The behavioral health sector is at a crossroads. The landscape is shifting rapidly, and for many, it feels harder than ever to plan. The One Big Beautiful Bill is a sweeping piece of legislation that redefines Medicaid eligibility and coincides with a broader restructuring of the U.S. Department of Health and Human Services (HHS) under the Trump administration.
Combined, these changes have introduced new questions about sustainability, staffing, and service delivery. While some details are still in flux, the direction is crystal clear: Providers will need to adapt.
To help make sense of what’s changing, I recently joined a discussion with Chuck Ingoglia, CEO of the National Council for Mental Wellbeing, and Monica Oss, CEO of OPEN MINDS. We looked at where the policy is headed and how agencies can prepare.
Here are three key takeaways for leaders preparing for the road ahead.
1. Medicaid work requirements will create operational challenges
Some states have previously tested work requirements—most notably in 2018-2019, Arkansas implemented work requirements, which led to widespread disenrollments. However, recent changes mark the first time such mandates are being implemented program-wide in Medicaid expansion states for “able-bodied” adults without dependents. Individuals with serious mental illness or substance use disorders are expected to be exempt, but the definitions and enforcement mechanisms are still being developed.
That ambiguity is already affecting planning. Behavioral health agencies are asking: How will we know which clients are exempt? What documentation will be required? Who’s responsible for tracking compliance, and what happens if a claim is denied?
From a technology standpoint, these changes raise important infrastructure questions. Intake processes may need to capture new data points. Eligibility logic may need to be updated more frequently. Payer rules could vary by state or change mid-year.
To paraphrase Monica Oss: “We’ve seen versions of this before. And what history tells us is that these requirements often reduce coverage without improving outcomes. So, now’s the time to figure out how you’ll track compliance, support clients who might be affected, and safeguard your revenue cycle from gaps in eligibility.”
2. Federal funding streams are changing but not vanishing
The legislation coincides with administrative proposals to restructure the Substance Abuse and Mental Health Services Administration and consolidate federal public health agencies. There are changes HHS introduced in the proposed budget that still require Congressional approval. At the same time, the bill eliminates several behavioral health-specific grants that many safety net providers have long relied on to fund crisis response, peer support, housing navigation, and early intervention programs. As Chuck Ingoglia noted during our discussion, “Behavioral health wasn’t targeted in this legislation. But we weren’t protected either. We got caught in the middle.”
While new funding channels like the Rural Health Fund will become available, they will largely flow through the states, introducing more variation in program design, oversight, and eligibility. Behavioral health providers will need to align their operations and reporting practices with new criteria faster than ever before.
To avoid being squeezed, agencies must be both grant-ready and advocacy-ready. That means tracking state-level implementation plans, understanding how policy changes affect your population, and demonstrating the value and outcomes of your services, often on short timelines.
3. Compliance and outcomes reporting are under the microscope
In today’s funding environment, outcomes reporting has become a compliance imperative. As grant criteria evolve and value-based payment models accelerate, behavioral health providers are being asked to deliver not just care, but proof of impact.
Funding decisions, whether from public sources, private payers, or foundations, are increasingly tied to demonstrable outcomes. But “outcomes” can mean different things to different stakeholders. To stay competitive, behavioral health organizations need to clearly report clinical progress, service utilization, payer mix, and program effectiveness—often in real time. Health plans want data tied to value-based payment models. Grantmakers want evidence of community impact. State agencies want metrics aligned with the Healthcare Effectiveness Data and Information Set)and/or Medicaid Section 1115 waiver goals.
The ability to pull this data quickly and reliably often depends on whether core systems, like your electronic health records, are structured to support it. That includes things such as: built-in outcomes tracking at the point of care, integration with financial and billing systems, and custom reporting dashboards that reflect funder-specific metrics. Organizations that rely on manual reporting or siloed systems will likely struggle to meet new requirements. In a tight funding environment, that can be the difference between receiving a grant or being ineligible.
WHAT’S NEXT
The days of treating technology as an optional line item are over. Leaders are recognizing that their ability to stay flexible—financially, clinically, and operationally— often hinges on the strength of their systems.
At a minimum, organizations need tools that can adapt to policy changes, support mobile and hybrid teams, and simplify administrative work for already stretched staff. That includes:
- Automating documentation to reduce clinician burnout, streamlining workflows as billing rules shift.
- Equipping leadership with real-time dashboards for decision-making.,
- Improving client communication through reminders, forms, and follow-ups.
When work requirements roll out, systems will need to flag at-risk clients, adjust claims logic, and document exemption statuses.
When state rules change, workflows may need to flex without requiring a system overhaul. When staffing is tight, onboarding and training must be faster and more intuitive. What we’re seeing from agencies that are weathering this moment well is that they’ve invested in infrastructure designed for change, not just compliance.
There’s no question that the next few years will bring significant changes. But behavioral health remains a bipartisan priority, and there is still room to plan, adjust, and advocate. That means having the right systems, the right partnerships, and the right information to make decisions in real time.
Josh Schoeller is the CEO of Qualifacts.