2025 advocacy piece

9 Legislation Can Positively Impact Behavioral Healthcare Stories Telehealth restrictions are another factor limiting capacity and access to care. New Jersey’s current telehealth statute has explicitly restricted the manner by which alcohol and drug counselor (ADC) interns, other graduates, and social work interns may deliver services. All are permitted to provide and bill for in-person clinical services (under supervision); however, they have all been prohibited from providing virtual services. This limits capacity, as many clients prefer counseling and other supports virtually as it is more convenient, with no time lost to travel and no need to overcome barriers, such as lack of transportation, childcare, illness and more. Such restrictions also impact continuity of care when individuals who receive in-person services suddenly face a barrier to care or just acquire a preference for telehealth. Waivers were developed during the pandemic to allow Clinicians (Field) • Clinician (Office-based) • Program Managers PIPELINE ATTRACTION ONBOARDING RETENTION Dwindling completions Shortages expected in near term Licensure delays Pending licensure precludes employers from signing clinicians More flexible alternatives Increasing preference for remote working opportunities Burnout due to double staffing Program managers often serve multiple roles due to the workforce shortages, leading to burnout Lucrative alternatives Clinicians expecting higher starting salaries with less experience Potentially excessive entry requirements Program manager job below top of operating license for master’s graduates / doesn’t take pre-master’s YOE into account Pain point driving workforce challenges Excerpt from New Jersey Department of Children and Families Labor Market Analysis slide 26 - June 2023 NJAMHAA also recommends passage of S1761/A2805 to bring accountability to New Jersey’s licensing Boards. The workforce study commissioned by the Department of Children and Families, in collaboration with the Department of Human Services, in 2023 confirmed that licensing delays preclude the hiring of clinicians (see chart above). Hiring an individual who has a pending application for licensure would result in paying top level wages for staff who cannot work to the top of that potential license. Common pain points experienced by each group along the recruitment-to-retention pathway ADC interns to obtain temporary certifications and other graduates to obtain temporary licenses in order to meet the standards within the telehealth statute. The provisions of both of these waivers have been incorporated into A2803/S3565, which NJAMHAA fully supports. Unfortunately, both the issuance of waivers and the text of the bill have overlooked social work interns, whom NJAMHAA recommends be added to the definition of healthcare provider in the telehealth statute. The statute must also be amended to clarify that current provisions only apply to licensed and certified staff who provide telemedicine (in addition to other telehealth services, such as education, care management and skills training) and that unlicensed and non-certified staff may provide telehealth services equivalent to the in–person services they are qualified for, deliver and bill Medicaid for. The legislation would require a report on the number of outstanding applications, the average time for approving an application, and a list of the most common errors on applications rendering them incomplete, among other data points, including staff costs, recruitment and retention initiatives and the status of Information Technology infrastructure. Such reporting requirements represent a first step toward improving the licensure process by clearly identifying where problems exist. Note: synthesized pain points do not represent every staff/provider experience