Several changes proposed in the 2023 CMS Physician Fee Schedule and Medicare Part B policies may help to advance integrated care. The proposed changes include a new General BHI service code for use when behavioral health is the focal point of care and allowing previously excluded behavioral health professionals to provide services to Medicare patients.

The new General BHI code is designed to allow reimbursement for direct services provided by psychologists and social workers in integrated primary care settings where behavioral health is the focal point of care. The changes would also allow the initiating visit to be for a behavioral health rather than physical health concern.

To expand access to behavioral health, CMS is proposing to make a change in the supervision requirements which would allow additional behavioral health professionals to provide “incident to” services. The exception would allow licensed professional counselors, marriage and family therapists, addiction counselors and certified peer counselors in integrated settings to provide services under “general supervision” rather than “direct supervision” of a physician or non-physician practitioner (NPP) including when the physician or NPP is offsite.

Additional provisions may impact and expand behavioral health services such as bundled monthly payments for comprehensive chronic pain care; expanding individual therapy session length for opioid treatment programs and allowing services from mobile units; and encouraging smaller and rural organizations to form Accountable Care Organizations to take advantage of Shared Savings Programs which provide additional funding to address patient social needs.

The proposed changes are open for public comment and you can read more about the proposed changes here: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched and here: https://www.cms.gov/blog/strengthening-behavioral-health-care-people-medicare.

CFHA celebrates these steps which would help to support and expand integrated, whole person care.