Laura Hanen, Senior Vice President, District Policy Group
Throughout the year, CPNP worked to advance the policy priorities outlined in the 2021 Health Policy Agenda. CPNP engages in advocacy on behalf of its members alone as well in collaboration with five national coalitions. As we close out the year, we look back on the many advocacy activities CPNP has been engaged in with the expectation that 2022 will be just as action packed.
Government Affairs Committee Activities
Throughout the year, the Government Affairs Committee collaborated and developed four new issue briefs to help advance our policy priorities. Each issue brief describes the policy challenges and obstacles that members face and describes how psychiatric pharmacists add value in these areas and can help increase access to critical health care services.
The Government Affairs Committee also worked to develop a CPNP Federal Advocacy Toolkit. The purpose of the toolkit is to assist CPNP members engage in federal advocacy to advance the practice of psychiatric pharmacists. The toolkit is designed for those who are new to advocacy as well as those who have previous experience. Many of the tips and tools included can also be useful in state advocacy efforts. The toolkit will be available on with website in January.
Major Advocacy Milestones
CPNP began the year with offering the Biden Administration 12 specific recommendations to increase access to mental health and substance use services. The full list of recommendations can be found in a letter to the White House and HHS.
In the spring, CPNP wrote a letter to Substance Use and Mental Health Services Administration (SAMHSA) and the HHS Assistant Secretary of Health urging inclusion of psychiatric pharmacists on the list of exempt providers in the Practice Guidelines for the Administration of Buprenorphine for Treating Opioid Use Disorder.
In September, CPNP wrote a letter to CMS providing comment on the FY2023 Physician Fee Schedule advocating for:
In September, CPNP joined APA, APNA, National Council, NAMI, and the National Association of State Mental Health Program Directors in sending a letter to the Food and Drug Administration (FDA) expressing concerns about the implementation date and various elements of the new Clozapine REMS system that launched mid-November. After the launch of the new system, CPNP led another letter to FDA and met with FDA officials to discuss a number of issues with the NCR implementation such as enrollment challenges, the 90-day transition to allow RDAs without the patient being enrolled, telephone wait times and difficulties with the ability to switch providers or remove a patient from a provider. CPNP will continue monitoring these system issues with members.
In October, Members of CPNP’s Board, Government Affairs Committee, and Public Affairs Committee participated in 25 virtual Congressional visits along with our government affairs consultants with the District Policy Group at Faegre Drinker. The purpose of the visits was to educate Congressional offices on the role of psychiatric pharmacists in providing patient care services and discussing policy options to remove barriers for patients in accessing their services. CPNP will be doing more Congressional visits early in the new year.
In December, CPNP leadership and current and former Board members met with Kristi Martin, Senior Advisor to the Director of the Center for Medicare Services to discuss opportunities to increase the availability of mental health and substance use services for Medicare enrollees through the inclusion of psychiatric pharmacists on health care teams as well as the importance of Comprehensive Medication Management Services for Medicare enrollees.
Pharmacists Scope of Practice
Throughout the year, CPNP has been an active participant of the Joint Commission of Pharmacy Practitioners (JCPP) to advocate with federal policymakers to pay for patient care services provided by pharmacists, including during the public health emergency (PHE). In April, the Pharmacy and Medically Underserved Areas Enhancement Act (H.R. 2759/S. 1362) was reintroduced with bipartisan support. The legislation adds pharmacists to the list of providers whose patient care services, when delivered to patients in medically underserved communities, are covered by Medicare Part B (i.e., grant them “provider status.”) While the bill has strong bipartisan support, the bill is very costly and therefore serves as an important vehicle for educating members of Congress on the importance of paying for patient care services provided by pharmacists.
In addition, JCPP members have had multiple meetings with leadership of the Center for Medicare services to discuss needed amendments to the Public Readiness and Emergency Preparedness Act (PREP) to allow the provision of the following services by pharmacists, as well as payment:
CPNP has supported all activities that will open the door to payment to pharmacists for patient care services. Unfortunately, CMS continues to maintain that they do not have the authority to do so.
Mental Health and Substance Use Legislation
This year there has been much attention in 2021 at the federal level on the need for mental health and substance use services resulting from the COVID pandemic. Select Senators issued three separate requests for information on how to better address mental health and substance use in which CPNP provided comment. They included the following:
CPNP has also actively supported the Mainstreaming Addiction Treatment (MAT) Act (H.R. 1384/ S. 445) to eliminate the DATA waiver (or X waiver) requirement for prescribing buprenorphine to treat opioid use disorders. There are now 229 cosponsors in the House of Representatives, which is sufficient support to ensure passage.
CPNP anticipates legislative activity to address mental health and substance use to pick up in 2022.
Maintaining flexibilities for telehealth has been a key priority for CPNP this year. CPNP has advocated for these flexibilities in our physician fee schedule comment letter, as noted above, and has endorsed legislation including:
Congress is expected to take up telehealth legislation in 2022 to ensure telehealth flexibilities are maintained after the expiration of the PHE declaration.
CPNP supported funding for mental health and substance use services, research, and workforce training through the following funding vehicles: