Dear Secretary Azar and Administrator Verma:
We are writing to express our support for our nation's mental health and substance use disorder treatment providers who play a critical role in supporting individuals through Community Mental Health Centers (CMHCs) and Community Behavioral Health Organizations (CBHOs). While the federal emergency discretionary funds provided to the Substance Abuse and Mental Health Services Administration (SAMHSA) are valuable, the scale of the COVID-19 pandemic demands additional emergency funding to meet the significant behavioral health needs of our communities. It is critical that these organizations receive a meaningful level of support from the Public Health and Social Services Emergency Fund (PHSSEF).
Approximately one in five Americans experience mental illness or substance use disorders, and the pandemic will only increase the number of Americans struggling with these issues. A recent poll by the Kaiser Family Foundation found that nearly half of Americans say that worry and stress related to the pandemic are hurting their mental health. Additionally, our front-line health providers and first responders are working around the clock in extremely difficult circumstances, dealing with traumatic situations – often without adequate time to rest and debrief. It is critical that we ensure those who take care of our communities also have the mental health supports they need.
Unfortunately, at a time when we need to be increasing community-based treatment, we are seeing the opposite. A recent nationwide field survey conducted by the National Council for Behavioral Health highlights the immediate financial crisis threatening the backbone of the community-based mental health service system in the United States. Nearly all (92.6%) of CBHOs nationwide have been forced to reduce their operations. Alarmingly, 62.1% of behavioral health organizations project that they will only survive financially for three months or less under the current COVID-19 conditions. Moreover, the National Governors Association recently noted in a letter to Congress that mental health and substance use providers faced "collapse" without emergency Medicaid financing.
Additional emergency funding is needed for CBHOs to defray the cost of staff sick leave and hazard pay, purchase Personal Protective Equipment (PPE), and obtain the capacity to rapidly expand tele-mental health care including technology, staff training, and technical support. Without this support, Americans in psychiatric crisis and people at risk of opioid overdoses could overwhelm hospital emergency facilities. There is also considerable evidence that COVID-19 is undermining progress in the ongoing battle against the opioid epidemic.
As you know, the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136) included $100 billion in funding for the PHSSEF to support health care providers on the front lines of the coronavirus crisis. The recently passed Paycheck Protection Program and Health Care Enhancement Act includes an additional $75 million for the PHSSEF.
Based on the information we have received to date, we are concerned that behavioral health providers are largely left behind in the planned allocations of the initial $100 billion fund. HHS initially announced that $30 billion of the $100 billion fund would go to Medicare fee-for-service providers. In its recent follow up announcement, HHS indicated it will distribute an additional $20 billion of the fund based on net patient revenues with little clarity on how Medicaid-dependent and Medicaid-only providers will be treated. We are concerned that this approach may continue to significantly underfund and potentially continue to exclude many essential providers, including mental health and substance use disorder treatment providers who serve a large number of Medicaid beneficiaries. We are also concerned that the $10 billion HHS intends to allocate to hospitals in high impact areas and the $10 billion intended for rural health clinics and hospitals will also not adequately address behavioral health care.
We appreciate your efforts to quickly allocate funding to critical health care providers, but we must ensure that all future efforts recognize the needs of mental health and substance use disorder providers and organizations so they can continue to meet the needs of their communities during this crisis. Thank you for your attention to this important matter and we look forward to working with you.Sincerely,
Reyna TaylorVice President, Public PolicyNational Council for Behavioral HealthDirect: 202-774-1651ReynaT@thenationalcouncil.org