Three things to know about CMS’s approach to behavioral health in 2024
On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) unveiled its 2024 Physician Fee Schedule final rule. It includes changes to greatly increase access to behavioral healthcare for Medicare beneficiaries. Because many compliance rules in behavioral health will be changing in 2024, and simultaneously, a new set of behavioral health professionals will be entering the Medicare program for the first time, there’s never been a better time for a compliance review on behavioral health.
Three key insights from the Physician Fee Schedule
CMS’ key objectives are to improve access to behavioral health services, enhance the quality of care, promote integration of behavioral and physical health, and address disparities in behavioral health. While many compliance rules will be changing in behavioral health for 2024, the following are the three most important updates you should know from the 2024 behavioral health final rule:
Marriage and family therapists (MFTs) and mental health counselors (MHCs)
CMS now allows clinical social workers, MFTs, and MHCs to bill for Health Behavior Assessment and Intervention (HBAI) services using certain CPT codes, as well as any successor codes. This expansion includes clinical psychologists, who gained billing eligibility starting in 2023.
Continued payment for telehealth services
The 2024 behavioral health final rule highlights continued payment for telehealth services provided by rural health clinics (RHCs) and federally qualified health centers (FQHCs) In the final rule, CMS will also delay the requirement for an in-person visit with the physician or practitioner within six months of initiating mental health telehealth services.
New rules and payments for coverage of the partial hospital program and intensive outpatient program
Partial Hospitalization Program (PHP)
In the 2024 behavioral health final rule, CMS outlined an increase in the payment rate based on PHP days and non-PHP days to better account for costs and reimbursement. PHP is covered for substance use disorder treatment if it is covered in lieu of inpatient hospitalization. CMS is also expanding the existing rate structure to include two PHP Ambulatory Payment Classifications (APCs) for each provider type; one for days with three services per day and one for days with four or more services per day.
Intensive Outpatient Program (IOP)
Starting in 2024, CMS will attempt to fill in the coverage gap by reimbursing for IOP. Just like with PHP, there are two new APCs for community mental health clinics and hospitals. According to CMS, “RHCs will be paid the 3-services per day payment amount for hospital outpatient departments. For FQHCs, payment will be the lesser of a FQHC’s actual charges or the 3-services per day payment amount for hospital outpatient departments.”
The behavioral health final rule is just the beginning. As we continue on into 2024, you can expect a significant influx of more rules and regulations within the behavioral health sector. Should you require further clarification or have any inquiries, additional information can be found at www.cms.gov.
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