Weekly Health Care Policy Update – May 15, 2023

May 22, 2023

In this update: 

  • Federal Agencies
    • Covid-19 PHE Ended on May 11th; CMS Publishes Guidance on Telehealth and Medicaid
    • DEA Publishes Rule Temporarily Extending Telehealth Flexibilities for Prescribing Controlled Substances
    • CMS Seeks Public Comment on CCBHC PPS Modifications
    • FDA Recommends Individual Risk Assessment for Blood Donations
    • HHS OIG Publishes Report on Medicare Improper Payments for Psychotherapy under Covid-19 Policies
    • CMMI Posts Article on Health Equity Progress
    • HRSA to Hold Webinar on Changes to Data Reporting for 2023
    • FDA Advisory Panel Recommends OTC Birth Control
  • Other Updates
    • USPSTF Recommends Earlier Breast Cancer Screening
  • New York State Updates
    • Governor Hochul Declares State Disaster Emergency to Provide Aid to Asylum Seekers
    • DFS Issues Guidance on Coverage of COVID-19 Testing and Immunizations After PHE Expiration
    • DFS Issues Guidance on IDR Criteria for Reasonable Fees Determination 
    • DOH Issues Emergency Rule for the Investigation of Communicable Diseases
    • DOH Issues Notice for Proposed State Plan Amendments
    • NYSOFA Issues Press Release on Expansion of Partial Dual Eligible Population
    • OMH Announces Pre-Recorded Webinars to Provide Guidance for End of PHE
  • Funding Opportunities
    • HHS Announces $1 Million Children and Youth Resilience Challenge
    • OASAS Releases RFA for Opioid Prevention Coalitions in Seven High-Need Counties
    • SAMHSA Releases NOFO for Preventing Youth Overdose Program
    • SAMHSA Releases NOFO for Minority AIDS Initiative

Federal Agencies

Covid-19 PHE Ends on May 11th; CMS Publishes Guidance on Telehealth and Medicaid
The Covid-19 public health emergency (PHE) ended at the end of the day on May 11th. The Centers for Medicare and Medicaid Services (CMS) has posted several guidance documents to summarize policy changes that will result from the end of the PHE.
 
On May 10th, CMS published a fact sheet on telehealth policy and the end of the PHE. Some key reminders include: 

  • Medicare Telehealth: Most Medicare telehealth flexibilities have been extended through December 31, 2024 by statute, including: 
    • Enabling access to telehealth in any area, not just rural areas;
    • Allowing patients to stay in their homes for telehealth visits, rather than travel to a facility; and
    • Permitting audio-only telehealth delivery of services where patients are unable to access audiovisual telehealth.
  • HIPAA Flexibilities: The Office of Civil Rights (OCR) offered enforcement discretion during the PHE for noncompliance with privacy and security rules under the Health Insurance Portability and Accountability Act (HIPAA) related to the use of telehealth platforms. This expired May 11th with the PHE, but OCR is offering a 90-day transition period (through August 9th) for providers to make any necessary changes, during which it will continue to offer enforcement discretion.
  • DEA Rules: As announced on May 3rd, the Drug Enforcement Administration (DEA) has extended flexibilities on the prescribing of controlled substances for six months, through November 11th, at which time DEA plans to issue a final rule. Further details are in the next item in this update.

On May 8th, CMS published a bulletin on the implications of the end of the PHE for Medicaid and the Children’s Health Insurance Program (CHIP). Key areas covered include: 

  • Medicaid and CHIP coverage: As of September 30, 2024, Medicaid and CHIP programs will no longer be required to cover Covid-19 vaccines and their administration, testing, and treatments without cost sharing­­­. The 100% FMAP for state expenditures for medical assistance for vaccines and their administration will also end on this date.
  • Telehealth: Telehealth flexibilities under Medicaid and CHIP are not tied to the Covid-19 PHE, and CMS encourages states to continue to cover these services.
  • PHE Flexibilities: The end of the PHE is accompanied by the end of several types of Medicaid and CHIP flexibilities: 
    • Section 1135 Waivers: The end of the Covid-19 National Emergency on April 10th previously ended CMS’s authority to issue new, prospective section 1135 waivers related to the pandemic. Any waivers currently in effect and approved prior to April 10th were able to remain in effect until May 11th.
    • Disaster Relief State Plan Amendments (SPAs): Disaster Relief SPAs were able to remain in effect until May 11th, or any earlier approved date.
    • Section 1915(c) Appendix K: Appendix K modifications to home and community-based services (HCBS) waivers, such as those applying to the Office for People with Developmental Disabilities (OPWDD) waiver, may ­­expire no later than six months after the end of the PHE (November 11th).

The telehealth fact sheet is available here. The Medicaid bulletin is available here.
 
DEA Publishes Rule Temporarily Extending Telehealth Flexibilities for Prescribing Controlled Substances
On May 10th, the Drug Enforcement Agency (DEA) published in the Federal Register a temporary rule to temporarily extend Covid-19 PHE policies on telehealth prescribing of some controlled substances, including buprenorphine and stimulants like Adderall. During the PHE, DEA had waived the requirements for practitioners to conduct an in-person visit before prescribing these controlled substances and to be registered with the DEA in every state where their patients are located.
 
Though the DEA announced its intent to temporarily extend these flexibilities on May 3rd(as covered in SPG’s update last week), the text of the rule was not published until May 10th. In the rule, DEA acknowledges that based on the almost 40,000 submitted comments, a general extension is appropriate. DEA has therefore delayed its issuance of a final rule on this subject for six months, until November 11th.
 
In the meantime, providers may continue to prescribe controlled substances without an in-person visit and without being DEA-registered in a given state. Specifically, prescribers may continue to establish new patient relationship through telehealth through November 11, 2023, and may then continue to prescribe controlled substances to existing for up to one year, through November 11, 2024, under the existing Covid-19 PHE rules.
 
The temporary rule is available here.
 
CMS Seeks Public Comment on CCBHC PPS Modifications
On May 12th, CMS issued a notice that it is seeking public comment on modifications to the Prospective Payment System (PPS) methodologies for Certified Community Behavioral Health Centers (CCBHCs). Under the current federal CCBHC demonstration, CCBHCs are outpatient behavioral health clinics that must meet a set of national standards established by the Substance Abuse and Mental Health Services Administration (SAMHSA), including offering services without regard for the patient’s ability to pay. In turn, demonstration CCBHCs are eligible to receive a PPS rate meant to account for the total cost of care for Medicaid patients. Currently, CCBHCs may choose between PPS-1 (which provides a daily rate per visit) and PPS-2 (which provides a monthly rate).
 
CMS now proposes to establish two new PPS options, PPS-3 (a new daily rate) and PPS-4 (a new monthly rate). Under PPS-3 and PPS-4, a set of Special Crisis Services (SCS) will be carved out of the PPS payment and billed as a separate rate (daily or monthly, respectively) during periods in which these services are provided. SCS includes: 

  • 9813 CCBHC mobile crisis services;
  • CCBHC Demo mobile crisis services (those other than 9813 services); and
  • Crisis stabilization services at the CCBHC.

New York’s CCBHCs currently operate under PPS-1. Other proposed changes include: 

  • CMS intends to modify PPS-2 to make the separation of “special populations” optional. Currently, under PPS-2, CCBHCs must be paid a separate rate for higher-needs special populations, as identified by the state.
  • CMS would require States to rebase CCBHC rates using actual cost data every three years, starting with cost data from Demonstration Year 2 (July 2018 through June 2019 for New York).
  • CMS would make changes to the quality bonus payment (QBP) system, including: 
    • Making quality bonus payments (QBP) optional for daily rate CCBHCs (PPS-1 and PPS-3);
    • Allowing tiered quality payments for individual QBP measures, for CCBHCs that meet minimum thresholds across all required QBP measures; and
    • Updating the set of QBP measures by adding new measures and changing some existing measures to become optional.

The full proposed guidance is available here. Comments may be submitted to CCBHC-Demonstration@cms.hhs.gov with the subject line “Public Comment on Updated PPS Guidance” by June 2nd.
 
FDA Recommends Individual Risk Assessment for Blood Donations
On May 11th, the Food and Drug Administration (FDA) finalized a policy to recommend individual risk assessment to determine eligibility for blood donations. The change is expected to expand the number of people eligible to donate blood, while maintaining safeguards to protect the safety of their blood supply. The updated policy is consistent with policies in the United Kingdom and Canada, and with best available scientific evidence.
 
The new policy eliminates time-based deferrals and screening questions specific to men who have sex with men (MSM) and women who have sex with MSM. Instead, all prospective blood donors will answer a series of individual, risk-based questions to determine eligibility. Prospective donors who report having had in the past three months both (1) either a new sexual partner or more than one sexual partner and (2) anal sex would be deferred, as would individuals taking medications to treat or prevent HIV infection (PrEP and PEP). These policies are intended to reduce the likelihood of donations by individuals with new or recent HIV infection who may be in the window for detection of HIV by nucleic acid testing.
 
The full announcement is available here.
 
HHS OIG Publishes Report on Medicare Improper Payments for Psychotherapy under Covid-19 Policies
On May 9th, the Office of the Inspector General (OIG) at the Department of Health and Human Services (HHS) published a report on Medicare improper payments for psychotherapy services during the first year of the Covid-19 PHE. In its sample, OIG found that the majority of Medicare payments were for claims that did not fully meet requirements.

The report specifically analyzes telehealth and non-telehealth psychotherapy billing from March 2020 through February 2021. Over this period, Medicare Part B paid $1 billion for more than 13.5 million psychotherapy services. OIG found that for 128 of the 216 sampled enrollee days, providers did not meet Medicare requirements and guidance when billing for some psychotherapy services, including services provided via telehealth. Errors included lack of time documentation, incomplete or missing treatment plans, and missing or incomplete service documentation.

As a result, OIG estimates that of the $1 billion that Medicare paid for psychotherapy services, providers received $580 million in improper payments for services that did not comply with Medicare requirements. This included $348 million for telehealth services and $232 million for non-telehealth services. However, OIG did not recommend recovering payments based on this extrapolation.

OIG made six recommendations to CMS, which include: 

  • Recover $35,560 in improper payments from the sampled claims;
  • Notify appropriate providers of the results of the audit to encourage them to identify and return overpayments voluntarily;
  • Conduct medical reviews of psychotherapy services to verify proper documentation;
  • Implement system edits for psychotherapy services to prevent payments for incorrectly billed services;
  • Strengthen educational efforts on appropriate billing; and
  • Review the Medicare program’s Local Coverage Determinations (LCDs) to identify how to more effectively promote program integrity.

CMS concurred with the first, second, third, and fifth of these recommendations. The full report is available here.

CMMI Posts Article on Health Equity Progress
On May 11th, the Center for Medicare and Medicaid Innovation’s (CMMI) Chief Medical Officer Dora Hughes authored a blog post in Health Affairs Forefront outlining CMMI’s health equity strategy, progress made over the last year, and additional areas of focus in the future. CMS defines health equity as “the attainment of the highest level of health for all people, where everyone has a fair and just opportunity to attain their optimal health regardless of race, ethnicity, disability, sexual orientation, gender identity, socioeconomic status, geography, preferred language, or other factors that affect access to care and health outcomes.” To promote its health equity initiative, CMMI proposed to develop new models and revise existing models to promote and incentivize equitable care, increase participation of safety net providers, increase collection and analysis of equity data, and monitor and evaluate models for health equity impact.
 
The blog details the progress made in each of these four areas, including the introduction of new and revised models with a prominent focus on health equity, engaging safety-net provider stakeholders to identify strategies for addressing barriers to safety-net provider participation in CMMI models, requiring the collection and analysis of equity data, expanding analytic work for current models to capture health equity impact, and conducting a retrospective, cross-model review focused on underserved populations.
 
Going forward, the Innovation Center plans to take several steps, including: 

  • Sharpening its focus on the needs of underserved populations not well represented in current models, such as people with disabilities;
  • Building upon earlier investments in rural health;
  • Continuing to explore mechanisms for social risk adjustment of payments, including new indices;
  • Testing models to address the high cost of drugs; and
  • Identifying and remedying aspects of current model designs that may lead to inequities.

The blog post is available here.
 
HRSA to Hold Webinar on Changes to Data Reporting for 2023
On May 9th, the Health Resources and Services Administration (HRSA) announced that, for 2023 reporting, health centers will submit aggregated Uniform Data System (UDS) data, including all UDS tables and appendices, via HRSA’s Electronic Handbooks using the traditional submission method. Health centers are also encouraged to submit patient-level data, or UDS+, if they are ready. These changes are part of HRSA’s ongoing UDS Modernization Initiative.
 
More information on the Modernization Initiative is available here. HRSA will hold a webinar on June 6th from 1pm to 2:30pm ET to further discuss these changes. Registration for the webinar is available here.
 
FDA Advisory Panel Recommends OTC Birth Control
On May 10th, a Food and Drug Administration (FDA) advisory panel voted unanimously to support making a birth control pill available over-the-counter (OTC). The application is from pharmaceutical manufacturer Perrigo, for the pill Opill, which contains only progestin. Progestin-only pills can have reduced side effects as compared to combination pills, but also have reduced effectiveness when not taken appropriately.
 
The panel analyzed data to assess whether the pill would be safe, effective, and easy for women of all ages to use appropriately, and concluded that the benefits outweigh the risks. The American Medical Association, the American College of Obstetricians and Gynecologists, and the Society for Adolescent Health and Medicine have all publicly supported making OTC birth control pills available. The FDA will make its final decision this summer.

Other Updates

USPSTF Recommends Earlier Breast Cancer Screening
On May 9th, the United States Services Preventive Task Force (USPSTF) released draft guidance updating its recommendation for breast cancer screening. The Task Force now recommends (with a B rating) that all women be screened for breast cancer every other year beginning at age 40. The Task Force’s previous recommendation was that women begin screening at age 50, and that women in their 40s make an individual decision about screening based on their health history and preferences. The changes are based on new data about breast cancer in people younger than 50. If finalized, the recommendation would clarify that all women should begin screening at age 40 and do so every other year. This change would have little impact on insurer coverage of mammograms because the Affordable Care Act already requires coverage of an annual mammogram beginning at age 40.
 
The draft recommendation is available here and a press release is available here. Comments will be accepted until June 5th.

New York State Updates

Governor Hochul Declares State Disaster Emergency to Provide Aid to Asylum Seekers
On May 9th, Governor Hochul issued an Executive Order declaring a State Disaster Emergency in response to an anticipated surge of asylum seekers following the expiration of the federal Title 42 immigration policy with the end of the Covid-19 PHE on May 11th. The Order implements the State Comprehensive Emergency Management Plan and temporarily suspends or modifies regulations to provide greater flexibility for NYS and local governments in procuring and mobilizing resources for asylum seekers. The Governor’s office notes that this will enable the deployment of more than $1 billion for shelter, healthcare through NYC Care, and other public assistance initiatives approved in the State Fiscal Year (FY) 2024 Enacted Budget earlier this month.
 
The Order also would ensure that a landlord-tenant relationship is not created between entities who are providing temporary housing for at least thirty days to assist with the emergency response (including, but not limited to, hospitals and not-for-profit housing providers) and individuals in need of shelter.  
 
The Executive Order is available here. The Order is effective through June 8th, unless further extended. The Governor’s press release is available here.
 
DFS Issues Guidance on Coverage of COVID-19 Testing and Immunizations After PHE Expiration
On May 10th, the NYS Department of Financial Services (DFS) issued a circular letter to regulated insurance plans to provide guidance on covering Covid-19 diagnostic testing and immunizations after the expiration of the Covid-19 PHE. As of May 12th, the following coverage provisions are in effect:   

  • Plans may impose cost-sharing, prior authorization, and/or medical management requirements for Covid-19 laboratory testing and related outpatient visits.
  • Plans are not required to cover OTC Covid-19 diagnostic tests.
  • Plans are not required to cover out-of-network Covid-19 laboratory testing and related outpatient visits, unless one of the requirements for an out-of-network coverage exception is met (i.e., the policy/contract covers out-of-network services; the plan has approved a referral to an out-of-network provider; the services result in a surprise bill; or the services are emergency services that are provided in a hospital).
  • Plans must continue to cover in-network Covid-19 immunizations at no cost-sharing for children under 19 years of age covered under all policies/contracts and for adults under non-grandfathered policies/contracts.
  • Plans are not required to cover out-of-network Covid-19 immunizations.

Plans should notify beneficiaries of implementation dates for changes in testing and immunization coverage policies, in accordance with federal guidance available here. The circular letter applies to regulated individual, small group, and large group health insurance policies. It does not apply to Child Health Plus, Essential Plan, and Medicaid managed care coverage.
 
The circular letter is available here. Questions may be submitted to health@dfs.ny.gov.
 
DFS Issues Guidance on IDR Criteria for Reasonable Fees Determination 
On May 9th, DFS issued a circular letter to regulated insurance plans to provide guidance regarding the criteria used to determine reasonable fees under New York’s independent dispute resolution (IDR) process. When there is a payment dispute between plans and providers pertaining to out-of-network services and surprise bills, either party can submit an application to DFS for assignment to an IDR entity.
 
The letter reminds plans and providers of the criteria used by IDR entities to determine whether the provider’s charge or the plan’s payment is reasonable, which include: 

  • Whether there is a gross disparity between the charged fee and fees that the provider accepts (or the issuer’s paid fee and fees that the issuer pays) when other patients receive services on an out-of-network basis;
  • The provider’s level of training and experience;
  • The provider’s usual out-of-network charge for comparable services;
  • The circumstances and complexity of the particular case;
  • Individual patient characteristics;
  • The plan’s median in-network rate for reimbursing similarly qualified providers for the same or similar services in the same region; and
  • For physician services, the usual and customary cost of the service.

DFS notes that all factors should carry the same weight, and no single factor is determinative. As such, plans and providers are advised to submit all relevant information to the IDR entity at the time of application or upon the IDR entity’s request, to allow for the IDR to make a determination.

The circular letter is available here. Questions may be submitted to health@dfs.ny.gov.
 
DOH Issues Emergency Rule for the Investigation of Communicable Diseases
On May 10th, the NYS Department of Health (DOH) issued emergency regulations that update DOH’s and local health departments’ authority to take specific actions to monitor and respond to disease outbreaks. The provisions of the emergency rule were originally proposed on April 19th and are described in SPG’s summary, available here. Currently, the emergency rule is set to expire June 22nd, but DOH intends to adopt the rule permanently. The emergency rule is available here. Comments can be submitted to Katherine Ceroalo at regsqna@health.ny.gov until July 9th. 
 
DOH Issues Notice for Proposed State Plan Amendments
On May 10th, DOH issued a public notice that it intends to amend the Medicaid State Plan to: 

  • Continue enhanced private duty nursing fees that reflect a 30% increase for providers enrolling in the program and attesting to having the necessary training and an additional 45% increase for providers participating in a public provider directory, effective May 12th through March 31, 2024; and
  • Decrease reimbursement for COVID-19 related tests and specimen collection to 60% of the Medicare fee, effective May 12th through September 30, 2024. 

The notice is available here. The proposed SPAs will be available here for public review. Comments can be submitted to spa_inquiries@health.ny.gov.
 
NYSOFA Issues Press Release on Expansion of Partial Dual Eligible Population
On May 9th, the NYS Office for the Aging (NYSOFA) published a press release on the expansion of the Medicare Savings Program (MSP). Due to increased income eligibility thresholds passed in the 2022-23 NYS Budget, NYSOFA expects that the MSP will provide financial assistance to an additional 300,000 Medicare beneficiaries as a result of the increased income eligibility thresholds to 186% of the federal poverty line (FPL), or $2,280 per month for an individual and $3,077 per month for a couple. MSP enrollees, also referred to as partial dual eligibles, can receive payment assistance for their Part B premiums and are automatically enrolled in the Extra Help program (also known as the Low Income Subsidy for Medicare Part D). 
 
The press release is available here. Information on the MSP application process is available here.
 
OMH Announces Pre-Recorded Webinars to Provide Guidance for End of PHE
On May 8th, the NYS Office of Mental Health (OMH) announced that it would publish pre-recorded webinars that provide an overview of regulatory changes that are in effect after the expiration of the federal PHE on May 11th. The information in the webinars corresponds directly to recently issued OMH guidance documents “Impact of the End of the Federal PHE on the OMH System” and “Telehealth Services Guidance for OMH Providers” (SPG’s summary is available here). Links to the webinar series and guidance documents are available here.

Funding Opportunities

HHS Announces $1 Million Children and Youth Resilience Challenge
On May 5th, HHS announced the HHS Children and Youth Resilience Challenge, which will provide $1 million in funding for “innovative community-led solutions to promote resilience in children and adolescents affected by the Covid-19 pandemic and other disasters.” Promising solutions may include any activity “identified and driven” by members of the community that “involves community members working together to identify goals and develop plans that build on community strengths and implement those plans.”
 
The challenge will be conducted in two phases. In Phase 1, lasting until July 2023, interested organizations may submit proposals. HHS will select up to 14 organizations as finalists and award them $25,000 each, which HHS encourages them to use to support Phase 2. In Phase 2, running from August 2023 to May 2024, finalists will implement pilot programs based on their proposals. From this phase, HHS will award a grand prize of $300,000 and two runner-up prizes of $175,000 each. Finalists will also present at an in-person summit in Washington, D.C. in summer 2024.
 
Phase 1 proposals are due July 7th. An informational webinar will be held on May 18th, from 3pm to 4:15pm ET. Registration is available here. More information on this initiative as well as another HHS mental health initiative (FindSupport.gov, an online guide to mental health resources) is available in the press release here.
 
OASAS Releases RFA for Opioid Prevention Coalitions in Seven High-Need Counties
On May 10th, the Office of Addiction Services and Supports (OASAS) released a Request for Applications (RFA) for the Fentanyl, Opioids, Rx (FOR) Community Prevention Coalition initiative, which will fund community coalitions to deliver evidence-based opioid prevention services and implement environmental change strategies in counties disproportionately impacted by opioid-related overdoses and deaths. FOR Coalitions will be expected to provide the following activities: 

  • Conduct a comprehensive needs assessment of the community;
  • Develop and implement a strategic plan to engage underserved communities;
  • Develop a relationship with the OASAS Regional Addiction Resource Center (RARC);
  • Provide harm reduction informational sessions and training events for community members; and
  • Mentor or develop a prevention-focused youth coalition in a middle or high school.

Through this initiative, OASAS will award $1.4 million in total annual funding to 7 coalitions (up to $200,000 annually per awardee) over a four-year program period. OASAS will award one coalition in each of the following high-need counties: Bronx, Chautauqua, Chemung, Dutchess, Greene, Sullivan, and Ulster.
 
Eligible applicants are not-for-profit entities and local government units (LGUs) that are either existing prevention-focused coalitions working with a RARC in a high-risk county, or a fiscal agent acting on behalf of an existing prevention-focused coalition.
 
The RFP is available here. Questions can be submitted to Grants@oasas.ny.gov with the subject line “RFA SETT – 23009” by May 17th. Applications should be submitted to Grants@oasas.ny.gov with the subject line “RFA – OASAS SETT-23009, [Provider Name]” by June 16th.  
 
SAMHSA Releases NOFO for Preventing Youth Overdose Program
On April 28th, SAMHSA released a notice of funding opportunity (NOFO) for the Preventing Youth Overdose: Treatment, Recovery, Education, Awareness and Training (PYO TREAT) program, which aims to increase prevention, treatment, and recovery services for youth with or at risk for opioid use disorder (OUD) and/or co-occurring disorders. Funding will be used to: 

  • Support organizations that raise community awareness about fentanyl;
  • Improve access to medications to treat OUD in underrepresented groups;
  • Provide education and training activities for families and school personnel; and
  • Enable providers to support youth with their treatment and recovery.

Eligible applicants are domestic public and private non-profit entities, including organizations with appropriate expertise in providing services or programs for children, adolescents, or young adults (excluding certain schools). SAMHSA anticipates making four awards of up to $450,000 annually per award, for a performance period of three years.
 
The NOFO is available here. Questions may be submitted to Arianna Douglas at Arianna.Douglas@samhsa.hhs.gov. Applications are due June 27th.
 
SAMHSA Releases NOFO for Minority AIDS Initiative
On April 21st, SAMHSA released a NOFO for the FY 2023 Minority AIDS Initiative (MAI): The Substance Use and HIV Prevention Navigator Program for Racial/Ethnic Minorities which aims to fund outreach and prevention efforts for high-risk racial/ethnic minority populations vulnerable to substance use, HIV, and viral hepatitis. Award recipients must implement evidence-based prevention strategies and provide navigation services to link individuals to support services.  
 
Through this initiative, SAMHSA will award $10.3 million in total annual funding to 34 participants (up to $300,000 annually per awardee) over a five-year program period. Eligible applicants are domestic public and private non-profit entities located in states and communities hardest hit by the HIV Epidemic, as listed here, including all NYC boroughs except Staten Island. MAI recipients from the previous four fiscal years are ineligible to apply.
 
The NOFO is available here. Applications are due by June 20th. Questions can be sent to Mai-pn@samhsa.hhs.gov or Sara Fleming at Sara.Fleming@samhsa.hhs.gov.