act H.R. 4058: Telemental Health Care Access Act S. 2061: Telemental Health Care Access Act S. 2069: Excellence in Mental Health and Addiction Treatment Act H.R. 1738/S. 646: Stabilize Medicaid and CHIP Coverage Act S.285: Medicaid Reentry Act S.340: TREATS Act H.R. 1577/S. 596: Treat and Reduce Obesity Act H.R. 314: Medicare Sequester COVID Moratorium Act H.R 1868: To prevent across the board direct spending cuts S. 1512/H.R. 2903: CONNECT for Health Act H.R. 4480: Telehealth Coverage and Payment Parity Act S. 1798/H.R. 1398: TIKES Act H.R. 5674 / S. 3061: Medicare Mental Health Inpatient Equity Act H.R. 2503 Social Determinants Accelerator Act of 2021 Medicaid/Medicare/Private Insurance provisions in the Build Back Better Act S. 610, Public Law 117-71: Protecting Medicare and American Farmers from Sequester Cuts Act H.R. 4406 Supporting Medicaid in the U.S. Territories Act H.R. 341 Ensuring Telemental Health Expansion Act of 2021 H.R. 6698 Stop Unfair Medicaid Recoveries Act H.R. 6636 / S. 2697 Due Process Continuity of Care Act HR 3173/S. 3018 Improving Seniors Access to Timely Care Act Draft bill re: Medicare reimbursement of services provided by advanced trainees

Client expense: $260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 69 / S. 623 - Sunshine Protection Act of 2021 H.R. 423/ S. 828 - Mental Health Access Improvement Act H.R. 1385/ S. 3696 - Behavioral Health Coordination and Communication Act of 2022 H.R. 1475/ S. 1795 - Pursuing Equity in Mental Health Act H.R. 1545/ S. 3689 - Crisis Counseling Act H.R. 2256/ S. 834 - Resident Physician Shortage Reduction Act of 2021 H.R. 2376 - Excellence in Recovery Housing Act H.R. 2929 - Virtual Peer Support Act H.R. 3345 - Helping MOMS Act of 2021 H.R. 3407/ S. 411 - MOMMAS Act H.R. 3447 - Permanency for Audio-Only Telehealth Act H.R. 3450/ S. 1727 - Medicaid Bump Act H.R. 3753/ S. 1962 - Parity Implementation Assistance Act H.R. 4058/ S. 2061 - Telemental Health Care Access Act of 2021 H.R. 4122/ S. 3658 - Resident Education Deferred Interest (REDI) Act H.R. 4251 - Native Behavioral Health Access Improvement Act of 2021 H.R. 4944 - Helping Kids Cope Act of 2021 H.R. 4770 - Evaluating Disparities and Outcomes of Telehealth (EDOT) Act of 2021 H.R. 5218 - Collaborate in an Orderly and Cohesive Manner Act H.R. 5837 - To amend title XVIII of the Social Security Act to expand access to telehealth services relating to substance use disorder treatment, and for other purposes. H.R. 6202 - Telehealth Extension Act of 2021 H.R. 7045/ S. 3796 - Closing Health Coverage Gaps for Public Servants Act of 2022 H.R. 7073 - Into the Light for Maternal Mental Health Act H.R. 7076 - Supporting Childrens Mental Health Care Access Act of 2022 H.R. 7116 - 988 Implementation Act of 2022 H.R. 7232 - 988 and Parity Assistance Act of 2022 H.R. 7233 - Keeping Incarceration Discharges Streamlined for Children and Accommodating Resources in Education Act or the KIDS CARES Act H.R. 7234 - Summer Barrow Prevention, Treatment, and Recovery Act H.R. 7235 - Substance Use Prevention, Treatment, and Recovery Services Block Grant Act of 2022 H.R. 7236 - Strengthen Kids Mental Health Now Act of 2022 H.R. 7237 - Reauthorizing Evidence-based and Crisis Help Initiatives Needed to Generate Improved Mental Health Outcomes for Patients Act of 2022 or the REACHING Improved Mental Health Outcomes for Patients Act of 2022 H.R. 7238 - Timely Treatment for Opioid Use Disorder Act of 2022 H.R. 7241 - Community Mental Health Services Block Grant Reauthorization Act H.R. 7248 - Continuing Systems of Care for Children Act H.R. 7249 / S. 3686 - Anna Westin Legacy Act of 2022 H.R. 7254 - Mental Health Justice and Parity Act of 2022 H.R. 7255 - Garrett Lee Smith Memorial Reauthorization Act H.R. 7370 - Student Mental Health Rights Act S.Res. 518 - Behavioral Health Resolution S. 3593 - Telehealth Extension and Evaluation Act S. 3628 - Youth Mental Health and Suicide Prevention Act S. 3663 - Kids Online Safety Act S. 3688 - Improving Access to Tele-Behavioral Health Services Act S. 3704 - Advancing Student Services in Schools Today (ASSIST) Act S. 3799 - Prepare for and Response to Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT Pandemics Act) (No legislation) Implementation of new REMS regulations

Client expense: $166,945 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Office of Management & Budget (OMB), SENATE

Draft Legislation - IMD Medicaid (Napolitano) S. 586: NO PAIN Act H.R. 1551/S 584: Nutrition Counseling Aiding Recover for Eating Disorders Act H.R. 3450/S. 1727: Medicaid Bump Act H.R. 3447: Permanency for Audio Only Telehealth Act H.R. 4058: Telemental Health Care Access Act S. 2061: Telemental Health Care Access Act S. 2069: Excellence in Mental Health and Addiction Treatment Act H.R. 1738/S. 646: Stabilize Medicaid and CHIP Coverage Act S.285: Medicaid Reentry Act S.340: TREATS Act H.R. 1577/S. 596: Treat and Reduce Obesity Act H.R. 314: Medicare Sequester COVID Moratorium Act H.R 1868: To prevent across the board direct spending cuts S. 1512/H.R. 2903: CONNECT for Health Act H.R. 4480: Telehealth Coverage and Payment Parity Act S. 1798/H.R. 1398: TIKES Act Letter to CMS re: TN Medicaid proposed amendment (Coalition letter) H.R. 5674 / S. 3061: Medicare Mental Health Inpatient Equity Act H.R. 2503 Social Determinants Accelerator Act of 2021 Medicaid/Medicare/Private Insurance provisions in the Build Back Better Act S. 610, Public Law 117-71: Protecting Medicare and American Farmers from Sequester Cuts Act H.R. 4406 Supporting Medicaid in the U.S. Territories Act H.R. 341 Ensuring Telemental Health Expansion Act of 2021 H.R. 6698 Stop Unfair Medicaid Recoveries Act H.R. 6636 / S. 2697 Due Process Continuity of Care Act

Client expense: $226,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), HOUSE OF REPRESENTATIVES, SENATE

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for HR 6279/S 3629 - Opioid Treatment Access Act which would make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Joined advocacy efforts with Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education ASAM and ten other health professional associations have called for the FDA to immediately and fully retract its buprenorphine Drug Safety Communication of January 12, 2022. In their letter, the signatories maintain that the communication is based on flawed analysis. As part of the National Alliance for Underage Drinking, ASAM sent a letter to Representative Roybal-Allard, Representative Joyce, and Representative DeLauro in support of reauthorization of the Sober Truth on Preventing (STOP Act). First passed by Congress in 2006 and later reauthorized in the 21st Century Cures Act, the STOP Act aims to reduce underage age drinking through a comprehensive approach comprised of cost-effective, evidence-based strategies. On January 26th, ASAM submitted a comment letter to CMSs proposed rule Patient Protection and Affordable Care Act (ACA); HHS Notice of Benefit and Payment Parameters (the NBPP 2023 Rule). In its letter, ASAM supports, among other things: reinterpretation of the ACAs guaranteed availability requirement; the new interpretation would require issuers to enroll individuals with past-due premiums; reversion to pre-2020 non-discrimination protections that would prohibit certain exchanges, insurers, and agents and brokers from discriminating based on sexual orientation and gender identity; ensuring nondiscriminatory benefit design through refining the EHB nondiscrimination policy, providing a clear regulatory framework to evaluate plan benefit design and implementation based upon clinical guidelines and evidence; and requirements that issuers offer at least one standardized plan at every product network type, metal level, and in every service area where the issuer also offers non-standardized plans and that standardized plans use fixed copays instead of coinsurance. The letter also documents ASAMs general support for proposals related to network adequacy regulations, with recommendations for further refinement. On March 22, 2022, ASAM and other stakeholders sent a letter, spearheaded by former Representative Patrick J. Kennedy, to the Secretary of State Antony J. Blinken, and the U.S. Agency for International Development Administrator, Samantha Power. The letter urges mental health and substance use disorders (SUDs) be integrated in the U.S. - Ukraine relief efforts, and that the U.S. coordinate with multilateral health organizations and the World Health Organization to address mental health and SUDs caused and exacerbated by the invasion of Ukraine. ASAM joined a coalition letter to urge Congress to respond to a new and growing threat to our nations youth: e-cigarette manufacturers use of synthetic nicotine to evade Food and Drug Administration (FDA) oversight. Specifically, the letter urges Congress to quickly address this serious public health situation by enacting legislation at the earliest possible opportunity that enables FDAs Center for Tobacco Products to regulate synthetic nicotine products. ASAM joined a coalition letter to express support for the Food and Drug Administrations commitment to issuing proposed rules to prohibit menthol as a characterizing flavor in cigarettes and prohibit all characterizing flavors in cigars. Once issued, the letter urges FDA to move quickly to finalize and implement these life-saving rules. ASAM joined a coalition letter supporting the Into the Light for Maternal Mental Health and Substance Use Disorders Act of 2022, which would address critical issues of maternal mental health and well-being. ASAM joined a coalition letter urging Congress to support increased funding of important addiction prevention, treatment, harm reduction, and recovery support programs aimed at strengthening the addiction service workforce in Fiscal Year 2023. Advocated for federal clarification of suspicious order rules to break down perceived and real barriers to buprenorphine access at pharmacies Advocated for passage of HR 3441/ S 1438 the Opioid Workforce Act/Substance Use Disorder Workforce Act to increase Medicare supported GME slots for addiction medicine, addiction psychiatry, and pain medicine. Supported HR 7246/S 3940 - the Student Athlete Opioid Misuse Prevention Act which would establish a grant program through SAMHSA to provide educational and training at the youth, high school, and collegiate level for students and student athletes themselves, as well as athletic directors, youth sports coaches and organizers, school administrators, and others on the signs and dangers of opioid and substance misuse, and strategies for prevention. Advocated for draft legislative text that would close severe MH/SUD coverage gaps in Medicare. Supported H.R.7116- the 9-8-8 Implementation Act which would provide resources needed to improve the nations mental health/substance use crisis system.

Client expense: $90,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

H.R. 721 Mental Health Services for Students Act of 2021 H.R. 5469 Pursuing Equity in Mental Health Act H.R.1667/S.610 Dr. Lorna Breen Health Care Provider Act H.R. 586 STANDUP Act H.R.1309/S.194 SERVE Act H.R.3150/S.1578 Mental Health Professionals Workforce Shortage Loan Relief Act Mental Health Needs of Migrant Youth at the Southern Border H.R. 1324/S. 467 Effective Suicide Screening and Assessment in the Emergency Department Act of 2021 H.R. 3450/S. 1727 The Medicaid Bump Act H.R. 4122 The Resident Education Deferred Interest Act S.2069 Excellence in Mental Health and Addiction Treatment Expansion Act

Client expense: $20,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA), White House Office

H.R. 721 Mental Health Services for Students Act of 2021 H.R. 5469 Pursuing Equity in Mental Health Act H.R.1667/S.610 Dr. Lorna Breen Health Care Provider Act H.R. 586 STANDUP Act H.R.1309/S.194 SERVE Act H.R.3150/S.1578 Mental Health Professionals Workforce Shortage Loan Relief Act Mental Health Needs of Migrant Youth at the Southern Border H.R. 1324/S. 467 Effective Suicide Screening and Assessment in the Emergency Department Act of 2021 H.R. 3450/S. 1727 The Medicaid Bump Act H.R. 4122 The Resident Education Deferred Interest Act S.2069 Excellence in Mental Health and Addiction Treatment Expansion Act

Client expense: $20,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA), White House Office

H.R. 721 Mental Health Services for Students Act of 2021 H.R. 5469 Pursuing Equity in Mental Health Act H.R.1667/S.610 Dr. Lorna Breen Health Care Provider Act H.R. 586 STANDUP Act H.R.1309/S.194 SERVE Act H.R.3150/S.1578 Mental Health Professionals Workforce Shortage Loan Relief Act Mental Health Needs of Migrant Youth at the Southern Border H.R. 1324/S. 467 Effective Suicide Screening and Assessment in the Emergency Department Act of 2021 H.R. 3450/S. 1727 The Medicaid Bump Act H.R. 4122 The Resident Education Deferred Interest Act S.2069 Excellence in Mental Health and Addiction Treatment Expansion Act

Client expense: $20,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA), White House Office

S. 1512/H.R. 2903 - Connect for Health Act of 2021 - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth H.R. 366 - Protecting Access to Post-COVID-19 Telehealth Act of 2021 - provisions related to continuing the regulatory flexibilities provided during the Public Health Emergency S. 368/H.R. 1332 Telehealth Modernization Act - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth S. 2061 - Tele-mental Health Care Access Act of 2021 to repeal the in-person visit Medicare requirement for mental health services provided via telehealth Proposals to prevent future sequester cuts, reducing Medicare payments H.R. 3684, Infrastructure bill - provisions related to the Medicare sequester and funding for broadband S.610 - Protecting Medicare and American Farmers from Sequester Cuts Act - provisions related to Medicare payments and the Medicare sequester H.R. 5376, "Build Back Better Act" - provisions related to health policy, Medicare, workforce and hospital emergency preparedness S. 1727/H.R. 3450 - Medicaid Bump Act - provisions related to providing an enhanced FMAP for behavioral health care services and to ensuring the increased payments supports the provision of service Home Hospital Care Model

Client expense: $60,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 19 - Lower Costs, More Cures Act of 2021 - Rep. McMorris Rodgers, Cathy [R-WA-5] - Medicare and Medicaid reforms H.R. 56 - Patient Access to Medical Foods Act - Rep. Biggs, Andy [R-AZ-5] - coverage of medical foods H.R. 66 - CARING for Kids Act - Rep. Buchanan, Vern [R-FL-16] - CHIP extension H.R. 315 - Medicare Sequester COVID Moratorium Act - Rep. Schneider, Bradley Scott [D-IL-10] - Medicare Sequester H.R. 340 - Incentivizing Medicaid Expansion Act of 2021 - Rep. Veasey, Marc A. [D-TX-33] - Medicaid expansion H.R. 502 - Medicare Dental Benefit Act of 2021 - Rep. Barragan, Nanette Diaz [D-CA-44] - Medicare dental coverage H.R. 525 - COVID HCBS Relief Act of 2021 - Rep. Dingell, Debbie [D-MI-12] - HCBS H.R. 599 - Protecting Medicare Beneficiaries with Pre-Existing Conditions Act - Rep. Schneider, Bradley Scott [D-IL-10] - pre-existing conditions H.R. 722 - Ensuring Vaccination and Treatment Affordability Act - Rep. Pappas, Chris [D-NH-1] - cost-sharing for COVID-19 vaccines H.R. 918 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Rep. Cardenas, Tony [D-CA-29] - Medicaid & COVID-19 H.R. 955 - Medicaid Reentry Act of 2021 - Rep. Tonko, Paul [D-NY-20] - Medicaid coverage H.R. 975 - Ensuring Seniors Access to COVID Treatments Act - Rep. Casten, Sean [D-IL-6] - coverage of COVID-19 drugs H.R. 1227 - Medicare-X Choice Act of 2021 - Rep. Delgado, Antonio [D-NY-19] - Medicare-X H.R. 1495 - Jim Ramstad Legacy of Recovery Act - Rep. Emmer, Tom [R-MN-6] - Medicaid coverage for SUD H.R. 1717 - Protecting Married Seniors from Impoverishment Act of 2021 - Rep. Upton, Fred [R-MI-6] - HCBS and spousal impoverishment H.R. 1722 - Puerto Rico Health Care Fairness, Accountability, and Beneficiary Access Act of 2021 - Rep. Velazquez, Nydia M. [D-NY-7] - Medicaid for territories H.R. 1791 - CHIPP Act - Rep. Barragan, Nanette Diaz [D-CA-44] - CHIP extension H.R. 1795 - Expanded Coverage for Former Foster Youth Act - Rep. Bass, Karen [D-CA-37] - coverage for foster youth H.R. 1880 - To amend the Deficit Reduction Act of 2005 to make permanent the Money Follows the Person Rebalancing Demonstration - Rep. Dingell, Debbie [D-MI-12] - Money Follows the Person extension H.R. 1969 - Medicare Advantage Integrity Act - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - Medicare Advantage benchmark rates H.R. 1976 - Medicare for All Act of 2021 - Rep. Jayapal, Pramila [D-WA-7] - Medicare for All H.R. 1978 - Protecting Seniors Through Immunization Act of 2021 - Rep. Kuster, Ann M. [D-NH-2] - cost sharing for vaccines under Medicare part D H.R. 1999 - Protect Seniors and Cut Waste Act - Rep. Smith, Jason [R-MO-8] - sequester for Pay-As-You-Go H.R. 2166 - Ensuring Parity in MA and PACE for Audio-Only Telehealth Act of 2021 - Rep. Sewell, Terri A. [D-AL-7] - Medicare coverage of telehealth H.R. 2217 - Territory Federal Matching Requirement Equity Act of 2021 - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - FMAP for territories H.R. 2297 - MIND Act - Rep. Boyle, Brendan F. [D-PA-2] - Medicaid payment for services provided in institutions for mental diseases H.R. 2464 - More Help for Seniors Act of 2021 - Rep. Craig, Angie [D-MN-2] - Medicare prescription drug benefit H.R. 2881 - Medicare Buy-In and Health Care Stabilization Act of 2021 - Rep. Higgins, Brian [D-NY-26] - Medicare public insurance H.R. 3108 - Medical Nutrition Therapy Act of 2021 - Rep. Kelly, Robin L. [D-IL-2] - coverage of medical foods H.R. 3173 - Improving Seniors Timely Access to Care Act of 2021 - Rep. DelBene, Suzan K. [D-WA-1] - prior authorization H.R. 3447 - Permanency for Audio-Only Telehealth Act - Rep. Smith, Jason [R-MO-8] - Medicare telehealth coverage H.R. 3450 - Medicaid Bump Act - Rep. Tonko, Paul [D-NY-20] - Medicaid funding and behavioral health H.R. 3894 - CARING for Social Determinants Act of 2021- Rep. Blunt Rochester, Lisa [D-DE-At Large] - Medicaid and SDOH H.R. 3961 - COVER Now Act - Rep. Doggett, Lloyd [D-TX-35] - Medicaid expansion H.R. 4040 Advancing Telehealth Beyond COVID-19 Act of 2021- Rep. Cheney, Liz [R-WY-At Large] - Medicare telehealth coverage H.R. 4043 - Ensuring Patient Access to Critical Breakthrough Products Act of 2021 - Rep. DelBene, Suzan K. [D-WA-1] - Medicare coverage of breakthrough devices H.R. 4074 - Addressing Social Determinants in Medicare Advantage Act of 2021 - Rep. Bilirakis, Gus M. [R-FL-12] - Medicare Advantage supplemental benefits H.R. 4158 - Insulin Access for All Act of 2021 - Rep. Rush, Bobby L. [D-IL-1] - cost sharing for insulin H.R. 4187 - Medicare Vision Act of 2021 - Rep. Schrier, Kim [D-WA - Medicare vision coverage H.R. 4263 - Patient Parity Protection Act of 2021 - Rep. Gottheimer, Josh [D-NJ-5] - out-of-network services H.R. 4311 - Medicare Dental, Vision, and Hearing Benefit Act of 2021 - Rep. Doggett, Lloyd [D-TX-35] - Medicare dental, vision, and hearing benefits H.R. 4406 - Supporting Medicaid in the U.S. Territories Act of 2021 - Rep. Soto, Darren [D-FL-9] - Medicaid support in U.S. territories H.R. 4439 - Medicaid Dental Benefit Act - Rep. Barragan, Nanette Diaz [D-CA-44] - Medicaid dental benefit H.R. 4640 - Close the Medigap Act of 2021 - Rep. Doggett, Lloyd [D-TX-35] - Medicare supplemental health insurance policies H.R. 4650 - Medicare Dental Coverage Act of 2021 - Rep. Kelly, Robin L. [D-IL-2] - Medicare dental benefit H.R. 4941 - PACE Part D Choice Act of 2021 - Rep. Blumenauer, Earl [D-OR-3] - prescription drug plans in the Medicare-only PACE program H.R. 4942 - BETTER Kidney Care Act - Rep. Blumenauer, Earl [D-OR-3] - demonstration program for Medicare enrollees with ESRD H.R. 4974 - State Public Option Act - Rep. Schrier, Kim [D-WA-8] - Medicaid public option H.R. 5099 - Lowering Medicare Premiums and Prescription Drug Costs Act - Rep. Schneider, Bradley Scott [D-IL-10] - Medicare cost-sharing benefits H.R. 5110 - Medicare Medically Necessary Dental Care Act of 2021 - Rep. Cohen, Steve [D-TN-9] - Medicare dental benefits H.R. 5165 - Improving Medicare Coverage Act - Rep. Jayapal, Pramila [D-WA-7] - Medicare eligibility age H.R. 5414 - Ensuring Medicaid Continuity for Children in Foster Care Act of 2021 - Rep. Bilirakis, Gus M. [R-FL-12] - Medicaid coverage for children in foster care H.R. 5425 - Protecting Rural Telehealth Access Act - Rep. O'Halleran, Tom [D-AZ-1] - Medicare telehealth services H.R. 5576 - Fair Drug Prices for Kids Act - Rep. Wild, Susan [D-PA-7] - Medicaid Drug Rebate Program under CHIP H.R. 5632 - Long-Term Care Pharmacy Definition Act of 2021 - Rep. Schrader, Kurt [D-OR-5] - Medicare long term care pharmacy H.R. 5674 - Medicare Mental Health Inpatient Equity Act of 2021 - Rep. Tonko, Paul [D-NY-20] - inpatient psychiatric hospital services under Medicare H.R. 6101 - Drug Price Transparency in Medicaid Act of 2021 - Rep. Carter, Earl L. "Buddy" [R-GA-1] - drug pricing in Medicaid S. 97 - Medicare Dental Benefit Act of 2021 - Sen. Cardin, Benjamin L. [D-MD] - Medicare dental coverage S. 150 - Ensuring Parity in MA for Audio-Only Telehealth Act of 2021 - Sen. Cortez Masto, Catherine [D-NV] - Medicaid telehealth coverage S. 151 - COVID HCBS Relief Act of 2021 - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 274 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Sen. Bennet, Michael F. [D-CO] - Medicaid & COVID-19 S. 340 - TREATS Act - Sen. Portman, Rob [R-OH] - telehealth - Medicare telehealth coverage S. 386 - Medicare-X Choice Act of 2021 - Sen. Bennet, Michael F. [D-CO] - Medicare-X S. 448 - Ensuring Kids Have Access to Medically Necessary Dental Care Act - Sen. Cardin, Benjamin L. [D-MD] - CHIP S. 653 - COMP Act - Sen. Portman, Rob [R-OH] - Medicare secondary payer rules S. 748 - Medicare Sequester Relief Act - Sen. Shaheen, Jeanne [D-NH] - Medicare sequestration S. 1180 - Choose Medicare Act - Sen. Merkley, Jeff [D-OR] - Medicare public insurance S. 1536 - Medical Nutrition Therapy Act of 2021 - Sen. Collins, Susan M. [R-ME] - coverage of medical foods S. 1727 - Medicaid Bump Act - Sen. Smith, Tina [D-MN] - Medicaid funding and behavioral health S. 1844 - Lowering Medicare Premiums and Prescription Drug Costs Act - Sen. Casey, Robert P., Jr. [D-PA] - Medicare premiums and drug costs S. 2111 - Audio-Only Telehealth for Emergencies Act - Sen. Kennedy, John [R-LA] - Medicare coverage of telehealth S. 2112 - EASE Behavioral Health Services Act - Sen. Kennedy, John [R-LA] - telehealth S. 2164 - Lower Costs, More Cures Act of 2021 - Sen. Crapo, Mike [R-ID] - Medicare and Medicaid reforms S. 2197 - Rural and Frontier Telehealth Expansion Act - Sen. Rosen, Jacky [D-NV] - FMAP & telehealth S. 2210 - Better Care Better Jobs Act - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 2236 - Expanding Health Care Options for Early Retirees Act - Sen. Brown, Sherrod [D-OH] - Medicare buy-in S. 2315 - Medicaid Saves Lives Act - Sen. Warnock, Raphael [D-GA] - Medicaid expansion S. 2618 - Medicare and Medicaid Dental, Vision, and Hearing Benefit Act of 2021 - Sen. Casey, Bob [D-PA] - Medicaid dental, vision, and hearing benefits S. 2639 - State Public Option Act - Sen. Schatz, Brian [D-HI] - Medicaid public option S. 2689 - Ensuring Medicaid Continuity for Children in Foster Care Act of 2021 - Sen. Burr, Richard [R-NC] - Medicaid-eligibility for children in foster care S. 3018 - Improving Seniors Timely Access to Care Act of 2021 - Sen. Marshall, Roger [R-KS] - prior authorization under MA S. 3061 - Medicare Mental Health Inpatient Equity Act of 2021 - Sen. Collins, Susan M. [R-ME] - inpatient psychiatric hospital services under Medicare S. 3193 - Expanded Telehealth Access Act - Sen. Daines, Steve [R-MT] - Medicare telehealth service providers S. 3332 - Let States Innovate Under Medicaid Act - Sen. Braun, Mike [R-IN] - Medicaid program promotion Regulatory Issues: Ongoing implementation issues for the Medicare Advantage (MA) and Medicare Part D prescription drug programs, including risk adjustment methodology, network adequacy and provider directories, encounter data and other data-related issues, and risk adjustment data validation (RADV) audit issues including proposed RADV regulation for MA; bidding and payment issues (including MA rate assumptions, MA coding intensity, MA Secondary Payer issues, Part D reinsurance, Part D low income subsidies, Part D direct and indirect remuneration (DIR), and audits); calendar year 2022 policy and technical regulation for MA and Part D; Part D reform, out of pocket limits; issues related to Medicare for All, Medicare buy-in, reduced Medicare eligibility age, and public option; issues relating to 2022 Rate Notice; issues related to coverage in non-Medicaid Expansion States (e.g., Gap Population); issues related to expanded Medicare fee for service benefits (dental, hearing and vision); issues related to Medicaid coverage gap; potential Medicare NCD relating to monoclonal antibodies for treatment of Alzheimers disease; Executive Orders relating to international pricing, Part D rebates, insulin costs, and importation; issues related to MLTSS; issues related to removal of safe harbor protection for rebates; issues relating to COVID-19, including testing and vaccines; issues related to health equity; issues related to vaccination; issues related to audio-only telehealth; issues related to addressing the social determinants of health, including housing, transportation, nutrition, educational opportunities, and MA supplemental benefits; issues related to Medicaid presumptive eligibility and continuous eligibility; issues relating to Medicaid best price; in-home health risk assessments; Medicare Medical Loss Ratio issues; issues related to changes to prior authorization regulations, electronic documentation, and related issues; issues relating to sequestration under the Medicare Advantage and Part D programs; implications of physician fee schedule on MA; application process, audits to evaluate compliance with MA and Part D program rules, benefit design rules, enrollment rules, requirements for notice and denial forms, marketing materials review and approval, marketing activities, including conduct and compensation of brokers and agents and plan sponsor marketing staff; measurement and oversight of plan performance including Special Needs Plans (SNPs); quality measures, grievance and appeals processes, fraud and abuse compliance including training; contracting issues for Dual Eligible SNPs; Federal preemption of State authority under MA and Part D programs, Part D prescription drug event data reporting, Part D formulary rules, Part D pharmacy access standards, Part D coverage gap discount program, including employer group waiver plan (EGWP) issues, and other operational issues; issues raised by Part D coverage of new specialty drugs, the Part D non-interference policy and related issues (e.g., preferred pharmacy and any willing pharmacy requirements, standards for network pharmacy reimbursement, and policies regarding sponsor negotiation of pharmacy price concessions); issues related to the international price index; issues related to child and maternal health; issues related to Medicaid supplemental and disproportionate share hospital (DSH) funding; issues related to Medicaid funding for territories; issues related to medical management; issues relating to MA supplemental benefits; Medication Therapy Management Program requirements and the Center for Medicare and Medicaid Innovation (CMMI) Demonstration; MA EGWP issues; CMMI's value based payment models; Part D requirements for offering basic and enhanced alternative plans; MA and Part D systems issues affecting enrollment and disenrollment processing and payment and other operational issues; issues relating to MA and Part D Star Rating system including measures, the methodology for calculating ratings, and the role of the ratings for payment purposes; functionality of the Medicare Personal Plan Finder and Drug Plan Finder; National Medicare Education Program; Medicare demonstration program on performance-based payments for physician groups; physician quality reporting initiative; issues relating to Medicare coverage policy and national coverage decisions; issues relating to MACRA, including implications for MA and Part D plans; Medicare/Medicaid integration for dual eligibles, including implementation of the Capitated Financial Alignment Demonstration and related issues (e.g., quality ratings); Medicaid managed care regulations and policies, including CMS's substantial revisions to the managed care regulations, mental health parity rules, the Medicaid managed care actuarial soundness standard, quality oversight, Medicaid and CHIP Payment and Access Commission (MACPAC), grievance and appeals processes, fraud and abuse compliance, beneficiary information requirements, treatment of Medicaid health plan member hospital days in the upper payment limit calculation; policies affecting State Medicaid funding, including block grants, the calculation of the federal medical assistance (federal matching) percentage (FMAP), and intergovernmental transfers (IGTs); coordination of benefits with state Medicaid programs; Medicaid prescription drug cost issues affecting Medicaid health plans including issues raised by Medicaid coverage of new specialty drugs; health plan-related Childrens Health Insurance Program (CHIP) issues, including eligibility and outreach issues and CHIP reauthorization; implementation of Medicaid changes made in Deficit Reduction Act of 2005, including Medicaid managed care organization provider tax issues; standards for electronic prescribing; implementation of Medicaid changes of interest to Medicaid health plans made in the Affordable Care Act (ACA) including Medicaid expansion, the managed care organization (MCO) prescription drug rebate provisions, minimum payments to primary care providers (PCPs), interactions between the Medicaid program and health insurance exchanges, and Medicaid and CHIP maintenance of effort (MOE) requirements; implications of the health insurer fee for Medicaid health plans; issues related to Medicaid Managed long-term care including home and community-based waiver services (HCBS); expanding the availability of Medicare Advantage and Medicaid health plan telemedicine programs; implications of the new non-discrimination rules for health plans participating in public programs; issues related to Medigap coverage; issues related to business continuity in relation to pandemics or natural events (e.g., hurricane, tornado, etc.); cybersecurity; provider directories; value-based insurance design models; Part D prescriber enrollment requirements; Part D recovery audit contractor programs; issues relating to enrollment of beneficiaries with ESRD into MA plans; issues related to health homes for children with medically complex conditions; socioeconomic status impacts on star ratings related to MA and Part D programs; and other issues relating to health care reform implementation.

Client expense: $2,630,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office

H.R. 3894 - CARING for Social Determinants Medicaid and Social Determinants of Health (SDOH) legislation. S. 1798/H.R. 1397 - TIKES Act. H.R. 3894 - CARING for Social Determinants Act of 2021. S. 2112/H.R. 4036 - The Enhance Access to Support Essential Behavior Health Services (EASE) Act. S. 1554/H.R. 3089 - Accelerating Kids' Access to Care Act. H.R. 2503 - Social Determinants Accelerator Act of 2021. S. 1727/H.R. 3450 - The Medicaid BUMP Act.

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE

Medicaid and Social Determinants of Health (SDOH) legislation (proposal under development related to social determinants of health) S. 1798 and H.R.1397, TIKES Act H.R.3894, CARING for Social Determinants Act of 2021 S.2112 and H.R.4036, The Enhance Access to Support Essential Behavioral Health Services (EASE) Act S.1554 and H.R.3089, Accelerating Kids Access to Care Act H.R.6216, Sickle Cell Disease Comprehensive Care Act H.R.2503, Social Determinants Accelerator Act of 2021 S.1727 and H.R. 3450, The Medicaid BUMP Act

Client expense: $227,157 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Draft Legislation - IMD Medicaid (Napolitano) S. 586: NO PAIN Act H.R. 1551/S 584: Nutrition Counseling Aiding Recover for Eating Disorders Act H.R. 3450/S. 1727: Medicaid Bump Act H.R. 3447: Permanency for Audio Only Telehealth Act H.R. 4058: Telemental Health Care Access Act S. 2061: Telemental Health Care Access Act S. 2069: Excellence in Mental Health and Addiction Treatment Act H.R. 1738/S. 646: Stabilize Medicaid and CHIP Coverage Act S.285: Medicaid Reentry Act S.340: TREATS Act H.R. 1577/S. 596: Treat and Reduce Obesity Act H.R. 314: Medicare Sequester COVID Moratorium Act H.R 1868: To prevent across the board direct spending cuts S. 1512/H.R. 2903: CONNECT for Health Act H.R. 4480: Telehealth Coverage and Payment Parity Act S. 1798/H.R. 1398: TIKES Act Letter to CMS re: TN Medicaid proposed amendment (Coalition letter) H.R. 5674 / S. 3061: Medicare Mental Health Inpatient Equity Act H.R. 2503 Social Determinants Accelerator Act of 2021 Medicaid/Medicare/Private Insurance provisions in the Build Back Better Act S. 610, Public Law 117-71: Protecting Medicare and American Farmers from Sequester Cuts Act H.R. 4406 Supporting Medicaid in the U.S. Territories Act H.R. 341 Ensuring Telemental Health Expansion Act of 2021

Client expense: $300,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Indian Health Service, Justice, Dept of (DOJ), Natl Science Foundation (NSF), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), SENATE, Veterans Affairs, Dept of (VA), White House Office

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities. Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings. Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates. Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels. Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA. Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers. Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes. Joined advocacy coalition letter to Chairman Ron Wyden and Ranking Member Mike Crapo of the Senate Committee on Finance, encouraging full extension of federal mental health and substance use disorder parity protections to Medicare, all of Medicaid, and TRICARE. Sent Congressional letter recommending closer coordination among relevant federal agencies, greater integration between primary care and behavioral health reimbursement, and robust funding for the addiction treatment workforce-- such as the Addiction Medicine Fellowship Program. ASAM also expressed support for legislation to ensure state compliance with mental health and addiction parity law and codification of audio-video telehealth prescribing flexibilities for the treatment of substance use disorder. Finally, ASAM called on federal legislators to consider new and promising strategies like contingency management Advocated for addiction-related provisions in the Build Back Better Act (BBBA) that would increase access to comprehensive, high-quality addiction care in ways that reduce racial, ethnic, and economic disparities, and make important investments in the addiction medicine workforce. Sent letter to the FDA responding to their request for feedback in reevaluating the voluntary status of the Opioid Analgesics (OA) Risk Evaluation and Mitigation Strategy (REMS) program. Currently, FDA is considering extending the REMS program to become a mandatory course for all opioid prescribers. Urged against FDA making the REMS program mandatory for all opioid prescribers and identified other strategies to expand provider education more effectively. Primarily, ASAM emphasized the importance of the concurrent passage of the Medication Access and Training Expansion (MATE) Act (S 2235/HR 2067) and the Mainstreaming Addiction Treatment (MAT) Act (S 445/HR 1384). Advocated for the HR 6279, the Opioid Treatment Access Act that would allow for broader access to methadone for opioid use disorder, including through measured expansion of prescribing/pharmacy dispensing. Joined coalition letter urging reconsideration of the requirements in the Interim Final Rule (IFR), entitled Requirements Related to Surprise Billing; Part II, 86 Fed. Reg. 55,980 (Oct. 7, 2021), implementing the No Surprises Act (NSA) that directs Independent Dispute Resolution (IDR) entities to consider the qualifying payment amount (QPA) a rebuttable presumptive reasonable payment for out-of-network physicians engaging in the IDR process. Joined coalition letter urging inclusion of provisions in the Administration's budget request for FY 23 that expand the Administrations efforts to reduce tobacco use, which remains the leading preventable cause of death in the United States. Urged inclusion of the field of addiction medicine in reauthorizations of several SAMHSA programs as well as conveyed ways to improve clinician access to relevant addiction medicine education

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

H.R. 19 - Lower Costs, More Cures Act of 2021 - Rep. McMorris Rodgers, Cathy [R-WA-5] - Medicare and Medicaid reforms H.R. 56 - Patient Access to Medical Foods Act - Rep. Biggs, Andy [R-AZ-5] - coverage of medical foods H.R. 66 - CARING for Kids Act - Rep. Buchanan, Vern [R-FL-16] - CHIP extension H.R. 315 - Medicare Sequester COVID Moratorium Act - Rep. Schneider, Bradley Scott [D-IL-10] - Medicare Sequester H.R. 340 - Incentivizing Medicaid Expansion Act of 2021 - Rep. Veasey, Marc A. [D-TX-33] - Medicaid expansion H.R. 502 - Medicare Dental Benefit Act of 2021 - Rep. Barragan, Nanette Diaz [D-CA-44] - Medicare dental coverage H.R. 525 - COVID HCBS Relief Act of 2021 - Rep. Dingell, Debbie [D-MI-12] - HCBS H.R. 599 - Protecting Medicare Beneficiaries with Pre-Existing Conditions Act - Rep. Schneider, Bradley Scott [D-IL-10] - pre-existing conditions H.R. 722 - Ensuring Vaccination and Treatment Affordability Act - Rep. Pappas, Chris [D-NH-1] - cost-sharing for COVID-19 vaccines H.R. 918 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Rep. Cardenas, Tony [D-CA-29] - Medicaid & COVID-19 H.R. 955 - Medicaid Reentry Act of 2021 - Rep. Tonko, Paul [D-NY-20] - Medicaid coverage H.R. 975 - Ensuring Seniors Access to COVID Treatments Act - Rep. Casten, Sean [D-IL-6] - coverage of COVID-19 drugs H.R. 1227 - Medicare-X Choice Act of 2021 - Rep. Delgado, Antonio [D-NY-19] - Medicare-X H.R. 1495 - Jim Ramstad Legacy of Recovery Act - Rep. Emmer, Tom [R-MN-6] - Medicaid coverage for SUD H.R. 1717 - Protecting Married Seniors from Impoverishment Act of 2021 - Rep. Upton, Fred [R-MI-6] - HCBS and spousal impoverishment H.R. 1722 - Puerto Rico Health Care Fairness, Accountability, and Beneficiary Access Act of 2021 - Rep. Velazquez, Nydia M. [D-NY-7] - Medicaid for territories H.R. 1791 - CHIPP Act - Rep. Barragan, Nanette Diaz [D-CA-44] - CHIP extension H.R. 1795 - Expanded Coverage for Former Foster Youth Act - Rep. Bass, Karen [D-CA-37] - coverage for foster youth H.R. 1880 - To amend the Deficit Reduction Act of 2005 to make permanent the Money Follows the Person Rebalancing Demonstration - Rep. Dingell, Debbie [D-MI-12] - Money Follows the Person extension H.R. 1969 - Medicare Advantage Integrity Act - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - Medicare Advantage benchmark rates H.R. 1976 - Medicare for All Act of 2021 - Rep. Jayapal, Pramila [D-WA-7] - Medicare for All H.R. 1978 - Protecting Seniors Through Immunization Act of 2021 - Rep. Kuster, Ann M. [D-NH-2] - cost sharing for vaccines under Medicare part D H.R. 1999 - Protect Seniors and Cut Waste Act - Rep. Smith, Jason [R-MO-8] - sequester for Pay-As-You-Go H.R. 2166 - Ensuring Parity in MA and PACE for Audio-Only Telehealth Act of 2021 - Rep. Sewell, Terri A. [D-AL-7] - Medicare coverage of telehealth H.R. 2217 - Territory Federal Matching Requirement Equity Act of 2021 - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - FMAP for territories H.R. 2297 - MIND Act - Rep. Boyle, Brendan F. [D-PA-2] - Medicaid payment for services provided in institutions for mental diseases H.R. 2464 - More Help for Seniors Act of 2021 - Rep. Craig, Angie [D-MN-2] - Medicare prescription drug benefit H.R. 2881 - Medicare Buy-In and Health Care Stabilization Act of 2021 - Rep. Higgins, Brian [D-NY-26] - Medicare public insurance H.R. 3108 - Medical Nutrition Therapy Act of 2021 - Rep. Kelly, Robin L. [D-IL-2] - coverage of medical foods H.R. 3173 - Improving Seniors Timely Access to Care Act of 2021 - Rep. DelBene, Suzan K. [D-WA-1] - prior authorization H.R. 3447 - Permanency for Audio-Only Telehealth Act - Rep. Smith, Jason [R-MO-8] - Medicare telehealth coverage H.R. 3450 - Medicaid Bump Act - Rep. Tonko, Paul [D-NY-20] - Medicaid funding and behavioral health H.R. 3894 - CARING for Social Determinants Act of 2021- Rep. Blunt Rochester, Lisa [D-DE-At Large] - Medicaid and SDOH H.R. 3961 - COVER Now Act - Rep. Doggett, Lloyd [D-TX-35] - Medicaid expansion H.R. 4040 Advancing Telehealth Beyond COVID-19 Act of 2021- Rep. Cheney, Liz [R-WY-At Large] - Medicare telehealth coverage H.R. 4043 - Ensuring Patient Access to Critical Breakthrough Products Act of 2021 - Rep. DelBene, Suzan K. [D-WA-1] - Medicare coverage of breakthrough devices H.R. 4074 - Addressing Social Determinants in Medicare Advantage Act of 2021 - Rep. Bilirakis, Gus M. [R-FL-12] - Medicare Advantage supplemental benefits H.R. 4158 - Insulin Access for All Act of 2021 - Rep. Rush, Bobby L. [D-IL-1] - cost sharing for insulin H.R. 4187 - Medicare Vision Act of 2021 - Rep. Schrier, Kim [D-WA - Medicare vision coverage H.R. 4263 - Patient Parity Protection Act of 2021 - Rep. Gottheimer, Josh [D-NJ-5] - out-of-network services H.R. 4311 - Medicare Dental, Vision, and Hearing Benefit Act of 2021 - Rep. Doggett, Lloyd [D-TX-35] - Medicare dental, vision, and hearing benefits H.R. 4406 - Supporting Medicaid in the U.S. Territories Act of 2021 - Rep. Soto, Darren [D-FL-9] - Medicaid support in U.S. territories H.R. 4439 - Medicaid Dental Benefit Act - Rep. Barragan, Nanette Diaz [D-CA-44] - Medicaid dental benefit H.R. 4640 - Close the Medigap Act of 2021 - Rep. Doggett, Lloyd [D-TX-35] - Medicare supplemental health insurance policies H.R. 4650 - Medicare Dental Coverage Act of 2021 - Rep. Kelly, Robin L. [D-IL-2] - Medicare dental benefit H.R. 4941 - PACE Part D Choice Act of 2021 - Rep. Blumenauer, Earl [D-OR-3] - prescription drug plans in the Medicare-only PACE program H.R. 4942 - BETTER Kidney Care Act - Rep. Blumenauer, Earl [D-OR-3] - demonstration program for Medicare enrollees with ESRD H.R. 4974 - State Public Option Act - Rep. Schrier, Kim [D-WA-8] - Medicaid public option H.R. 5099 - Lowering Medicare Premiums and Prescription Drug Costs Act - Rep. Schneider, Bradley Scott [D-IL-10] - Medicare cost-sharing benefits H.R. 5110 - Medicare Medically Necessary Dental Care Act of 2021 - Rep. Cohen, Steve [D-TN-9] - Medicare dental benefits H.R. 5165 - Improving Medicare Coverage Act - Rep. Jayapal, Pramila [D-WA-7] - Medicare eligibility age H.R. 5414 - Ensuring Medicaid Continuity for Children in Foster Care Act of 2021 - Rep. Bilirakis, Gus M. [R-FL-12] - Medicaid coverage for children in foster care H.R. 5425 - Protecting Rural Telehealth Access Act - Rep. O'Halleran, Tom [D-AZ-1] - Medicare telehealth services S. 97 - Medicare Dental Benefit Act of 2021 - Sen. Cardin, Benjamin L. [D-MD] - Medicare dental coverage S. 150 - Ensuring Parity in MA for Audio-Only Telehealth Act of 2021 - Sen. Cortez Masto, Catherine [D-NV] - Medicaid telehealth coverage S. 151 - COVID HCBS Relief Act of 2021 - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 274 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Sen. Bennet, Michael F. [D-CO] - Medicaid & COVID-19 S. 340 - TREATS Act - Sen. Portman, Rob [R-OH] - telehealth - Medicare telehealth coverage S. 386 - Medicare-X Choice Act of 2021 - Sen. Bennet, Michael F. [D-CO] - Medicare-X S. 448 - Ensuring Kids Have Access to Medically Necessary Dental Care Act - Sen. Cardin, Benjamin L. [D-MD] - CHIP S. 653 - COMP Act - Sen. Portman, Rob [R-OH] - Medicare secondary payer rules S. 748 - Medicare Sequester Relief Act - Sen. Shaheen, Jeanne [D-NH] - Medicare sequestration S. 1180 - Choose Medicare Act - Sen. Merkley, Jeff [D-OR] - Medicare public insurance S. 1536 - Medical Nutrition Therapy Act of 2021 - Sen. Collins, Susan M. [R-ME] - coverage of medical foods S. 1727 - Medicaid Bump Act - Sen. Smith, Tina [D-MN] - Medicaid funding and behavioral health S. 1844 - Lowering Medicare Premiums and Prescription Drug Costs Act - Sen. Casey, Robert P., Jr. [D-PA] - Medicare premiums and drug costs S. 2111 - Audio-Only Telehealth for Emergencies Act - Sen. Kennedy, John [R-LA] - Medicare coverage of telehealth S. 2112 - EASE Behavioral Health Services Act - Sen. Kennedy, John [R-LA] - telehealth S. 2164 - Lower Costs, More Cures Act of 2021 - Sen. Crapo, Mike [R-ID] - Medicare and Medicaid reforms S. 2197 - Rural and Frontier Telehealth Expansion Act - Sen. Rosen, Jacky [D-NV] - FMAP & telehealth S. 2210 - Better Care Better Jobs Act - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 2236 - Expanding Health Care Options for Early Retirees Act - Sen. Brown, Sherrod [D-OH] - Medicare buy-in S. 2315 - Medicaid Saves Lives Act - Sen. Warnock, Raphael [D-GA] - Medicaid expansion S. 2618 - Medicare and Medicaid Dental, Vision, and Hearing Benefit Act of 2021 - Sen. Casey, Bob [D-PA] - Medicaid dental, vision, and hearing benefits S. 2639 - State Public Option Act - Sen. Schatz, Brian [D-HI] - Medicaid public option S. 2689 - Ensuring Medicaid Continuity for Children in Foster Care Act of 2021 - Sen. Burr, Richard [R-NC] - Medicaid-eligibility for children in foster care Regulatory Issues: Ongoing implementation issues for the Medicare Advantage (MA) and Medicare Part D prescription drug programs, including risk adjustment methodology, network adequacy and provider directories, encounter data and other data-related issues, and risk adjustment data validation (RADV) audit issues including proposed RADV regulation for MA; bidding and payment issues (including MA rate assumptions, MA coding intensity, MA Secondary Payer issues, Part D reinsurance, Part D low income subsidies, Part D direct and indirect remuneration (DIR), and audits); calendar year 2022 policy and technical regulation for MA and Part D; Part D reform, out of pocket limits; issues related to Medicare for All, Medicare buy-in, reduced Medicare eligibility age, and public option; issues relating to 2022 Rate Notice; issues related to coverage in non-Medicaid Expansion States (e.g., Gap Population); issues related to expanded Medicare fee for service benefits (dental, hearing and vision); issues related to Medicaid coverage gap; potential Medicare NCD relating to monoclonal antibodies for treatment of Alzheimers disease; Executive Orders relating to international pricing, Part D rebates, insulin costs, and importation; issues related to MLTSS; issues related to removal of safe harbor protection for rebates; issues relating to COVID-19, including testing and vaccines; issues related to health equity; issues related to vaccination; issues related to audio-only telehealth; issues related to addressing the social determinants of health, including housing, transportation, nutrition, educational opportunities, and MA supplemental benefits; issues related to Medicaid presumptive eligibility and continuous eligibility; issues relating to Medicaid best price; in-home health risk assessments; Medicare Medical Loss Ratio issues; issues related to changes to prior authorization regulations, electronic documentation, and related issues; issues relating to sequestration under the Medicare Advantage and Part D programs; implications of physician fee schedule on MA; application process, audits to evaluate compliance with MA and Part D program rules, benefit design rules, enrollment rules, requirements for notice and denial forms, marketing materials review and approval, marketing activities, including conduct and compensation of brokers and agents and plan sponsor marketing staff; measurement and oversight of plan performance including Special Needs Plans (SNPs); quality measures, grievance and appeals processes, fraud and abuse compliance including training; contracting issues for Dual Eligible SNPs; Federal preemption of State authority under MA and Part D programs, Part D prescription drug event data reporting, Part D formulary rules, Part D pharmacy access standards, Part D coverage gap discount program, including employer group waiver plan (EGWP) issues, and other operational issues; issues raised by Part D coverage of new specialty drugs, the Part D non-interference policy and related issues (e.g., preferred pharmacy and any willing pharmacy requirements, standards for network pharmacy reimbursement, and policies regarding sponsor negotiation of pharmacy price concessions); issues related to the international price index; issues related to child and maternal health; issues related to Medicaid supplemental and disproportionate share hospital (DSH) funding; issues related to Medicaid funding for territories; issues related to medical management; issues relating to MA supplemental benefits; Medication Therapy Management Program requirements and the Center for Medicare and Medicaid Innovation (CMMI) Demonstration; MA EGWP issues; CMMI's value based payment models; Part D requirements for offering basic and enhanced alternative plans; MA and Part D systems issues affecting enrollment and disenrollment processing and payment and other operational issues; issues relating to MA and Part D Star Rating system including measures, the methodology for calculating ratings, and the role of the ratings for payment purposes; functionality of the Medicare Personal Plan Finder and Drug Plan Finder; National Medicare Education Program; Medicare demonstration program on performance-based payments for physician groups; physician quality reporting initiative; issues relating to Medicare coverage policy and national coverage decisions; issues relating to MACRA, including implications for MA and Part D plans; Medicare/Medicaid integration for dual eligibles, including implementation of the Capitated Financial Alignment Demonstration and related issues (e.g., quality ratings); Medicaid managed care regulations and policies, including CMS's substantial revisions to the managed care regulations, mental health parity rules, the Medicaid managed care actuarial soundness standard, quality oversight, Medicaid and CHIP Payment and Access Commission (MACPAC), grievance and appeals processes, fraud and abuse compliance, beneficiary information requirements, treatment of Medicaid health plan member hospital days in the upper payment limit calculation; policies affecting State Medicaid funding, including block grants, the calculation of the federal medical assistance (federal matching) percentage (FMAP), and intergovernmental transfers (IGTs); coordination of benefits with state Medicaid programs; Medicaid prescription drug cost issues affecting Medicaid health plans including issues raised by Medicaid coverage of new specialty drugs; health plan-related Childrens Health Insurance Program (CHIP) issues, including eligibility and outreach issues and CHIP reauthorization; implementation of Medicaid changes made in Deficit Reduction Act of 2005, including Medicaid managed care organization provider tax issues; standards for electronic prescribing; implementation of Medicaid changes of interest to Medicaid health plans made in the Affordable Care Act (ACA) including Medicaid expansion, the managed care organization (MCO) prescription drug rebate provisions, minimum payments to primary care providers (PCPs), interactions between the Medicaid program and health insurance exchanges, and Medicaid and CHIP maintenance of effort (MOE) requirements; implications of the health insurer fee for Medicaid health plans; issues related to Medicaid Managed long-term care including home and community-based waiver services (HCBS); expanding the availability of Medicare Advantage and Medicaid health plan telemedicine programs; implications of the new non-discrimination rules for health plans participating in public programs; issues related to Medigap coverage; issues related to business continuity in relation to pandemics or natural events (e.g., hurricane, tornado, etc.); cybersecurity; provider directories; value-based insurance design models; Part D prescriber enrollment requirements; Part D recovery audit contractor programs; issues relating to enrollment of beneficiaries with ESRD into MA plans; issues related to health homes for children with medically complex conditions; socioeconomic status impacts on star ratings related to MA and Part D programs; and other issues relating to health care reform implementation. *Add MACPAC to Agency List.

Client expense: $2,250,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Executive Office of the President (EOP), Federal Trade Commission (FTC), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office

S. 1512/H.R. 2903 - Connect for Health Act of 2021 - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth H.R. 366 - Protecting Access to Post-COVID-19 Telehealth Act of 2021 - provisions related to continuing the regulatory flexibilities provided during the Public Health Emergency S. 368/H.R. 1332 Telehealth Modernization Act - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth S. 2061 - Tele-mental Health Care Access Act of 2021 to repeal the in-person visit Medicare requirement for mental health services provided via telehealth H.R. 3589 - To provide a one-year delay of repayment of the Medicare Accelerated and Advance Payments Proposals to prevent future sequester cuts, reducing Medicare payments H.R. 3684, Infrastructure bill - provisions related to the Medicare sequester and funding for broadband H.R. 5376, "Build Back Better Act" - provisions related to health policy, Medicare, workforce and hospital emergency preparedness S. 1727/H.R. 3450 - Medicaid Bump Act - provisions related to providing an enhanced FMAP for behavioral health care services and to ensuring the increased payments supports the provision of service Home Hospital Care Model

Client expense: $60,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues regarding childrens health care coverage and access to care under Medicaid, CHIP, the Exchanges, and private insurance Issues related to implementation of aspects of childrens health coverage under Medicaid, CHIP, the Exchanges, and private insurance S. 1727/H.R. 345 - Medicaid Bump Act Issues regarding the implementation of the ACE Kids Act S.1544/H.R. 3089 - Accelerating Kids Access to Care Act Issues regarding childrens health included in Build Back Better Act H.R. 4934, the Childrens Mental Health Infrastructure Act, H.R. 4944, the Helping Kids Cope Act, H.R. 5035, Child Suicide Prevention and Lethal Means Safety Act, and issues regarding childrens mental health Issue regarding Medicaid supplemental payments reporting requirements H.R. 5131/S.2762, the Pediatric Access to Critical Healthcare (PATCH) Act, and issues regarding pediatric health care infrastructure and capacity Issues regarding the importance of Medicaid to military and veteran families FY 2022 Senate and House Labor-HHS appropriations provisions - Children's Hospitals Graduate Medical Education (CHGME) program funding Issues regarding Children's Hospitals Graduate Medical Education (CHGME) program appropriations Issues related to 340B Drug Pricing Program, prescription drug pricing, drug shortages, and pharmaceutical supply chain, including H.R. 4390, the PROTECT 340B Act of 2021 Issues regarding the passage and implementation of COVID-19 relief packages, increased FMAP funding, and the impact of COVID-19 on childrens hospitals, the pediatric supply chain, and pediatric residency programs Issues regarding COVID-19 vaccination efforts for children Issues regarding Emergency Temporary Standard (ETS) for workplace settings in health care settings Issues regarding surprise billing in health care S.168/H.R. 708 - Temporary Reciprocity to Ensure Access to Treatment (TREAT) Act H.R. 1397 - Telehealth Improvement for Kids Essential Services (TIKES) Act

Client expense: $790,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Defense, Dept of (DOD), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Occupational Safety & Health Administration (OSHA), SENATE

Issues regarding childrens health care coverage and access to care under Medicaid, CHIP, the Exchanges, and private insurance Issues related to implementation of aspects of childrens health coverage under Medicaid, CHIP, the Exchanges, and private insurance Issues regarding childrens health included in Build Back Better Act S. 1727/H.R. 345 - Medicaid Bump Act Issue regarding Medicaid supplemental payments reporting requirements Issues regarding the implementation of the ACE Kids Act S.1544/H.R. 3089 - Accelerating Kids Access to Care Act Issues regarding the importance of Medicaid to military and veteran families Issue regarding the passage and implementation of COVID-19 relief packages, increased FMAP funding, and the impact of COVID-19 on childrens hospitals, the pediatric supply chain, and pediatric residency programs. H.R. 1397 - Telehealth Improvement for Kids Essential Services (TIKES) Act

Client expense: $790,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Defense, Dept of (DOD), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Occupational Safety & Health Administration (OSHA), SENATE

Increase in Federal Medical Assistance Percentages; H.R. 955/S. 285 - Medicaid Reentry Act; H.R. 3450/S. 1727 - Medicaid Bump Act.

Client expense: Not reported · Firm income: $20,000

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

Advocated for Increased appropriations for HRSAs Substance Use Disorder Treatment and Recovery Loan Repayment Program. This program provides student loan repayment for addiction treatment professionals who commit to working in underserved or high-risk communities. Advocated for increased appropriations for HRSAs Addiction Medicine Fellowship Program. This Program provides grants to institutions with training opportunities for fellows in addiction medicine and addiction psychiatry who have demonstrated interest in providing addiction treatment in underserved communities Advocated for increased appropriations for HRSAs Integrated Substance Use Disorder Training Program. This program provides grants to expand the number of nurse practitioners, physician assistants, psychologists, and social workers trained to provide addiction and mental health services in underserved community-based settings that integrate primary care, mental health, and addiction services. Advocated for increased appropriations for federal initiatives that lead to a more diverse addiction treatment workforce, such as scholarships and loan repayment targeting underrepresented minority addiction medicine professionals, including SAMHSAs Minority Fellowship Program. Advocated for the alignment of coverage and payment policies in Medicare and Medicaid with evidence-based and nationally recognized addiction treatment and placement criteria and standards (e.g., The ASAM Criteria). This would include permanent modification to the Institutions for Mental Diseases (IMD) exclusion to allow federal Medicaid funds to serve individuals with SUDs in those residential and inpatient settings that are able to demonstrate that patient assessments, clinical services, level-of-care and length-of-stay recommendations are consistent with The ASAM Criteria and that evidence based medication management using Food and Drug Administration (FDA)-approved medications are available to patients in such settings Advocated for regulatory/sub-regulatory/application guidance that would require the use of evidence-based practices in the Substance Abuse Prevention and Treatment (SAPT) Block Grant, including requiring each grantee delivering SUD treatment services to provide access to all FDA-approved medications for SUDs treated by that grantee. Advocated for a requirement that SAPT, State Opioid Response Grant (SOR), and Rural Communities Opioid Response Program grantees that receive grant funds for the delivery of addiction treatment services should be limited to Medicaid providers in order to better integrate federal grant dollars and Medicaid funds and Administration support for increased oversight and improved mechanisms for ensuring that such funding does not supplant the consistent and scalable funding that Medicaid (or Medicare) provides. Advocated for S 2235/HR 2067 - Medication Access and Training Expansion (MATE) Act of 2021: This legislation would ensure most Drug Enforcement Agency (DEA) controlled medication prescribers have a baseline knowledge of how to identify, treat, and manage patients with SUD and would allow accredited health professional schools and residency programs to fulfill the training requirement through their own curricula, as well as provide them with resources to do so. Advocated for simultaneous passage of S 445/HR 1384 - Mainstreaming Addiction Treatment (MAT) Act, which would eliminate the requirement that practitioners apply for a separate waiver through the DEA to prescribe buprenorphine for addiction and eliminate the patient limits on buprenorphine prescribers. Advocated for S 285/HR 955 - the Medicaid Reentry Act: This legislation would allow for reestablishment of health insurance coverage under Medicaid for eligible individuals who are incarcerated, during the 30-day period preceding their release from jail or prison. Advocated for S 1821/HR 3514 - the Humane Correctional Health Care Act, which would repeal the inmate exclusion that bars the use of federal Medicaid matching funds from covering health care services in jails and prisons. Advocated for S1727/HR 3450 - The Medicaid Bump Act of 2021: This legislation would provide an enhanced Medicaid Federal Medical Assistance Percentage rate of 90 percent for State Medicaid spending on mental health and substance use disorder services in excess of 2019 levels. It would also require states to use the additional federal funds as a supplement to rather than a replacement for state funding levels, and to use the funds to increase the capacity, efficiency, and quality of behavioral health services, including through increasing provider reimbursement rates; Advocated for Section 9 of S. 1010 - the Turn the Tide Act - These provisions would increase Medicaid fees for addiction treatment services to at least Medicare levels; Advocated for HR 1364 - the Parity Enforcement Act: This legislation would expand the U.S. Department of Labors authority to hold health insurers and plan sponsors accountable for offering health plans that violate the Mental Health Parity and Addiction Equity Act (MHPAEA) of 2008 or for employing utilization review processes that prove more restrictive for mental health and addiction care than for other medical care in violation of the MHPAEA Advocated for S 340/HR 1674 - TREATS Act: This legislation would make permanent a new, audio-video, telehealth evaluation exception to the Ryan Haight Acts in-person exam requirement, which would allow clinicians to prescribe certain addiction treatment medications, like buprenorphine, to new patients through telehealth. It would also clarify Medicares continued ability, beyond the COVID-19 public health emergency, to reimburse for audio-only, SUD and mental health telehealth services after an in-person or telehealth evaluation. Provided technical assistance regarding a possible audio-only exception to Ryan Haight for initiation of buprenorphine for OUD. Advocated for HR 3925 Reducing Barriers to Substance Use Treatment Act: This legislation would prohibit states receiving Federal funding for medication-assisted treatment under Medicaid from imposing utilization control policies or procedures (as defined by the Secretary of the Department of Health and Human Services), including prior authorization requirements, with respect to such treatment. Advocated for the Administration to support continuous collaboration and sharing of information between the Centers for Medicare & Medicaid Services (CMS) and SAMHSA, which should include new, strategic efforts to provide technical assistance funds to states to support their operation of CMS-approved Section 1115 SUD waivers related to the IMD exclusion and to enhance their care delivery systems for patients. Advocated for the Administration to increase promotion to State Medicaid programs of adoption of two, new sets of bundled G codes to increase or establish payment for outpatient opioid use disorder (OUD) treatment and treatment services provided by opioid treatment programs (OTPs) at Medicare payment rates or higher. Advocated for the Administration to support the following regulatory and administrative efforts that would reduce barriers to accessing addiction treatment: Creation of safe-harbor provisions to the Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Civil, as they may be applied to the implementation of contingency management (CM) for the treatment of addiction. Approval of a prescription to over the counter (OTC) switch for at least one naloxone product. This change would save lives and reduce existing barriers that prevent access to this critical medication; Regulatory changes that would allow Medicaid reimbursement for the room and board portion of SUD residential levels of care that meet level of care standards set forth in The ASAM Criteria; Regulatory (or legislative) changes that would create a special registration exemption for jails, prisons, and their authorized personnel to prescribe and otherwise dispense controlled medications for initiation, maintenance or withdrawal management of OUD that is significantly less burdensome than currently applicable registration requirements in the Controlled Substances Act and related regulations. Such special registration should not limit the number of persons who are detained or incarcerated who can be treated with such medications by a qualified practitioner; Regulatory (or legislative) changes that would allow pharmacy dispensing and/or administration of methadone that has been prescribed by a legally authorized prescriber of controlled medications who is affiliated with an OTP or is a board-certified addiction specialist physician; Regulatory (or legislative) changes that would make permanent the opioid treatment program (OTP) flexibilities, including the methadone unsupervised dosing flexibilities, implemented during the COVID-19 Public Health Emergency while continuing study of the impact of these flexibilities; Assessment of current opioid order systems and monitoring programs to more fully understand the potential negative implications for patient access to buprenorphine at pharmacies and other controlled substance medications used to treat OUD; ; In the absence of Congressional action to eliminate the x-waiver, efforts to increase the DATA 2000 waiver patient limit -- aka, the applicable number; Issuance of regulations relating to a special registration for telemedicine, as was directed in Section 3232 of the SUPPORT Act of 2018. Advocated for the S.834/H.R.2256 Resident Physician Shortage Reduction Act, which would increase the number of Medicare GME slots by 14,000 over 7 years, including its inclusion in the next reconciliation package Advocated for House Resolution 349, which would support the goals of Overdose Awareness Day by lowering the United States flag to halfstaff on all Federal buildings on August 31st of each year. Advocated for the Support, Treatment, and Overdose Prevention of (S.T.O.P) Fentanyl Act of 2021 (H.R. 2366 / S. 1457). This legislation would expand fentanyl research and education, enhance overdose prevention and access to substance use disorder (SUD) treatment, and provide critical public health data and additional training support for various stakeholders. Advocated for changes to a draft opioid treatment program bill to make permanent certain COVID-19 flexibilities allowed to states for unsupervised doses, as well as "time in treatment" regulatory changes and to permit pharmacy dispensing of methadone for opioid use disorder treatment for certain experienced cohorts of prescribers Submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) outlining suggested improvements to the proposed Physician Payment Schedule for calendar year (CY) 2022. Among other recommendations, ASAM urged that CMS work with Congress to avoid a 2.5% cut in reimbursements for addiction medicine (ADM), finalize coding and payment rules for take-home naloxone nasal spray, and extend audio-only flexibility for opioid treatment programs (OTPs) to furnish therapy and counseling payments for substance use disorder (SUD). Advocated for the inclusion of enhanced mental health and substance use disorder (SUD) parity enforcement within the Senates version of the budget reconciliation proposal. These enhanced enforcement measures would authorize the Department of Labor to assess civil monetary penalties against insurers that violate the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008. Supported $195 million over five years to the Employee Benefits Security Administration for enforcement. Advocated for the Moms Matter Act (H.R. 909). The Moms Matter Act is a bipartisan bill that would increase federal funding for culturally congruent, community-based mental and behavior health programs. Advocated for H.R 1693 / S. 79, the Eliminating a Quantifiably Unjust Application of the Law Act. This legislation would eliminate the federal crack and powder cocaine sentencing disparity and apply it retroactively to those already convicted or sentenced. Supported nomination of Dr. Rahul Gupta to lead the Office of National Drug Control Policy (ONDCP), a critical position for coordinating the nations drug policy and response to the nations drug addiction and overdose crisis. Supported the Excellence in Mental Health and Addiction Treatment Expansion Act (S. 2069/H.R. 4323). This legislation would allow for every state and territory the ability to join the Certified Community Behavioral Health Clinic (CCBHC) demonstration and would authorize investments in the model for current and prospective CCBHCs. Supported implemented recommendations regarding the CARES Acts amendment of 42 CFR Part 2 to advance further alignment of 42 CFR Part 2 (Part 2) with the Health Insurance Portability and Accountability Act (HIPAA) for the purposes of treatment, payment, and health care operations (TPO). Advocated for H.R. 2786/ S. 1314, the Tobacco Tax Equity Act of 2021, which would increase the federal excise tax on cigarettes and set federal tax rates for other tobacco products at an equivalent level. Supported the tobacco tax provisions included in the portion of the Build Back Better Act that was approved by the Ways and Means Committee Advocated for passage of the Advancing FASD Research, Services, and Prevention Act (S.2238 and H.R.4151), known as the FASD Respect Act. The legislation would in part reauthorize and strengthen existing federal FASD programs at NIAAA, CDC, and HRSA, and for the first time calls for long-neglected, meaningful support for individuals and families living with FASD. Supported H.R.4244 - STOP Stigma Act, which would make amendments to the names of certain agencies to help end the stigmatization of substance use disorder, and for other purposes. Supported the National Committee on Vital and Health Statistics (NCVHS) efforts to enhance the exchange of clinical and administrative data through their recommendations to the Secretary but highlighted the important role of the Current Procedural Terminology (CPT) code set as serving the needs of a data-driven health system by allowing physicians, patients, researchers, medical groups, allied health care professionals, health systems, hospitals, medical coders, accreditation organizations, payers, and health information technology professionals to easily exchange data on the medical services and procedures provided to patients. Supported draft legislation that would amend the Controlled Substances Act to increase the number of days before which certain controlled substances for maintenance or detoxification treatment must be administered, and for other purposes.

Client expense: $70,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Drug Enforcement Administration (DEA), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Office of Natl Drug Control Policy (NDCP), SENATE, Substance Abuse & Mental Health Services Administration (SAMHSA)

H. Res. 349 - In support the goals of Overdose Awareness Day by lowering the United States flag to half-staff on all Federal buildings on August 31st of each year H.Res 538 - Bebe Moore Campbell BIPOC Mental Health Awareness Month H.R. 586/S. 1543- The STANDUP Act H.R. 588 - Stopping the Mental Health Pandemic Act H.R. 593 - Coronavirus Mental Health and Addiction Assistance Act of 2021 H.R. 654/S. 26 - Drug-Free Communities Pandemic Relief Act H.R. 666/ S. 162 - the Anti-Racism in Public Health Act H.R. 721/S. 1841 - Mental Health Services for Students Act H.R. 909/S. 484 - Moms Matter Act H.R. 912 - American Indian and Alaska Native Veterans Mental Health Act H.R. 925/S. 327 - Data to Save Moms Act H.R. 955/S. 285 - Medicaid Reentry Act H.R. 959/ S. 346 - the Black Maternal Health Momnibus Act H.R. 1025 - Kids Access to Primary Care Act of 2021 H.R. 1195 - the Workplace Violence Prevention for Health Care and Social Service Workers Act H.R. 1205/S. 2157 - Improving Mental Health Access from the Emergency Department Act H.R. 1324/S. 467 - Effective Suicide Screening and Assessment in the Emergency Department Act H.R. 1331 - the Strengthening Mental Health Supports for BIPOC Communities Act H.R. 1400 - the COVID-19 Health Disparities Action Act of 2021 H.R. 1475/S. 1795 - Pursuing Equity in Mental Health Act H.R. 1480 - Helping Emergency Responders Overcome (HERO) Act H.R. 1551/S.584 - Nutrition CARE Act H.R. 1554 - grants for community-based mental health and substance use disorder services H.R. 1587/S. 1731 - Medicare Audiologist Access and Services Act of 2021 H.R. 1667/S. 610 - Dr. Lorna Breen Health Care Provider Protection Act H.R. 1716/ S. 631 - the Covid-19 Mental Health Research Act H.R. 1738/S. 646 - Stabilize Medicaid and CHIP Act H.R. 2051/S. 854 - Methamphetamine Response Act of 2021 H.R. 2161/S. 971 - CAMRA Act Support Letter H.R. 2255/S. 1024 -the Healthcare Workforce Resilience Act H.R. 2256/S. 834 - the Resident Physician Shortage Reduction Act of 2021 H.R. 2264/ S. 660 - the Telemental Health Improvement Act H.R. 2364 - Synthetic Opioid Danger Awareness Act H.R. 2379 - State Opioid Response Grant Authorization Act of 2021 H.R. 2503 - Social Determinants Accelerator Act of 2021 H.R. 2591/S.957 - DUMP Opioids Act H.R. 2611 - Increasing Behavioral Health Treatment Act H.R. 2767/ S. 2144 - the Promoting Effective and Empowering Recovery Services (PEERS) in Medicare Act H.R. 2862 -the Campaign to Prevent Suicide Act H.R. 2874/S. 1576 - Behavioral Health Coverage Transparency Act of 2021 H.R. 2903/S. 1512 - the CONNECT for Health Act of 2021 H.R. 2929/ S. 157 - The Virtual Peer Support Act H.R. 2955 -the Suicide Prevention Act H.R. 2973 - the Strengthening Americas Families Act (SAFA) of 2021 H.R. 2981, the Suicide Prevention Lifeline Improvement Act of 2021 H.R. 3150/S. 1578 - the Mental Health Professionals Workforce Shortage Loan Repayment Act of 2021 H.R. 3407/S. 411 - Mothers and Offspring Mortality and Morbidity Awareness Act MOMMAs Act H.R. 3441 - The Substance Use Disorder Workforce Act of 2021 H.R. 3447 - Permanency for Audio-Only Telehealth Act H.R. 3450/S. 1727, the Medicaid Bump Act H.R. 3541/S. 1810 - Conrad State 30 and Physician Access Reauthorization Act H.R.3467 - the Improving Data Collection for Adverse Childhood Experiences Act H.R. 3753/S. 1962 - Parity Implementation Assistance Act H.R. 3755/S. 1975 - the Womens Health Protection Act H.R. 3894 - Collecting and Analyzing Resources Integral and Necessary for Guidance (CARING) for Social Determinants Act of 2021 H.R. 3931 / S. 2069 - Excellence in Mental Health and Addiction Treatment Expansion Act H.R. 4026 - Social Determinants of Health Data Analysis Act of 2021 H.R. 4058/S. 2061- The Telemental Health Care Access Act H.R. 4146 - Therapeutic Fraud Prevention Act of 2021 H.R. 4151/S. 2238 - FASD Respect Act H.R.4217 - TRIUMPH for New Moms Act of 2021 H.R. 4305, the Crisis Care Enhancement Act H.R. 4351/S. 981 - CARA 3.0 Act of 2021 H.R. 4387/S. 1675 - Maternal Health Quality Improvement Act of 2021 H.R. 4406 - Supporting Medicaid in the U.S. Territories Act of 2021 H.R. 4510 - Health Enterprise Zones Act of 2021 H.R. 4554 - Care That's Fair Act H.R. 4631- Protecting Our Students by Terminating Graduate Rates that Add to Debt (POST GRAD) Act H.R. 4649 - Supporting Underserved Populations by Placing Our Resources in Trusts (SUPPORT) for Mental Health Act H.R. 4770- Evaluating Disparities and Outcomes of Telehealth During the COVID-19 Emergency Act of 2021 (EDOT Act) H.R. 4943 - the Childrens Mental Health Infrastructure Act of 2021 H.R. 4944, the Helping Kids Cope Act of 2021 H.R. 4970 - Rural Medical Residency Expansion Act of 2021 H.R. 5035 - Child Suicide Prevention and Lethal Means Safety Act H.R. 5218 - Collaborate in an Orderly and Cohesive Manner Act H.R. 5224 - Preventing Overdoses and Saving Lives Act of 2021 S. 674 - Public Health Infrastructure Saves Lives Act S. 1024 - Healthcare Workforce Resilience Act S. 1902 - Behavioral Health Crisis Services Expansion Act S. 2086/ - Resilience Investment, Support, and Expansion from Trauma Act (RISE from Trauma Act) (Bill # TBD) - LAI Buprenorphine Access Act (No legislation) Amend Section 1834(m) of the Social Security Act to ensure that the Secretary has the tools to transition following the end of the public health emergency and ensure telehealth is regulated the same as in-person services.    (No legislation)_Retain the 3.75% increase to conversion factor for FY 22 and 23 in the MPFS

Client expense: $236,825 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Labor, Dept of (DOL), Office of Management & Budget (OMB), SENATE, Veterans Affairs, Dept of (VA)

Draft Legislation - IMD Medicaid (Napolitano) S. 586: NO PAIN Act H.R. 1551/S 584: Nutrition Counseling Aiding Recover for Eating Disorders Act H.R. 3450/S. 1727: Medicaid Bump Act H.R. 3447: Permanency for Audio Only Telehealth Act H.R. 4058: Telemental Health Care Access Act S. 2061: Telemental Health Care Access Act S. 2069: Excellence in Mental Health and Addiction Treatment Act H.R. 1738/S. 646: Stabilize Medicaid and CHIP Coverage Act S.285: Medicaid Reentry Act S.340: TREATS Act H.R. 1577/S. 596: Treat and Reduce Obesity Act H.R. 314: Medicare Sequester COVID Moratorium Act H.R 1868: To prevent across the board direct spending cuts S. 1512/H.R. 2903: CONNECT for Health Act H.R. 4480: Telehealth Coverage and Payment Parity Act S. 1798/H.R. 1398: TIKES Act Letter to CMS re: TN Medicaid proposed amendment (Coalition letter)

Client expense: $220,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Defense, Dept of (DOD), Education, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Health Resources & Services Administration (HRSA), Indian Health Service, Natl Science Foundation (NSF), Office of Management & Budget (OMB), Office of Science & Technology Policy (OSTP), SENATE, Veterans Affairs, Dept of (VA), White House Office

S. 1512 - Connect for Health Act of 2021 - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth H.R. 366 - Protecting Access to Post-COVID-19 Telehealth Act of 2021 - provisions related to continuing the regulatory flexibilities provided during the Public Health Emergency S. 368/H.R. 1332 Telehealth Modernization Act - provisions related to reducing barriers to Medicare coverage for telehealth services and to promote expansion of telehealth S. 2061 - Tele-mental Health Care Access Act of 2021 to repeal the in-person visit Medicare requirement for mental health services provided via telehealth H.R. 3589 - To provide a one-year delay of repayment of the Medicare Accelerated and Advance Payments H.R. 1868, prohibition the sequester's 2% cut to Medicare provider payments from going to effect during 2021 Proposals to prevent future sequester cuts, including reductions in Medicare payments S. 1727/H.R. 3450 - Medicaid Bump Act - provisions related to providing an enhanced FMAP for behavioral health care services and to ensuring the increased payments supports the provision of service Home Hospital Care Model

Client expense: $60,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 19 - Lower Costs, More Cures Act of 2021 - Rep. McMorris Rodgers, Cathy [R-WA-5] - Medicare and Medicaid reforms H.R. 56 - Patient Access to Medical Foods Act - Rep. Biggs, Andy [R-AZ-5] - coverage of medical foods H.R. 66 - CARING for Kids Act - Rep. Buchanan, Vern [R-FL-16] - CHIP extension H.R. 315 - Medicare Sequester COVID Moratorium Act - Rep. Schneider, Bradley Scott [D-IL-10] - Medicare Sequester H.R. 340 - Incentivizing Medicaid Expansion Act of 2021 - Rep. Veasey, Marc A. [D-TX-33] - Medicaid expansion H.R. 502 - Medicare Dental Benefit Act of 2021 - Rep. Barragan, Nanette Diaz [D-CA-44] - Medicare dental coverage H.R. 525 - COVID HCBS Relief Act of 2021 - Rep. Dingell, Debbie [D-MI-12] - HCBS H.R. 599 - Protecting Medicare Beneficiaries with Pre-Existing Conditions Act - Rep. Schneider, Bradley Scott [D-IL-10] - pre-existing conditions H.R. 722 - Ensuring Vaccination and Treatment Affordability Act - Rep. Pappas, Chris [D-NH-1] - cost-sharing for COVID-19 vaccines H.R. 918 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Rep. Cardenas, Tony [D-CA-29] - Medicaid & COVID-19 H.R. 955 - Medicaid Reentry Act of 2021 - Rep. Tonko, Paul [D-NY-20] - Medicaid coverage H.R. 975 - Ensuring Seniors Access to COVID Treatments Act - Rep. Casten, Sean [D-IL-6] - coverage of COVID-19 drugs H.R. 1167 - Advancing Enrollment and Reducing Drug Costs Act of 2021 - Rep. Pappas, Chris [D-NH-1] - Medicare prescription drug benefit H.R. 1227 - Medicare-X Choice Act of 2021 - Rep. Delgado, Antonio [D-NY-19] - Medicare-X H.R. 1495 - To amend title XIX of the Social Security Act to provide coverage under the Medicaid program for services for the treatment of psychiatric or substance use disorders furnished to certain individuals in an institution for mental diseases, and for other purposes - Rep. Emmer, Tom [R-MN-6] - Medicaid coverage for SUD H.R. 1717 - To amend title XIX of the Social Security Act to make permanent the protections under Medicaid for recipients of home and community-based services against spousal impoverishment - Rep. Upton, Fred [R-MI-6] - HCBS and spousal impoverishment H.R. 1722 - To amend titles XI and XIX of the Social Security Act to stabilize the Medicaid program in Puerto Rico - Rep. Velazquez, Nydia M. [D-NY-7] - Medicaid for territories H.R. 1791 - To amend title XXI of the Social Security Act to permanently extend the Children's Health Insurance Program, and for other purposes - Rep. Barragan, Nanette Diaz [D-CA-44] - CHIP extension H.R. 1795 - To amend title XIX of the Social Security Act to ensure health insurance coverage continuity for former foster youth - Rep. Bass, Karen [D-CA-37] - coverage for foster youth H.R. 1880 - To amend the Deficit Reduction Act of 2005 to make permanent the Money Follows the Person Rebalancing Demonstration - Rep. Dingell, Debbie [D-MI-12] - Money Follows the Person extension H.R. 1969 - To amend title XVIII of the Social Security Act to address disparity in Medicare Advantage benchmark rates for regions with low Medicare fee-for-service penetration - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - Medicare Advantage benchmark rates H.R. 1976 - To establish an improved Medicare for All national health insurance program - Rep. Jayapal, Pramila [D-WA-7] - Medicare for All H.R. 1978 - To amend title XVIII of the Social Security Act to provide information regarding vaccines for seniors as part of the Medicare & You handbook and to ensure that the treatment of cost sharing for vaccines under Medicare part D is consistent with the treatment of vaccines under Medicare part B, and for other purposes - Rep. Kuster, Ann M. [D-NH-2] - cost sharing for vaccines under Medicare part D H.R. 1999 - To delay and offset the sequester under the Statutory Pay-As-You-Go Act of 2010 as a result of the enactment of the American Rescue Plan Act of 2021, and for other purpose - Rep. Smith, Jason [R-MO-8] - sequester for Pay-As-You-Go H.R. 2166 - Ensuring Parity in MA and PACE for Audio-Only Telehealth Act of 2021 - Rep. Sewell, Terri A. [D-AL-7] - Medicare coverage of telehealth H.R. 2217 - Territory Federal Matching Requirement Equity Act of 2021 - Resident Commissioner Gonzalez-Colon, Jenniffer [R-PR-At Large] - FMAP for territories H.R. 2297 - MIND Act - Rep. Boyle, Brendan F. [D-PA-2] - Medicaid payment for services provided in institutions for mental diseases H.R. 2464 - More Help for Seniors Act of 2021 - Rep. Craig, Angie [D-MN-2] - Medicare prescription drug benefit H.R. 2881 - Medicare Buy-In and Health Care Stabilization Act of 2021 - Rep. Higgins, Brian [D-NY-26] - Medicare public insurance H.R. 3108 - Medical Nutrition Therapy Act of 2021 - Rep. Kelly, Robin L. [D-IL-2] - coverage of medical foods H.R. 3173 - Improving Seniors Timely Access to Care Act of 2021 - Rep. DelBene, Suzan K. [D-WA-1] - prior authorization H.R. 3447 - To amend title XVIII of the Social Security Act to expand accessibility to certain telehealth services under the Medicare program - Rep. Smith, Jason [R-MO-8] - Medicare telehealth coverage H.R. 3450 - Medicaid Bump Act - Rep. Tonko, Paul [D-NY-20] - Medicaid funding and behavioral health H.R. 3894 - To require the Secretary of Health and Human Services to issue and disseminate guidance to States to clarify strategies to address social determinants of health under the Medicaid program and the Children's Health Insurance Program - Rep. Blunt Rochester, Lisa [D-DE-At Large] - Medicaid and SDOH H.R. 3961 - To amend title XIX of the Social Security Act to provide for a demonstration project under the Medicaid program for political subdivisions of States to provide medical assistance for the expansion population under such program - Rep. Doggett, Lloyd [D-TX-35] - Medicaid expansion H.R. 4040 - To amend title XVIII of the Social Security Act to extend telehealth flexibilities under the Medicare program - Rep. Cheney, Liz [R-WY-At Large] - Medicare telehealth coverage H.R. 4043 - To amend title XVIII of the Social Security Act to ensure prompt coverage of breakthrough devices under the Medicare program - Rep. DelBene, Suzan K. [D-WA-1] - Medicare coverage of breakthrough devices H.R. 4074 - To amend title XVIII of the Social Security Act to expand the availability of supplemental benefits to certain Medicare Advantage enrollees - Rep. Bilirakis, Gus M. [R-FL-12] - Medicare Advantage supplemental benefits H.R. 4158 - To amend titles XVIII and XIX of the Social Security Act to eliminate cost sharing with respect to coverage of insulin as a covered part D drug under the Medicare program or as a covered outpatient drug under the Medicaid program - Rep. Rush, Bobby L. [D-IL-1] - cost sharing for insulin H.R. 4187 - To amend title XVIII of the Social Security Act to provide coverage for certain vision items and services under part B of the Medicare program - Rep. Schrier, Kim [D-WA] - Medicare vision coverage H.R. 4263 - To amend title XVIII of the Social Security Act to provide for an exception to the definition of an off-campus outpatient department of a provider under the Medicare program for certain departments of a provider if such provider was forced to relocate its campus - Rep. Gottheimer, Josh [D-NJ-5] - out-of-network services S. 97 - Medicare Dental Benefit Act of 2021 - Sen. Cardin, Benjamin L. [D-MD] - Medicare dental coverage S. 150 - Ensuring Parity in MA for Audio-Only Telehealth Act of 2021 - Sen. Cortez Masto, Catherine [D-NV] - Medicaid telehealth coverage S. 151 - COVID HCBS Relief Act of 2021 - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 274 - Stronger Medicaid Response to the COVID-19 Pandemic Act - Sen. Bennet, Michael F. [D-CO] - Medicaid & COVID-19 S. 340 - TREATS Act - Sen. Portman, Rob [R-OH] - telehealth - Medicare telehealth coverage S. 386 - Medicare-X Choice Act of 2021 - Sen. Bennet, Michael F. [D-CO] - Medicare-X S. 448 - Ensuring Kids Have Access to Medically Necessary Dental Care Act - Sen. Cardin, Benjamin L. [D-MD] - CHIP S. 653 - A bill to amend title XVIII of the Social Security Act to provide for the application of Medicare secondary payer rules to certain workers' compensation settlement agreements and qualified Medicare set-aside provisions - Sen. Portman, Rob [R-OH] - Medicare secondary payer rules S. 748 - A bill to provide for an extension of the temporary suspension of Medicare sequestration during the COVID-19 public health emergency - Sen. Shaheen, Jeanne [D-NH] - Medicare sequestration S. 1180 - Choose Medicare Act - Sen. Merkley, Jeff [D-OR] - Medicare public insurance S. 1536 - Medical Nutrition Therapy Act of 2021 - Sen. Collins, Susan M. [R-ME] - coverage of medical foods S. 1727 - Medicaid Bump Act - Sen. Smith, Tina [D-MN] - Medicaid funding and behavioral health S. 1844 - Lowering Medicare Premiums and Prescription Drug Costs Act - Sen. Casey, Robert P., Jr. [D-PA] - Medicare premiums and drug costs S. 2111 - A bill to amend title XVIII of the Social Security Act to provide for the waiver of certain telehealth requirements to permit reimbursement for audio-only telehealth services under the Medicare program during emergency declarations - Sen. Kennedy, John [R-LA] - Medicare coverage of telehealth S. 2112 - A bill to amend title XVIII of the Social Security Act and the SUPPORT for Patients and Communities Act to provide for Medicare and Medicaid mental and behavioral health treatment through telehealth - Sen. Kennedy, John [R-LA] - telehealth S. 2164 - Lower Costs, More Cures Act of 2021 - Sen. Crapo, Mike [R-ID] - Medicare and Medicaid reforms S. 2197 - A bill to amend title XIX of the Social Security Act to increase the Federal medical assistance percentage for States that provide Medicaid coverage for telehealth services - Sen. Rosen, Jacky [D-NV] - FMAP & telehealth S. 2210 - A bill to amend title XIX of the Social Security Act to expand access to home and community-based services (HCBS) under Medicaid - Sen. Casey, Robert P., Jr. [D-PA] - HCBS S. 2236 - A bill to amend title XVIII of the Social Security Act to provide an option for first responders age 50 to 64 who are separated from service due to retirement or disability to buy into Medicare - Sen. Brown, Sherrod [D-OH] - Medicare buy-in Regulatory Issues: Ongoing implementation issues for the Medicare Advantage (MA) and Medicare Part D prescription drug programs, including risk adjustment methodology, network adequacy and provider directories, encounter data and other data-related issues, and risk adjustment data validation (RADV) audit issues including proposed RADV regulation for MA; bidding and payment issues (including MA rate assumptions, MA coding intensity, MA Secondary Payer issues, Part D reinsurance, Part D low income subsidies, Part D direct and indirect remuneration (DIR), and audits); calendar year 2021 policy and technical regulation for MA and Part D; Part D reform, out of pocket limits; issues related to Medicare for All, Medicare buy-in, reduced Medicare eligibility age, and public option; issues relating to 2022 Rate Notice; issues related to coverage in non-Medicaid Expansion States (e.g., Gap Population); issues related to expanded Medicare fee for service benefits (dental, hearing and vision); issues related to Medicaid coverage gap; potential Medicare NCD relating to monoclonal antibodies for treatment of Alzheimers disease; Executive Orders relating to international pricing, Part D rebates, insulin costs, and importation; issues related to MLTSS; issues related to removal of safe harbor protection for rebates; issues relating to COVID-19, including testing and vaccines; issues related to health equity; issues related to vaccination; issues related to audio-only telehealth; issues related to addressing the social determinants of health, including housing, transportation, nutrition, educational opportunities, and MA supplemental benefits; issues related to Medicaid presumptive eligibility and continuous eligibility; issues relating to Medicaid best price; in-home health risk assessments; Medicare Medical Loss Ratio issues; issues related to changes to prior authorization regulations, electronic documentation, and related issues; issues relating to sequestration under the Medicare Advantage and Part D programs; implications of physician fee schedule on MA; application process, audits to evaluate compliance with MA and Part D program rules, benefit design rules, enrollment rules, requirements for notice and denial forms, marketing materials review and approval, marketing activities, including conduct and compensation of brokers and agents and plan sponsor marketing staff; measurement and oversight of plan performance including Special Needs Plans (SNPs); quality measures, grievance and appeals processes, fraud and abuse compliance including training; contracting issues for Dual Eligible SNPs; Federal preemption of State authority under MA and Part D programs, Part D prescription drug event data reporting, Part D formulary rules, Part D pharmacy access standards, Part D coverage gap discount program, including employer group waiver plan (EGWP) issues, and other operational issues; issues raised by Part D coverage of new specialty drugs, the Part D non-interference policy and related issues (e.g., preferred pharmacy and any willing pharmacy requirements, standards for network pharmacy reimbursement, and policies regarding sponsor negotiation of pharmacy price concessions); issues related to the international price index; issues related to child and maternal health; issues related to Medicaid supplemental and disproportionate share hospital (DSH) funding; issues related to Medicaid funding for territories; issues related to medical management; issues relating to MA supplemental benefits; Medication Therapy Management Program requirements and the Center for Medicare and Medicaid Innovation (CMMI) Demonstration; MA EGWP issues; CMMI's value based payment models; Part D requirements for offering basic and enhanced alternative plans; MA and Part D systems issues affecting enrollment and disenrollment processing and payment and other operational issues; issues relating to MA and Part D Star Rating system including measures, the methodology for calculating ratings, and the role of the ratings for payment purposes; functionality of the Medicare Personal Plan Finder and Drug Plan Finder; National Medicare Education Program; Medicare demonstration program on performance-based payments for physician groups; physician quality reporting initiative; issues relating to Medicare coverage policy and national coverage decisions; issues relating to MACRA, including implications for MA and Part D plans; Medicare/Medicaid integration for dual eligibles, including implementation of the Capitated Financial Alignment Demonstration and related issues (e.g., quality ratings); Medicaid managed care regulations and policies, including CMS's substantial revisions to the managed care regulations, mental health parity rules, the Medicaid managed care actuarial soundness standard, quality oversight, Medicaid and CHIP Payment and Access Commission (MACPAC), grievance and appeals processes, fraud and abuse compliance, beneficiary information requirements, treatment of Medicaid health plan member hospital days in the upper payment limit calculation; policies affecting State Medicaid funding, including block grants, the calculation of the federal medical assistance (federal matching) percentage (FMAP), and intergovernmental transfers (IGTs); coordination of benefits with state Medicaid programs; Medicaid prescription drug cost issues affecting Medicaid health plans including issues raised by Medicaid coverage of new specialty drugs; health plan-related Childrens Health Insurance Program (CHIP) issues, including eligibility and outreach issues and CHIP reauthorization; implementation of Medicaid changes made in Deficit Reduction Act of 2005, including Medicaid managed care organization provider tax issues; standards for electronic prescribing; implementation of Medicaid changes of interest to Medicaid health plans made in the Affordable Care Act (ACA) including Medicaid expansion, the managed care organization (MCO) prescription drug rebate provisions, minimum payments to primary care providers (PCPs), interactions between the Medicaid program and health insurance exchanges, and Medicaid and CHIP maintenance of effort (MOE) requirements; implications of the health insurer fee for Medicaid health plans; issues related to Medicaid Managed long-term care including home and community-based waiver services (HCBS); expanding the availability of Medicare Advantage and Medicaid health plan telemedicine programs; implications of the new non-discrimination rules for health plans participating in public programs; issues related to Medigap coverage; issues related to business continuity in relation to pandemics or natural events (e.g., hurricane, tornado, etc.); cybersecurity; provider directories; value-based insurance design models; Part D prescriber enrollment requirements; Part D recovery audit contractor programs; issues relating to enrollment of beneficiaries with ESRD into MA plans; issues related to health homes for children with medically complex conditions; socioeconomic status impacts on star ratings related to MA and Part D programs; and other issues relating to health care reform implementation.

Client expense: $2,510,000 · Firm income: Not reported

Government targets: Centers For Medicare and Medicaid Services (CMS), Congressional Budget Office (CBO), Executive Office of the President (EOP), Food & Drug Administration (FDA), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), Internal Revenue Service (IRS), Labor, Dept of (DOL), Medicare Payment Advisory Commission (MedPAC), Office of Management & Budget (OMB), Office of Personnel Management (OPM), SENATE, Treasury, Dept of, White House Office