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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:

  • Allowing psychiatric pharmacists to bill incident to at a higher level of Evaluation and Management (E/M) visit codes to increase payment for services.
  • Retaining telehealth flexibilities extended during the public health emergency.
  • Revising the definition of direct supervision to include virtual presence.
  • Expansion of audio-only services to SUD services.
  • Removing continuous 6-month in person requirement for telemental health visits.

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:

  • Order and administer COVID testing
  • Order and administer COVID vaccines, to enable retirees, pharmacy technicians and students under supervision to help with vaccine distribution
  • Routine and catch-up vaccines for youths ages 3 – 18 years
  • Order and delivery of monoclonal antibodies for treatment

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 sent a letter to Senate Finance Committee Chairman Ron Wyden (D-OR), and Ranking Member Mike Crapo (R-ID) in response to their request for evidence-based solutions and ideas to enhance behavioral health care in areas such as workforce, care integration and use of telehealth.
  • CPNP sent a letter to Senators Bill Cassidy, M.D. (R-LA) and Chris Murphy (D-CT), members of the U.S. Senate Health, Education, Labor and Pensions Committee, in response to their request for feedback on the effectiveness of federal mental health and substance use disorder programs included in the Mental Health Reform Act of 2016 that are up for reauthorization.
  • CPNP sent a letter to Senate Finance Committee members Michael Bennet (D-CO) and John Cornyn (R-TX) in response to their “A Bold Vision for America’s Mental Well-being,” a white paper outlining a new framework for reimagining and redesigning how mental and behavioral health care is delivered in the United States.

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.

Telehealth

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:

  • CPNP supports the Telemental Health Care Access Act (H.R. 4058/S. 2061) to remove the six-month in person visit requirement prior to telemental health services for Medicare beneficiaries as enacted in the Consolidated Appropriations Act, 2021.
  • CPNP supports the CONNECT for Health Act (H.R. 2903/S. 1512) to permanently remove geographic and originating site restrictions for telehealth services provided to Medicare enrollees and provides HHS authority to waive telehealth restrictions in statute, a provision currently in place due to the pandemic but on a temporary basis.

Congress is expected to take up telehealth legislation in 2022 to ensure telehealth flexibilities are maintained after the expiration of the PHE declaration.

Federal Funding

CPNP supported funding for mental health and substance use services, research, and workforce training through the following funding vehicles:

  • American Rescue Plan, COVID supplemental funding bill, that became law in March provided $3.8 billion for federal mental health and substance use programs.
  • The annual funding bill, FY2023 Labor-Health and Human Services-Education bill, that funds health professions training, prevention, patient care services, and research to address mental health and substance use disorders. CPNP has sent numerous letters in support of MH and SUD funding streams. The twelve FY2023 spending bills are funded through a continuing resolution through February 18 to be finalized in 2022.
  • The Build Back Better Act (Budget Reconciliation) that passed the House and now is being negotiated in the Senate includes:
    • The Parity Implementation Assistance Act to give federal officials the ability to impose civil monetary penalties for violations of the Federal Parity Act. The bill includes $195 million for enforcement through September 2026.
    • $75 million for the National Suicide Prevention Lifeline.
    • $500 million in funding for qualified teaching health centers and behavioral health care centers (including both SUD and MH) for improvement, renovation, or infrastructure.
    • $75 million to grow and diversify the maternal mental health and substance use disorder treatment workforce.
    • $100 million to address maternal mental health conditions and substance use disorders with respect to pregnant, lactating, and postpartum individuals.
  • The Infrastructure Investment and Jobs Act, signed into law in November, provides $65 billion to expand broadband access - $42 billion targeted to broadband deployment in unserved or underserved areas and $14 billion to provide $30-a-month internet subsidy for low-income families. Broadband is critical to the availability to telehealth, which is a CPNP policy priority.
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25 Years!