Department of Health & Mental Hygiene Alcohol & Drug Abuse Administration Mental Hygiene Administration May 2012 Behavioral Health Regulations: Workgroup Report

Overview A workgroup was formed to examine State regulations addressing community mental health and substance use disorder programs in order to make recommendations for changes needed to support an integrated (MH and SA) community behavioral healthcare system.

Workgroup Members Brian Hepburn - MHA Daryl Plevy - MHA Sharon Olihaver - MHA Stacey Diehl - MHA Darrell Nearon – BH and Disabilities Barbara Francis – OAG Susan Tucker – Office of Health Services Wendy Kanely - OHCQ Sue Jenkins - ADAA Lori Doyle - Provider Tracy Schulden - Provider Oleg Tarkovsky - Provider Kathy Rebbert- Franklin, Chair - ADAA

Guiding Principles  Address both system & service integration  Promote administrative simplicity  Facilitate & support use of evidence-based interventions  Promote person-centered approach

 Create integrated regulatory system for providers serving those with substance use disorders and mental illness  Align BH quality control mechanisms with those applied to somatic health  Address regulations, not financing  Eliminate duplication with other regulations: Health Occupations Boards, FDA  Achieve consistency in service delivery Objectives

New Approach Transition from reliance on State regulations to recognition of accreditation by nationally accrediting entity.

New Approach – State’s Role  Requires & monitors accrediting status of providers.  Maintains regulations for activities not covered by accreditation standards.  Assists providers with transition to accreditation.

Benefits of Accreditation  Providers expected to respond to one set of standards.  Providers able to apply greater focus to quality instead of compliance.  Providers will meet insurance reimbursement requirements.  State resources have increased capacity to follow-up on concerns/complaints and focus on non-reimburseable service development and provision.

WHO will be required to be accredited? Exemptions:  FQHCs  Hospital programs in regulated space  Licensed individuals in solo or group practice Applies to: All other mental health, substance use disorder & co-occurring treatment programs

Different Models Licensed individuals in solo or group practice:  Accreditation not required.  FFS payments only for individuals licensed to practice independently. Licensed and Unlicensed in practice together:  Program must be accredited due to unlicensed practitioner(s) Unlicensed staff in practice together:  Program must be accredited due to unlicensed practitioner(s)

HOW will transition proceed? Further analysis by Workgroup. Additional & on-going opportunities to provide feedback. Accrediting entities must be approved by State. State exploring methods to help facilitate transition for providers.

WHEN will transition occur? July 2012 Final Workgroup Recommendations January 2013 Legislation introduced & passed July 2013 Legislation implemented July 2015 Compliance with legislation required

Additional Analyses 1. Review crosswalks of COMAR to accrediting standards. 2. Determine critical elements in State’s oversight and monitoring. 3. Survey other states for lessons learned. 4. Plan future relationships and communication channels between accrediting entities, OHCQ, and BH Administration 5. Evaluate ways to assist providers with accreditation process.

Assistance with Accreditation Currently large number of MH & SA programs licensed/certified (>2k). Analyze needs of provider communities. Evaluate various methods to assist with accreditation process.

Current Licenses – Substance Abuse 21 Education Programs 263 Outpatient Programs 95 Residential Programs 11 Residential Detox Programs 11 Non-Residential Detox Programs 55 OMT Programs 32 Correctional Programs TOTAL = 488

Current Licenses – Mental Health 198 Outpatient Mental Health Centers 4 Group Homes and 150 above 54 Vocational Programs 26 Mobile Treatment Services 35 Partial Hospitalization Programs 171 PRP for Adults 109 PRP for Minors 16 Residential Crisis Services 743 Residential Rehabilitation Programs 17 Respite Care Services 21 Therapeutic Group Homes 1 Therapeutic Nursery Program TOTAL = 1,545

Stakeholder Feedback Ongoing: Forums: MHA conference May 2 MADC conference May 9 Final Report and Recommendations