As part of continuing efforts to integrate delivery of primary care, substance use disorder and mental health services in the state, the New Jersey Department of Health today announced new regulatory guidance to align licensure requirements and improve access to behavioral health care.
"With these waivers and clarified guidance, we are holding true to the goal that care for physical conditions, mental health, and substance use disorders should be integrated and coordinated. Patients often have problems in all three categories, and it is past due for the health care system to design itself to meet all of a patient's needs,” said New Jersey Health Commissioner Dr. Shereef Elnahal. “By reducing bureaucratic hurdles for provider agencies, patients can get more of the care they need in one setting. This will be especially helpful in combatting the opioid epidemic."
The Department is releasing guidance to clarify that a healthcare facility licensed to provide both mental health services and substance use disorder services is permitted to share clinical space for those services as long as they comply with federal and state laws, particularly those pertaining to confidentiality and client rights.
The agency is also releasing a regulatory waiver for substance use disorder facilities to receive deemed status in place of required periodic inspections if the facility is accredited by an accrediting body recognized by the Department. The facility must have been accredited within the past two years and submit an application for this status. Prior to the release of this waiver, deemed status was available for mental health facilities, but not for substance use disorder facilities. This waiver opportunity will help to align licensure requirements and procedures across facility types, particularly those with multiple licenses.
Recognized accrediting bodies for substance use disorder facilities are the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), the Council on Accreditation of Family Services Agencies (COA), the Council on Accreditation of Rehabilitation Facilities (CARF) and the National Commission on Quality Assurance (NCQA). The Department will continue to investigate any complaints regardless of deemed status.
“Enabling integrated primary care is vital for New Jersey,” said John V. Jacobi, Dorothea Dix Professor of Health Law & Policy, Seton Hall Law School. “Dr. Elnahal’s provision of guidance in advance of the move to a single license helps to assure caregivers that the Department is their partner in the effort to provide excellent, evidence-based care.”
The Department is also taking steps to make it easier for residents to get access to opioid use disorder treatment in primary care settings. Late last year, the Department issued a waiver clarifying the definition of “drug abuse treatment services” in Ambulatory Care Facilities, such as Federally Qualified Health Centers to include buprenorphine and other medications for the treatment of opioid use disorders. This waiver provides these facilities with added flexibility to provide Medication Assisted Treatment to primary care patients with substance use disorders.
“The waiver allowing ambulatory health centers to provide MAT means that Zufall can now provide more holistic care to our patients, said Eva Turbiner, President and CEO of Zufall Health Center. “We were able to add capacity for MAT services and the patients no longer need to travel to different providers to get specific services. We believe it will improve continuity of care, resulting in successful treatment.”
For more information on the waivers, guidance and Frequently Asked Questions, visit the Department’s health facility licensing website. These materials, unless otherwise specified, does not address Medicaid reimbursement, which falls outside of the purview of the Department of Health (DOH). Any questions or issues related to Medicaid reimbursement should be directed to the Department of Human Services (DHS).
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