HHS Request for Comment on Chronic Disease of Addiction
Impact on your practice
This RFI is an opportunity for therapists and providers to shape federal policy priorities around addiction and mental health treatment, but it's a comment-gathering exercise with no immediate regulatory impact. Therapists in policy-engaged organizations should submit input on reimbursement, workforce, and access barriers.
Key facts
HHS is seeking public comment on successful addiction and mental health research, programs, and policies
Request focuses on prevention, treatment, and recovery interventions for addiction and co-occurring disorders
Part of Trump Administration's 'Great American Recovery' initiative
Seeks to identify gaps and novel policy recommendations using existing funding
Therapy Companion analysis
This Request for Information (RFI) represents a critical window for shaping federal addiction treatment policy, but it demands immediate action from your practice. The 25-day comment period (closing July 5, 2026) is your opportunity to influence how SAMHSA allocates existing funding and structures future reimbursement priorities around addiction and co-occurring mental health treatment. If your practice treats patients with substance use disorders—whether opioid use disorder, stimulant use disorders, or alcohol use disorders—the policy directions emerging from this RFI will directly affect your revenue streams, treatment protocols, and payer relationships within 12-24 months. The document signals several concerning policy directions that warrant aggressive advocacy: the administration's emphasis on "Ending Support for Harm Reduction" suggests potential defunding or regulatory restrictions on medication-assisted treatment modalities, peer support services, and syringe service programs—services many of your Medicaid and commercial patients rely on. Conversely, the focus on "Medications for Opioid Use Disorder" indicates likely expansion of buprenorphine and methadone funding, which could increase referrals to your practice if you hold DATA waiver prescribing privileges (for LCSWs with psychiatric training, psychologists, and psychiatric NPs). The emphasis on "Integration of Health Records" and "Health Technology" signals forthcoming documentation and EHR compliance requirements—likely tied to interoperability mandates that will require software investments or vendor contract renegotiations. The CCBHC (Certified Community Behavioral Health Center) expansion mentioned in the document could redirect funding away from solo practitioners and smaller group practices toward larger integrated systems if you're not already enrolled. Your reimbursement strategy depends on whether your practice specializes in SUD treatment: if it represents >20% of your revenue, you need to comment on current Medicaid reimbursement rates (most states reimburse SUD treatment at 30-40% below general mental health rates), prior authorization barriers, and medication denial patterns.
Background
The Trump Administration's 'Great American Recovery' initiative represents a significant policy shift from the previous administration's harm-reduction-focused approach to addiction. This RFI is not routine—it explicitly seeks to identify gaps and novel policy recommendations while evaluating which existing programs to continue or discontinue. The language around 'ending support for harm reduction' signals ideological direction that conflicts with evidence-based practices supported by SAMHSA's own research (medication-assisted treatment combined with psychosocial intervention remains the gold standard for opioid use disorder). This creates a bifurcated landscape: therapists may face expanding funding for traditional abstinence-based and faith-based approaches while experiencing funding reductions or regulatory barriers for evidence-based pharmacological interventions. The broader context is workforce shortage—the addiction treatment workforce is critically understaffed, and therapy licensing boards across states have not kept pace with scope-of-practice expansions necessary to address the treatment gap. The RFI's focus on 'strengthening agency collaboration' and 'engaging faith-based providers' suggests the federal government may be shifting resources toward non-clinical, community-based models that could either augment your practice (if you partner strategically) or bypass it (if referral networks consolidate around larger health systems or religious organizations). The emphasis on rural communities and hard-hit areas indicates potential geographic carve-outs in funding that could disadvantage urban private practices while creating opportunities in underserved markets.
What you should do
Submit a detailed comment to the RFI (via Regulations.gov, document 2026-11602) by July 5, 2026 addressing: (1) current Medicaid reimbursement disparities for SUD treatment vs. general mental health, with specific dollar amounts your practice experiences; (2) prior authorization denial rates for medication-assisted treatment and evidence-based psychotherapies (CBT, contingency management); (3) state licensing barriers preventing LCSWs, LPCs, and MFTs from expanding SUD treatment capacity. Include data from your practice (patient volume, payer mix, average authorization delays) to substantiate claims.
Audit your current patient roster and reimbursement data: identify what percentage of revenue comes from SUD treatment, which payers reimburse below-market rates, and which medications/modalities are most frequently denied. Use this data to determine whether harm-reduction funding cuts or MAT expansion would benefit or harm your practice, then position your comment accordingly.
If your practice does not currently treat opioid use disorder with MAT, obtain DATA waiver training and certification (psychiatrists, psychiatric NPs, and psychologists with psychiatric training can prescribe; LCSWs with advanced training may prescribe in some states—verify your state's regulations) within 6 months, as the RFI suggests MAT expansion funding. This is a revenue opportunity.
Review your EHR contracts and assess interoperability compliance: the RFI's emphasis on 'integration of health records' suggests HHS will mandate HL7 FHIR compliance and real-time data exchange. Request your vendor's roadmap and timeline; budget $5,000-$15,000 for upgrades if your system is not current. Non-compliant systems may face reimbursement delays or exclusion from federal program networks.
Document your clinical protocols for co-occurring disorders (SUD + mental illness) using evidence-based criteria (DSM-5, ASAM placement criteria). When HHS/SAMHSA publish final guidance based on RFI comments, they will likely tie continued funding to documented assessment and treatment planning standards. Practices without standardized protocols will face prior auth barriers and payer pushback.
Notable excerpts
"Ending Support for Harm Reduction" (HHS RFI, Table of Contents, Guidance Section). This single phrase signals potential defunding of syringe services and peer support models—practices should clarify which services fall under this category and document their efficacy to counter future restrictions.
"SAMHSA Is Directing Targeted CCBHC Investments to Hard-Hit Communities" (HHS RFI, Resources Section). CCBHC expansion may consolidate funding into larger integrated systems; solo and small-group practices should assess whether CCBHC certification is feasible in your market.
Comments on this notice must be received by July 5, 2026 (HHS RFI, Document Dates). This is a hard deadline—submissions received after this date will not be reviewed. Delay costs your practice influence on reimbursement policy.
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Policy changes drive denial patterns
Therapy Companion tracks both: the policy shifts on this page and the denial patterns hitting your claims.
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