The federal Institutions for Mental Disease (IMD) exclusion hampers Maryland’s efforts to address mental health parity. The Medicaid IMD exclusion is an outdated, discriminatory federal rule that creates significant barriers to treatment for adults with severe mental illness. Under this rule, federal Medicaid reimbursements to states are prohibited for non-geriatric adults receiving psychiatric care in a treatment facility with more than 16 beds.

Outpatient mental health clinics across Maryland have forever struggled to cover their costs to provide effective mental health and addiction services to vulnerable and frequently low-income children and adults. CCBHCs have now been approved in six states through state plan amendments with another five states approved through a federal CCBHC Medicaid demonstration program. Simply put, Maryland is falling behind nationally.

These states have shown adherence to a strict set of mental health and addiction services, quality measures, and expanded access to care for their communities. In exchange for adherence to certification rules that hold providers accountable for evidence-base coordinated treatment and programs, CCBHCs receive a bundled payment rate that covers the cost of services.

Data from Sheppard Pratt's three CCBHC grants, coupled with national data show actual hospitalization costs drop when providing CCBHC services with a bundled rate. By providing high quality and "high touch" services, CCBHCs can be part of the solution to reduce overall expensive Medicaid hospitalization costs.

Being able to staff our programs adequately and clinically appropriately is key to our ability to effectively serve our patients. Our front-line staff, particularly our nurses, dedicate themselves every day to the mission of the organization, caring for some of our most vulnerable residents. 

Delays in licensure and certification directly impact access to care. Inadequate staff levels lead to unstaffed beds. Unstaffed beds can lead to an increase in emergency department boarders. And increased boarders in emergency departments leads to challenging clinical situations, staff burnout, and less than ideal patient care.

The Board of Nursing needs to do better. 

Maryland is in the midst of a behavioral health workforce crisis. Federal data found that Maryland has 63 federally designated mental health professional shortage areas (HPSAs), including 11 entire counties. These shortage areas, in which less than 20 percent of residents are getting their mental health needs met, impact over 1.7 million Marylanders. 

This is unsustainable. There are simply not enough behavioral health professionals to meet the mental health and substance use needs of all Marylanders. There are many positive ideas and strategies for growing the behavioral health workforce – stipends and scholarships, enhanced training programs, loan repayment, paid internships, etc. This bill will help to solve the issue and begin to build the workforce we need in Maryland.

To effectively meet the highly specialized needs of the students served in Sheppard Pratt Schools, we must have the capacity to employ highly qualified and experienced special and general education teachers. The current disparity between public and nonpublic teacher salaries does not allow for Sheppard Pratt to pay their special and general educators a salary that aligns with their public school counterparts.

The Collaborative Care Model is a validated, patient-centered, evidence-based approach for integrating physical and behavioral health care in primary care settings. 

Commercial health insurers in Maryland and Medicare are already reimbursing providers for delivering this model. An ongoing CoCM pilot in the Maryland Medicaid program has demonstrated “clinically significant improvement” in depression and anxiety symptoms for more than 65 percent of participants. It is time to end the pilot and join the 20+ other states that are providing CoCM broadly to their Medicaid recipients.

Several simple steps can be taken to address both hospital inpatient overstays as well as the mental health patient burden on the State’s emergency rooms. It is important to stress two points: 1) parents and families should not have to relinquish custody to the State for youth to access care, and 2) adults should not lose their civil liberties by being unduly held on inpatient units. While Sheppard Pratt is actively participating with the Maryland Hospital Association and the Department of Health on tracking youth inpatient overstays, the problem runs deeper than just youth—extending to adults and a lack of invested resources.