CMS Seeks Ideas for Innovative Behavioral Health Payment Model

CMS announced it will hold a meeting to gather input on potential models to pay for behavioral healthcare that would improve quality, expand access, and lower costs for beneficiaries.

According to an announcement in the Federal Register, the September 8 meeting at CMS’ Baltimore headquarters will be open to the public. Interested stakeholders, including community health groups, healthcare providers, nonprofit organizations, and patient advocates, may also submit comments online or by mail.

The initiative is to be established under the Center for Medicare and Medicaid Innovation (CMMI), which tests experimental payment models that strive to improve the quality and access of care while containing costs for beneficiaries of Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).

Some potential components of such a model could include increased use of telemedicine in behavioral health, multi-payer participation, or structuring as an advanced alternative payment model (APM) as outlined in the Medicare Access and CHIP Reauthorization Act. Advanced APMs allow practices to take on risk and potentially reap rewards based on the outcomes of their patients, which CMS explained could be a good solution for addressing the current deficits in behavioral healthcare.

These shortcomings, which can lead to unsatisfactory patient outcomes and unnecessary expenditures, mainly fall within 4 domains:

• Substance use disorders, including the widespread opioid crisis
• Mental disorders when patients have comorbid conditions
• Alzheimer’s disease and other forms of dementia
• Challenges related to the behavioral health workforce, such as provider shortages

The public meeting will convene 4 panel sessions that will allow behavioral health experts to discuss these domains from their varying perspectives. Attendees can then ask the panelists questions and make brief statements.

“The recommendations provided during this meeting will assist us, as we explore the possibility of designing a model test to address behavioral health payment and service delivery,” CMS concluded in the announcement.

HHS Secretary Tom Price, MD, had been an outspoken critic of CMMI during his days as a House Representative. In a letter signed by 178 other Republican legislators and sent to then-CMS Administrator Andy Slavitt last September, Price requested that CMMI halt its mandatory initiatives, such as bundled payment models. He wrote that by making such programs mandatory, CMMI had “exceeded its authority” and “failed to engage stakeholders,” resulting in beneficiaries and providers “blindly being forced into high-risk government-dictated reforms with unknown impacts.”

In his confirmation hearing to become head of HHS, Price emphasized that he supported CMMI’s goal of developing innovative, cost-cutting solutions, but objected to how it has “gotten off track a bit and has mandatorily been dictating to physicians how they must practice.”

The announcement of a public meeting to gather input on a new behavioral health payment model fits with Price’s request in the September 2016 letter asking CMS to commit to “establishing an open, transparent process that supports clear and consistent communication with physicians, patients, and other relevant stakeholders in the development of new CMMI models.”

It is also safe to assume that provider participation in the behavioral health payment model that results from this process will be completely voluntary, not mandatory.