The National Association for Behavioral Healthcare (NABH) is kicking off the new decade with a new leader.
Shawn Coughlin took over as president and CEO of the trade association Jan. 1, following the retirement of the organization’s long-time leader Mark Covall, who headed up NABH for the past 24 years.
With Coughlin at the helm, NABH plans to tackle a lofty set of goals over the next ten years — principle of which is to break things, from silos and stereotypes to outdated legislation.
Formerly the National Association of Psychiatric Health Systems (NAPHS), NABH is a trade association that represents and advocates for behavioral health providers nationwide. Its member base includes about 1,800 organizations, which span the continuum of care, from provider systems and residential treatment facilities to outpatient centers and beyond.
Although Coughlin is new to the position, he’s familiar to NABH. He’s served as its executive vice president for government relations and public policy since 2017. Before that, he was a NABH lobbyist on Capitol Hill.
In his new role, Coughlin is taking aim at the behavioral health workforce shortage, administrative burdens on providers and ‘blatant parity violations’ currently allowed by law.
Behavioral Health Business connected with Coughlin to discuss all that and more. You can find that conversation below, edited for length and clarity.
BHB: Congratulations on the new role, Shawn! As CEO of NABH, what are your goals and priorities in the year and decade ahead?
Coughlin: Our focus going into 2020 remains on the key issues we’ve been working on in the past year.
Some of that is focused on the issues we face with managed care organizations.
We’re looking at issues like medical necessity to ensure that MCOs are using clear, transparent and readily available public criteria to determine what is medically necessary. We’re also focused on utilization management [and network adequacy].
There are a lot of questions about whether a patient needs another day of care or to be in a certain level of care. It’s a lot of micromanagement that is diverting our members from the delivery of patient care to administrative burdens associated with managed care companies.
Our members are interested in being in managed care networks, yet we hear a lot of managed care plans across the country say, “Oh, no, we’ve got plenty of providers. We don’t have any room.” We’re constantly hearing that patients within those very same markets can’t find a provider in-network that will see them on a timely basis.
Managed care plans are not even close to adhering to the requirements of parity. They’re hiding behind all these non-qualitative treatment limitations and bobbing and weaving to avoid actually providing access and coverage for services.
That’s going to be our number one focus.
What about on the regulatory side of things?
We still have this underlying problem with the Medicare conditions of participation, which are so outdated.
They were put in place in 1966, with minor clarifications in the 1980s. These conditions no longer reflect current best practices. It bleeds a lot of costs and time away from our members being able to provide direct services because they’re suck doing paperwork.
Another area that we’re going to be emphasizing much more is the behavioral health care workforce. We are trying to now think outside the box and see if we can find some new ideas and initiatives.
We were very pleased to see that over the holidays, CMS issued a request for information on federal standards that are higher than the state standards for supervision of individuals providing care.
We’re working diligently to get some comments in on that and identify areas where federal standards push down on state standards and prohibit providers at all levels from practicing at the top their licenses.
Then we’ve got perennial issues that we continue to hammer on like the Medicaid IMD exclusion and the Medicare 190-day lifetime limitation. Those are parity issues, and we feel the federal government should not continue to have blatant exclusions or caps that they’ve prohibited in the private sector.
Sounds like your plate is full. Given that this is an election year, how is that going to play into your progress?
It always takes time, and you never know when an issue is going to ripen.
But [government leaders are acknowledging] that the opioid crisis has not gone away and that there are additional actions needed. We’re happy with that, and we’ve been working with the Energy and Commerce Committee in the House and the Senate Finance Committee to try to get them to continue to address the opioid crisis.
Even though it’s an election year, there are diligent officials who continue to focus on critical issues. We’ll continue to do the same thing and look for opportunities to advance positive legislation.
You touched on the opioid crisis. The epidemic is pervasive nationwide, but we’ve heard complaints from providers who worry the government is too focused on opioids at the expense of other behavioral health crises. How do you see that balance evolving?
Our message has been that these are not drug-specific issues or problems.
We know many people with substance use disorders (SUDs) use multiple substances. And it shouldn’t be lost on anybody that alcohol continues to kill as many people as the opioid crisis on an annual basis. We’re seeing meth reprising. We’re seeing benzodiazepines being abused.
Siloing these dollars into specific areas is hugely problematic, and we keep pushing back against that.
In many instances, people with SUDs also have underlying mental health conditions that have not been addressed. There are comorbidities and co-dependencies, so you can’t deal with this in a silo.
Unfortunately, that’s the way behavioral health has been treated over the years by the federal government.
Behavioral health was siloed away from medical surgical services; there were silos between mental health services, behavioral services and SUDs; and there were further silos by disease state.
We continue to try to educate lawmakers on the fact that targeting one specific problem is not going to get us to the place we need to be in ensuring comprehensive access to comprehensive services.
These services all need to be integrated. Hopefully we’re making progress on that. I believe we are.
The workforce shortage is another area that desperately needs to be addressed. What solutions are you pushing for?
It’s going to require a multi-component strategy.
Obviously, we need more trained providers. We need to ensure that the federal government makes it a priority to help build this workforce.
There are a host of grant programs, loan repayments and other initiatives the federal government has dabbled in. There’s a lot of peer-to-peer support and other initiatives developing organically from the ground up.
But also, managed care companies are in many instances paying providers in the behavioral health space less than Medicare rates and less than they’re paying primary care providers.
That’s just not the way the economics of the system works.
If they were truly providing access to a comprehensive network, they would be increasing their payments to providers and encouraging folks to go into areas where they have shortages or holes in their networks. They’re doing the exact opposite.
We’re trying to find innovative ways to move the ball forward rather than just say, ‘Well, that’s the way it is.’
We’ve talked a lot about challenges, but what opportunities do you see within the behavioral health realm in the year ahead?
We have seen a growing recognition of the need for access to services — and recognition that it’s okay to ask for help. That positive development is largely organic.
Michael Phelps has an initiative now, and you’re seeing all sorts of athletes coming out and saying, ‘Hey, I’ve had these problems. If you have an issue, speak up.’
That presents opportunities for us to get out there and be seen as part of the health care system, which our members clearly are.
Another area behavioral health is getting recognition is within Medicare. Last year, CMS expanded Medicare coverage for opioid use disorder (OUD) treatment. What sort of opportunities do you see this creating for providers?
It’s great that, finally, Medicare has recognized that there was a need.
There’s been a huge increase in the number of Medicare eligible individuals who are subject to substance abuse. There’s also been a huge increase in suicides within that population.
The fact that the federal government has stepped in and recognized this was a huge shortfall in the federal Medicare program is a big benefit.
We worked very closely with the industry and CMS to make sure the rollout of the Medicare OTP proposal truly addressed the needs out there. We’re very happy to see them accept many of our recommendations.
What often happens when Medicare starts covering something is that you see private sector insurance start to model it. Hopefully we’ll see that historic trend continue.
Frankly, it’s always surprised me that Medicare and Medicaid aren’t bound by the same parity rules that other insurers are.
I agree with you 100%.
With the Medicaid IMD exclusion, the government is flat out saying they won’t cover any benefits for anybody within the ages of 21 and 65.
That’s a blatant parity violation, and [so is] the Medicare lifetime cap on inpatient services.
It’s hard to say they’re clean on this when they maintain two significant parity violations, in my opinion, but it’s nice to see that improvement on the OTP side.
What bold predictions do you have for the behavioral health landscape in the year and the decade ahead?
The continuum of care doesn’t exist in its entirety everywhere.
With focus on integration of behavioral health into medical/surgical care, we’re starting to see recognition that individuals need access to the most appropriate care and the right setting at the right time.
The pendulum has swung too far to the other side, to de-institutionalization and everything being in the community. Now, we’re recognizing that did not work.
The pendulum is starting to swing back: We’re recognizing that we do need to have a full continuum of care in behavioral health. We do need to ensure that all levels of care are available — and that they’re available everywhere.
My hope is we’ll start to see some real progress on that and recognition that this continuum needs to be built out and accessible to everyone who needs it.
What message do you have for behavioral health providers in how they can help move the needle on some of these issues?
We’re all in this together. Anybody who’s engaged in legislation knows that the squeaky wheel gets the grease, so the more we can align our interests, speak up and move together collaboratively, the better off we all will be.