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Join Our Call for an Integrated Facility License for Physical and Behavioral Health Care

Posted October 18, 2023

Last week we sent a letter to New Jersey’s Acting Health Commissioner, Kaitlan Baston, M.D., urging her to move forward expeditiously with proposing regulations creating an integrated facility license that permits provision of physical and behavioral health care services in the same setting by the licensee. The integrated facility license and regulations are critical to the health of the people of New Jersey. Moreover, this step is required by New Jersey law. The license would allow ambulatory care facilities to provide physical, mental health, and substance use services under one license – rather than three.

Behavioral health disorders (i.e., mental health and substance use disorders) are prevalent and increasing, yet there is a marked disparity between diagnosis, treatment, and outcomes for physical health and behavioral health conditions. This disparity is due, in part, to the lack of coordination that currently exists in the health delivery system between behavioral and physical conditions.  Multiple studies have shown that integrating primary physical and behavioral health care improves access to high quality treatment, patient engagement, clinical outcomes, and patient satisfaction. Integrating physical and behavioral health provides a triple benefit: improving outcomes, increasing access, and reducing stigma around behavioral health.

The State Legislature recognized the benefits of integrated care and the need to modernize the state’s licensing system by passing two laws in 2017 directing the Departments of Health and Human Services to collaborate and for the Department of Health to issue an integrated facility license.

Unfortunately, as of today, facilities that want to integrate care must still navigate separate licensure processes, disjointed inspection schedules and standards, and inconsistent informal staff directions. The process creates time delays and costs for these facilities, and delays care that people can receive.

For these reasons, we brought this call for action to the new Acting Commissioner’s attention. As a physician and someone who has delivered integrated care, Dr. Baston has seen its value, and we trust that she sees the urgent need for action. Our letter to the Acting Commissioner has broad support from physicians, mental health providers, reproductive health providers, health insurers, consumers, hospital systems, public health entities, and regional health hubs. We are still adding names to the letter and sharing with the Commissioner to demonstrate the broad call and support for immediate action. We urge you to add your name and organization to the letter.

Beyond the integrated facility license, there is another key step that the State can and should take to improve access to behavioral health care for those covered by NJ Medicaid. Over two million people covered by NJ Medicaid coverage are unable to access care from Licensed Clinical Social Workers (LCSWs) independently practicing outside of a hospital or licensed facility because these LCSWs cannot bill NJ Medicaid for such care. This situation could be changed without any change in law and would immediately improve access to more LCSWs and improve behavioral health care in the state.

It is time to modernize the State’s regulations and systems and work quickly to improve access to behavioral care.

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