CMS Releases New Behavioral Health Payment Model

Today’s post is by Rebecca Rye.

On January 18, CMS announced a new payment model focusing on behavioral health. The Innovation in Behavioral Health (IBH) model focuses on improving quality of care and outcomes for Medicare and Medicaid beneficiaries with moderate to severe mental health issues or substance use disorders.

While full model details have not been released, CLA is here to help answer your preliminary questions.

What is the IBH model?

The IBH model is a state-based model aligned with Medicare and Medicaid. CMS will issue awards to Medicaid agencies in up to 8 states to implement the model. The Medicaid agencies will in turn work in coordination with their state’s agencies for mental health and/or substance use disorders to ensure policies are aligned.

In addition, these state agencies will accept responsibility for the selection of community-based behavioral health practices (practice participants) that meet model criteria. Practice participants will be required to:

• Lead an interprofessional care team and accept responsibility for coordinating with other members of the care team to address a patient’s comprehensive needs
• Create a health equity plan using a needs assessment appropriate for the population they provide care for
• Complete annual screens to monitor patients for underlying and/or unmet health-related social needs (HRSN) and refer patients to other health care providers or safety-net services as appropriate

The IBH model also places particular emphasis on expansion of health IT capabilities. Targeted funding will be available to practice participants for investment in technology solutions, including electronic health records, that will improve quality reporting and data sharing.

What organizations are eligible to participate in the model?

Eligible participants are community-based behavioral health organizations and providers where beneficiaries can receive outpatient mental health and/or substance use disorder treatment, including Community Mental Health Centers, opioid treatment programs, and public or private practices. Safety net providers are eligible to participate in the model.

States will be required to apply via a notice of funding opportunity (NOFO). States in the model are responsible for selecting practice participants that meet model criteria:

• Are licensed by the state to deliver treatment for either mental health and/or substance use disorders
• Meet all state-specific Medicaid enrollment requirements
• Serve adult Medicaid beneficiaries with moderate to severe behavioral health conditions
• Provide care in an outpatient setting

Where will the model run?

CMS will release a NOFO this spring and select up to 8 states to participate.

How will the funding work?

While complete details are not yet available, there will be funding for state Medicaid agencies and practice participants.

State Medicaid agencies will receive funding through cooperative agreements. Funds will be used in preparation activities to implement the model, including improving statewide health IT infrastructure, supporting practice participants, convening key partners, and developing the Medicaid alternative payment model.

Practice participants will also receive aligned payments through Medicaid and, if participating, Medicare. Various payments for practice participants may include: 

• Infrastructure funding to support health IT investments, telehealth and practice transformation
• Integration Support Payment, a prospective, risk adjusted Medicare per-member-per-month payment for initial and ongoing screening, assessment, and coordination for behavioral and physical health conditions; and HRSN screening and referral
• Performance-based payments to incentivize quality outcomes

What does the model timeline look like?

The model will launch in Fall 2024 and run for eight years.

In model year 1, states will recruit practice participants and conduct outreach. Model years 1-3 are considered a ‘pre-implementation period’. During this time states and practice participants will receive funding to implement model activities. Practice participants will receive funding to support health IT and electronic health record upgrades, as well as increased staffing needed to support model activities. Practice participants may elect to participate in the additional Medicare payment model. Those who do may receive additional funding during the pre-implementation period.

In model year 4, states will implement a Medicaid model that supports practice participants implementing the care delivery framework. Practice participants who choose to participate in the additional Medicare model will receive a per-beneficiary-per-month payment to further supplement their model activities. Practice participants may also receive performance-based payments in model years 4-8.

How CLA can help

While complete model details are not yet available, it’s not too early to start a conversation about the possibilities that the IBH model may hold. Reach out today.