Proposed MPFS (2023) Policies for Behavioral Health Care

1. Proposed MPFS (2023): Policies for Behavioral Health Care Medical Billers and Coders

2. COVID-19 has worsened the nation’s struggle with mental health and substance use disorders (collectively called ‘behavioral health conditions). For some Americans during the pandemic, this has meant feeling depressed and hopeless, making it challenging for them to perform everyday tasks. For older Americans and people with disabilities who may have already felt socially isolated, the pandemic has made it even harder to connect with family and friends. And for many people with substance use disorders, it has led to higher substance use, dangerous overdoses, and even death, including suicides.

3. To ensure that every American gets the behavioral health care they deserve, President Biden announced a strategy to address our national mental health crisis as part of the Administration’s Unity Agenda. Earlier this year, CMS issued its own Behavioral Health Strategy, seeking to adopt a data-informed approach that removes barriers to care and services and promotes person-centered behavioral health care, including emotional and mental wellbeing. In this article, we briefly discussed new behavioral health proposals from CMS’ recently proposed CY 2023 Physician Fee Schedule rule.

4. Mobilizing the Behavioral Health Workforce CMS is proposing to make changes to the Medicare program to ensure that behavioral health practitioners across the country can practice to the full extent of their license. CMS is proposing to create an exception to supervision requirements, allowing marriage and family therapists, licensed professional counselors, addiction counselors, certified peer recovery specialists, and others to provide behavioral health services while being under general supervision rather than “direct” supervision. Practically speaking, this means that these behavioral health practitioners would be able to provide services without a doctor or nurse practitioner physically on-site, expanding access to behavioral health services like counseling and cognitive behavioral therapy in additional communities, particularly rural or underserved communities where care can be hard to find.

5. Making Care More Effective CMS’s proposal to pay psychologists and social workers to help manage behavioral health needs as part of the primary care team is just one example of how they can encourage integrated care. Medicare has not historically recognized the team-based approach to pain management and treatment, including aspects such as person-centered care planning, medication management, and coordination between providers, that is often needed to manage chronic pain in ways that result in better outcomes. So, for the first time, Medicare is proposing new payments for team-based, comprehensive management and treatment of chronic pain.

6. Addressing the Nation’s Substance Use Disorder Crisis To help combat the increase in overdoses that have marked this pandemic, CMS clarifies that, in line with requirements of the Drug Enforcement Administration (DEA), Opioid Treatment Programs may bill Medicare for services performed by mobile units, such as vans, without obtaining a separate registration. This can improve treatment access for hard-to-reach populations, such as individuals who are homeless or who live in rural areas. CMS is also proposing to increase payment rates to Opioid Treatment Programs in order to better reflect the costs of the counseling services, while also proposing to pay for the initiation of buprenorphine (which treats opioid use disorder) over telehealth, rather than just in person, to further improve access.

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