New Jersey Eases Rules on Shared Clinical Space for BH, SA Treatment

March 2019 ~

The New Jersey Department of Health (NJDH) announced on March 18, 2019, new guidance permitting health care facilities that provide both mental health and substance use disorder services to share clinical space. The guidance also permits deemed status for accredited substance use disorder facilities in place of required periodic inspections.

According to the announcement, these changes are part of the Department’s continuing efforts to integrate delivery of primary care, substance use disorder and mental health services in the state.

The Department states it is releasing guidance that will provide clarity around healthcare facilities 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.

NJDH states it will also release 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. As stated in the announcement, 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.

NJDH recognizes the following accrediting bodies for substance use disorder facilities:

• 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)
• The National Commission on Quality Assurance (NCQA)

Additionally, changes are also underway that will provide residents assistance to access opioid use disorder treatment in primary care settings. Late last year, in an effort to offer facilities additional flexibility to provide Medication Assisted Treatment to primary care patients with substance use disorders, NJDH 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.

“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.”

For more information on the waivers, guidance and Frequently Asked Questions, refer to the NJDH’s health facility licensing website.

Source(s): HMA Weekly Roundup March 20, 2019; State of New Jersey Department of Health;