Document Type
DNP Project
Department
School of Nursing
Date of Degree
Spring 2025
Degree
Doctor of Nursing Practice (DNP)
Primary Advisor
Dr. Richard Ricciardi
Keywords
primary health care; behavioral medicine; policy making
Abstract
Background: This policy analysis explored the licensing requirements for primary care services compared with behavioral health and addiction services in agencies that were already licensed to provide the latter. This analysis looked at the challenges of doing so based on current New Jersey Department of Health regulations for licensing primary care facilities and Department of Human Services regulations for behavioral health and substance use treatment agencies. Creating an integrated health license moves agencies closer to providing whole person- centered care to vulnerable populations while enhancing quality of care and decreasing costs.
Objectives: The purpose of this policy analysis was to assess the barriers to implementing primary care into certified community behavioral health clinics based on existing licensing regulations across two state departments and engage stakeholders to pass legislature to streamline licensing requirements. This policy analysis identified successes and barriers to integrating primary care into existing behavioral health agencies and made recommendations for agencies and legislators. A policy analysis was conducted on existing laws and bills at the state and federal levels that seek to integrate primary care into behavioral health agencies. Current licensing regulations for outpatient mental health and substance use agencies and primary care services were reviewed and overlaps and gaps in requirements were identified. Barriers, perceived or otherwise, in agencies that have not yet integrated primary care into practice were identified. Legislators were contacted regarding the regulation conflicts and encouraged to support the pending legislation to create a guidance for agencies to integrate primary care services.
Methods: Extensive searches were done to identify regulations and waivers to regulations that were contradictory. A certified behavioral health community center that has integrated primary care was identified and an interview was conducted with a retired CEO to ascertain barriers and facilitators to the integration process. An agency wishing to integrate was interviewed regarding their knowledge of existing barriers and waivers to mitigate those challenges.
Results: One bill requiring the Department of Health to create language to license behavioral health agencies to also provide primary care services has been pending since the 2021 legislative session. A bill passed in 2017 to create an integrated license, but no action has taken place on that, even though the Commissioners of Health and Human Services were given 180 days after the effective date of the act to create rules and regulations for said integrated license. This timeframe has come and gone. The pending legislation would be the completion of the 2017 bill. It has had different sponsors each session and has not had a companion Senate bill since its introduction in 2021. With the discovery of the shared clinical space waiver, a significant barrier to integrating primary care services into behavioral health agencies is potentially mitigated. Whether the legislation gets passed or not, the waiver opens the door for integrating services and.
These findings were communicated to stakeholders, including elected officials who can advocate for legislation to enact new regulations and agencies who can advocate on behalf of patients to legislators regarding integrating care to improve healthcare delivery and cost effectiveness of care for Medicaid patients.
Copyright Notice
©2025 Christine Possemato. All rights reserved.
Recommended Citation
Possemato, C. (2025). Barriers to Integrating Primary Care Services into Behavioral Health Agencies: A Policy Analysis. , (). Retrieved from https://hsrc.himmelfarb.gwu.edu/son_dnp/187
Open Access
1
