By ROLF LOWE
On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) introduced new policies related to the Calendar Year 2024 Physician Fee Schedule intended to improve and promote access to mental health and substance use disorder services to meet the growing demand for these services. In its November 6, 2023, blog discussing the changes[1] CMS identified three areas the policies are intended to address which are expanding the behavioral health workforce, covering gaps in in access to behavioral health services and paying more accurately for behavioral health services.
The types of behavioral practitioners able to enroll in Medicare are being expanded to allow the enrollment of nearly 400,000 who were previously not eligible to bill the Medicare program for the services. CMS is allowing Marriage and Family Therapists and Mental Health Counselors to provide what they deem essential services, including individual and group psychotherapy. This includes all addiction counselors or alcohol and drug counselors who meet the Mental Health Counselor requirements. CMS has also instructed Medicare Advantage Plans (MAPs) to have an adequate number of outpatient behavioral health providers in their networks to help meet the identified demand for these services, as well as working on establishing payment for services in the area of community health integration and principal illness navigation. These latter services can also be be provided by peer support specialists to help beneficiaries with identified unmet social needs.
CMS has also established a new benefit in the area of intermediate level of behavioral health care for beneficiaries identified as Intensive Outpatient Program (IOP). This benefit can currently be provided by hospital outpatient departments, community mental health clinics, federally qualified health centers or rural health clinics. In addition, there will soon be an intensive outpatient program for individuals with opioid addiction problems called Opioid Treatment Programs (OTPs) .
Crisis services in a community setting have also been addressed through the policies. CMS is increasing the payment for crisis services provided in the community where behavioral health practitioners can meet the beneficiaries where they are to 150% of the Physician Fee Schedule rate. Payments for certain time-based behavioral health services and substance use disorder services are also being increased.
The implementation of these expanded behavioral health services will undeniably allow for improved access to care, which in turn should foster improved outcome for affected individuals. It will also bring new opportunities and considerations for providers working in these areas, including things such as reimbursement, documentation requirements, risk management and patient communication and education.
For additional information on CMS’ improvement to behavioral health benefits or assistance please contact Rolf Lowe of Wachler & Associates at (248) 544-0888.
[1] The CMS Blog can be found at the following URL, https://www.cms.gov/blog/important-new-changes-improve-access-behavioral-health-medicare-0