Introduction
Access to behavioral health care services has long been a challenge in the United States, with many individuals struggling to find timely and appropriate care. Recognizing the importance of addressing access to care, the Centers for Medicare & Medicaid Services (CMS) has taken significant steps to enhance access to behavioral healthcare services for Medicare Advantage plan enrollees. This article addresses many questions about CMS’s recent developments and proposals to improve access to Medicare behavioral health, including reimbursement for addiction or drug and alcohol counselors, mental health counselors (MHCs), and marriage and family therapists (MFTs). It also details the use of the Outpatient Behavioral Health category for billing.
The Consolidated Appropriations Act, 2023
The Consolidated Appropriations Act of 2023 marked a significant milestone in expanding access to behavioral health care services for Medicare beneficiaries. This legislation established a new statutory Medicare behavioral health benefit category for services furnished by MFTs and MHCs. Under this provision, an estimated 400,000 MFTs and MHCs will become eligible to enroll in Medicare, allowing them to provide vital behavioral health services to Medicare beneficiaries beginning January 1, 2024.
Expanding the Medicare Behavioral Health Provider List
In a separate rulemaking process within the Calendar Year 2024 Physician Fee Schedule final rule, CMS finalized that addiction or drug and alcohol counselors who meet the statutory requirements of MHCs will also be able to enroll in Medicare. This decision expands the pool of providers offering behavioral health services to Medicare beneficiaries to increase health equity. Enrolled MFTs, MHCs, and addiction counselors will be able to bill for behavioral health services beginning on January 1, 2024, the date previously mentioned.
Enhancing Network Adequacy Standards for Outpatient Behavioral Health
CMS proposes a comprehensive approach to ensure that individuals with Medicare Advantage plans can access various behavioral health providers, including newly enrolled professionals. CMS intends to categorize these providers under an Outpatient Behavioral Health umbrella as a facility specialty. This categorization will serve as a foundation for setting Medicare Advantage plan network adequacy standards.
Providers in the Outpatient Behavioral Health category will encompass MFTs, MHCs, Opioid Treatment Program providers, Community Mental Health Centers, addiction medicine physicians, and other professionals offering addiction medicine and behavioral health counseling or therapy services within the Medicare framework.
Telehealth Expansion
In response to the growing importance of telehealth in healthcare delivery, CMS is also taking steps to facilitate telehealth services in behavioral health. CMS proposes adding the Outpatient Behavioral Health facility specialty to the list of specialty types eligible for a 10% credit. This credit will be granted to Medicare Advantage plan organizations that include one or more telehealth providers of this specialty, offering additional telehealth benefits for covered services.
Conclusion
Improving access to Medicare behavioral health care providers is a crucial step toward addressing the mental health needs of Medicare Advantage plan enrollees. The actions taken by CMS, including establishing a new Medicare benefit category, enrollment opportunities for addiction counselors, and introducing network adequacy standards, demonstrate a commitment to enhancing behavioral healthcare access.
Moreover, integrating telehealth services into the behavioral health landscape highlights the agency’s recognition
