Foxx Chubby Health Policy Consulting

08/21/2025

We partner to do work we believe in for people we care about. So thankful for the opportunity to participate with . Looking forward to many more chances to help improve the state of our behavioral health system.

If you need help integrating quality and compliance into your practice... [email protected]. We'd love to partner with you.

Starting & Growing a Community-Based Behavioral Health Business in MarylandThis webinar is designed to help current and aspiring community-based behavioral h...

08/19/2025

Late this afternoon, I got a panicked text from a client.
She’s a seasoned clinician, owns a community-based mental health organization, and recently took on the challenge of becoming a surveyor.

Her text read:
“I’m about to leave a survey. We have to talk. We need to meet for a full day every month to go through everything.”

When she called, she explained what she had just experienced on her first survey: the organization she visited hadn’t updated documentation, reviewed policies, or completed basic administrative tasks in the entire three years since they were accredited.

I reminded her: “That’s why we built your compliance system the way we did. The task list tracks progress on every standard, cycles through annual policy reviews, and documents strategy along the way. And remember—we redesigned your communications process so the work is lighter and more sustainable.”

Later, after reflecting, she told me: “Thank you. Now I get it. I am so thankful you stayed on us.”

This is why we do the work. At Foxx Chubby HPC, we design systems that prevent panic. When compliance and quality are woven into daily operations, they stop being overwhelming tasks and start being part of the culture. That’s when you know it’s working.

If your compliance feels more like panic than process, let’s talk. www.foxxchubbyhpc.com or [email protected]

Foxx Chubby Health Policy Consulting assists owners of community-based mental health organizations in creating evidence based and compliant clinical and business practices. Our website offers additional support for owners by providing and highlighting resources and forums.

08/14/2025

Yesterday, my heart sank a little...

I met with a community-based mental health organization leader (and potential client) who proudly told me:

“Well… I put all the standards into ChatGPT and printed an entire manual.”

Listen… learning to use AI tools has absolutely changed the pace of my business. But I still have to be the expert in what I’m doing.

It says right in the disclaimer — “may be wrong.”

Using ChatGPT to write a bunch of policies you never read, implement, revise, or train on?
❌ Pointless.
Just as pointless as hiring a consultant to draft policies you never read, implement, revise, or train on.

AI is a tool, not a crutch. Yes — give it a standard and it’ll churn out a whole set of related policies for you.

But here’s the gag… you still have to:
• Know what the policy means
• Understand how it applies to your organization
• Train your staff on it
• Modify it to match your actual practice
• Implement it consistently

Otherwise, it’s just a beautifully written document sitting in a folder.

If you want to learn how to use AI the right way — so it improves your organization without sacrificing accuracy, compliance, or quality — let’s talk.
________________________________________

Foxx Chubby Health Policy Consulting
Partnering to do work we believe in for people we care about.📧 [email protected] | 🌐

Foxx Chubby Health Policy Consulting assists owners of community-based mental health organizations in creating evidence based and compliant clinical and business practices. Our website offers additional support for owners by providing and highlighting resources and forums.

06/02/2025

Last thing before I sign out on this first Monday of June 2025! 💥
(a little cross promotion)
The Maryland Behavioral Health Administration (BHA) is hosting TWO virtual listening sessions to gather feedback on the proposed updates to COMAR 10.63. Get the details directly from Carelon: https://s18637.pcdn.co/wp-content/uploads/sites/75/5.30.25-COMAR-10.63-Regulation-Listening-Sessions.pdf?_gl=1*1eb8xq3*_ga*MTA3OTEyNzEwMC4xNzQ4ODc3MDg4*_ga_DVJWV4YXE8*czE3NDg5MDA1OTQkbzMkZzEkdDE3NDg5MDE3MzIkajYwJGwwJGgw

These changes affect all licensed community behavioral health providers—covering compliance, staffing, licensure, and sanctions. Let’s show up informed. These regs shape how we all operate—our voices matter. 💬

👥 Need help reviewing the rule and preparing?
We are hosting a private prep session for our clients on Thursday, June 5 at 2:00 PM to break it all down and make sure everyone’s ready to ask informed questions.

We have room for 2–3 more community providers to join.

📩 DM or email [email protected] if you'd like to join.
✅ Not getting Carelon provider updates? Sign up here: https://maryland.carelonbh.com/sign-up-for-provider.../

05/21/2025

🚨 Maryland BHA Releases Proposed COMAR 10.63 Rule Update 🚨
🗓️ Public Comment Deadline: June 16, 2025

The Maryland Behavioral Health Administration (BHA) has released proposed updates to COMAR 10.63, and there are a few important highlights providers should know:

🔑 A key callout: This proposed action does not include changes to COMAR Sections 10.63.03, .04, or .05, which cover service descriptions, criteria, and delivery requirements for both accreditation- and non-accreditation-based licensed services. Based on yesterday's press release, there could be more changes coming.

🔧 Many of the proposed updates aim to clarify and codify existing requirements or operational expectations that providers have been expected to follow—but which had not been fully outlined in previous regulations.

📌 The overall focus appears to be on alignment, reinforcement, and transparency, rather than introducing entirely new standards.
Here’s what’s changing (and why it matters 👇):

🔍 COMAR 10.63.01 – General Compliance & Reporting
✅ Mandatory Corporate Compliance Plans & Officers
✅ Alignment with federal and accreditation standards
✅ Codified Critical Incident Reporting
✅ Site standards, recordkeeping, and telehealth delivery expectations
✅ Audio-only telehealth excluded unless otherwise permitted
✅ Requirements for planned and unplanned service discontinuation

👥 COMAR 10.63.02 – Staffing
✅ Role-based onboarding and annual training
✅ Ongoing background checks + exclusion list monitoring
✅ Definitions of Organizational vs. Program-Level staff
✅ Defined roles: Clinical Director, Program Director, Rehabilitation Specialist, Peer Support

📋 COMAR 10.63.06 – Licensure Process
✅ Codifies existing licensing and renewal processes
✅ Emphasis on documentation, disclosure, and program integrity

⚖️ COMAR 10.63.09 – Corrective Actions & Sanctions
✅ Framework for deficiency notices, corrective plans, and sanctions
✅ Public notification requirements for sanctioned providers
✅ Reinforces transparency and accountability

🗣️ We’re hosting a safe-space community discussion on May 28 to review the proposed rule and prepare public comments. Join us on Zoom at 12:30 PM.
🔗 https://lnkd.in/erzv3_GW

This is not a BHA event—this is a community provider space to share insights, ask questions, and prepare real feedback.

Source of truth information:
Press release: https://lnkd.in/eDhpm6RG
Proposed Rule: https://lnkd.in/eXzsTEbM

hashtag hashtag hashtag hashtag hashtag hashtag hashtag hashtag hashtag hashtag

This link will take you to a page that’s not on LinkedIn

01/10/2025

At Foxx Chubby Health Policy Consulting (HPC), our journey began with a clear purpose: addressing the critical need for quality assurance and provider education about compliance and continuous improvement in Maryland’s Community-Based Behavioral Healthcare system. Recognizing this need, we leveraged our extensive experience in government health programs, behavioral health, and consulting to bring a meaningful voice to the stakeholder landscape. It has been an exciting, albeit challenging, journey—but one that has been profoundly rewarding.

Over the years, we’ve been blessed to work alongside incredible partners across the continuum of care, identifying opportunities and solutions to ensure individuals in our state have access to quality community-based mental health services. However, as headlines highlight the devastating impact of substance use disorder (SUD) and the Governor's push to cut $2 billion from the state budget, we are reminded that our work is far from done.

This week, we are excited to share the first Foxx Chubby HPC Community Newsletter of the year. This issue focuses on the intentional slowdown of the Maryland Behavioral Health Administration (BHA) licensing process—an issue that cannot be ignored. Maryland’s behavioral health system is already strained, and the current licensing process discourages much-needed new investment in mental health and SUD services. While we recognize the challenges our partners at BHA face and the levers they are using to address systemic issues, there are alternative strategies that could be implemented—ones that do not disproportionately harm small providers. By working together, we can find balanced solutions that support both compliance and growth in the behavioral health sector.

We remain committed to being part of the solution, and we hope this newsletter sparks important conversations about how we can work together to build a system that prioritizes access, equity, and quality care for all Marylanders.

https://www.foxxchubbyhpc.com/post/foxx-chubby-hpc-news-letter-1-25

://www.foxxchubbyhpc.com/post/foxx-chubby-hpc-news-letter-1-25

At Foxx Chubby Health Policy Consulting (HPC), our journey began with a clear purpose: addressing the critical need for quality assurance and provider education about compliance and continuous improvement in Maryland’s Community-Based Behavioral Healthcare system. Recognizing this need, we leverag...

07/29/2024

We, too, are collecting our thoughts now that we have attended the last of the BHA scheduled stakeholder meetings regarding the PROPOSED updates and changes for COMAR 10.63 community-based mental health services regulations. After taking in so much information, there is so much more to do. But first...let's take a minute to breath. Then, let's self-assess, plan, and act!

As our team continues to process the proposed updates to the Maryland Department of Health, Behavioral Health Administration COMAR 10.63 community-based mental health services regulations, I recall a conversation I had at a local crab house. I met two women in the behavioral health field—one a sea...

02/08/2024

Optum Compliance Alert
Compliance Reminder #2
February 7, 2024

Reach out to [email protected] if you need help understanding the requirements.

What's the Issue? Optum and BHA have identified widespread compliance problems with SUD, IOP, and PHP programs.

Where's the Source of Truth Documentation?
Reminder #2:https://maryland.optum.com/content/dam/ops-maryland/documents/provider/Alerts/february-2024/Compliance_Issues_PHP_IOP_2.7.24.pdf

Optum BH Provider Page: https://maryland.optum.com/content/ops-maryland/maryland/en/bh-providers.html

What's our Recommendation?
1. Evaluate your program to determine if these activities are occurring.
2. Change your practices and document those changes.
3. Talk with your compliance professional about how to reconcile with Medicaid.

[email protected] if you or your team need help!