Policy Barriers and Opportunities at the State Level

Two recently released reports address barriers to behavioral health integration at a state level. They are: 

New Jersey

Innovative New Jersey clinicians have worked toward behavioral health integration, and some of those efforts were supported by the Nicholson Foundation. Clinicians reported their efforts are impeded by legal barriers in New Jersey’s licensure and reimbursement systems. The Nicholson Foundation asked Seton Hall Law School’s Center for Health & Pharmaceutical Law & Policy to examine those legal barriers, and to propose solutions that would facilitate appropriate behavioral health integration

This report reviews the clinical behavioral health literature and describes the statutory and regulatory law on licensure and reimbursement. It reflects extensive conversations with many primary care and behavioral health providers, academics, advocates, and government representatives.

The authors:

  • describe in clear terms both the “black letter” law and, equally as important, authoritative interpretations of that law as applied to behavioral health integration;
  • describe those instances in which current law impedes the development of integrated care. In some instances New Jersey law appears to lag the clinical developments in this area, suggesting that modifications in the law could benefit all; and
  • offer recommendations for adjustments to the regulatory framework governing reimbursement and licensure that would benefit behavioral health integration in New Jersey. 

Citations include the AHRQ Academy Product,  Guidebook of Professional Practices for Behavioral Health and Primary Care Integration Observations From Exemplary Sites; as well as publications by NIAC Members Alexander Blount, Roger Kathol, and Jürgen Unützer .


Access to behavioral health care services is one of the Commonwealth’s greatest health care challenges. A 2014 report of the Massachusetts Medicaid Policy Institute (MMPI), found that stakeholders prioritized behavioral health reform as one of the top five MassHealth issues for Governor Charlie Baker’s administration to consider.

The integration of physical and behavioral health services is a key reform being undertaken by some Massachusetts providers to address this issue. The goals of this report are to identify policy and regulatory barriers that may impede behavioral health integration and identify potential options for addressing these barriers.

The authors state:

“This report is intended to serve as a resource summarizing some key issues and potential opportunities as the state and key stakeholders move forward in the important effort to improve integration of physical and behavioral health.”

Posted June 2016