New focus on whole person care relies on behavioral health integration
CMS proposes making BHI coordination of services reimbursable
As part of its new approach to whole person health care, the Centers for Medicare and Medicaid Services (CMS) wants to reimburse clinical psychologists and clinical social workers for coordinating behavioral health integrations and services for Medicare patients.
The plan was introduced in the CY 2023 Medicare Physician Fee Schedule Proposed Rule issued in July.
“CMS is proposing to create a new General BHI service personally performed by a clinical psychologist (CP) or clinical social worker (CSW) to account for monthly care integration where the mental health services furnished by a CP or CSW are serving as the focal point of care integration,” said Eloy Paez, Executive Vice President Behavioral Health, INFINITY.
Under the proposal, psychiatric diagnostic evidence could serve as the initiating visit for the new general BHI service.
“This is a next step in the implementation of a CMS initiative to improve access to and quality of mental health care services,” Paez said. “It’s part of Medicare’s new overall emphasis on whole person care, a holistic approach to health care that encompasses efforts in physical health, behavioral health and health-related needs with the potential to impact patient outcomes and wellbeing.”
New Behavioral Health Strategy
In its 2022 Behavioral Health Strategy, CMS set out goals to remove barriers to behavioral health care and services, supporting a person’s whole emotional and mental wellbeing and promoting person-centered behavioral health care.
The CMS Behavioral Health Strategy covers multiple elements including access to prevention and treatment services for substance use disorders, mental health services, crisis intervention, and pain care; and further enable care that is well-coordinated and effectively integrated.
One of the objectives is to increase detection, effective management and/or recovery of mental health conditions through coordination and integration between primary and specialty care providers. The proposal to create a new General BHI service aligns with that objective, Paez said.
“If you have ever wondered how much influence comments have on the actions of CMS, this is a good example of a case in which CMS used comments as the basis for action,” Paez said. “CMS attributed the proposal to create a new General BHI service to comments received during PFS rulemaking for CY 2017 and 2018.”
Commenters during those rulemaking periods suggested that CMS allow professionals who were not eligible to report the approved initiating visit codes to serve as the primary hub for BHI services. They also suggested that behavioral health integration should include in depth psychological evaluation delivered by a clinical psychologist.
Full scope of practice
In addition to allowing reimbursement for behavioral health integration providers to coordinate BHI services, the proposed rule for CY 2023 would also allow providers to practice to the full scope of their licensure, and operate outside the direct supervision of a physician, under general supervision instead.
“From a practical standpoint, this would have more of an impact in some states than others, because scope of practice is determined on a state-by-state basis and states have differing licensure laws,” Paez said. “But to the extent allowed by the state, the availability of behavioral health services would increase if therapists were able to provide services under general rather than direct supervision. A physician may not necessarily have to be on site for services to be provided.”
To be covered under Medicare, services would still have to be provided by auxiliary personnel incident to the services of a physician or non-physician practitioner, Paez said
Read more about how the proposed rule and its aim to enhanced access to behavioral health services.
INFINITY can help
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