Practice Alert: Proposed CMS Reimbursement for LMFTs, LPCs, Addiction Counselors, Psychologists, Social Workers & Others

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HERE IS HOW

After decades of seeking inclusion as providers under Medicare, marriage and family therapists, licensed professional counselors, addiction counselors, and certified peer recovery specialists are being included to the full extent of their licensure in the Centers for Medicare and Medicaid Services (CMS) reimbursement proposal to change the CMS 2023 Physician Fee Schedule. If accepted, this landmark proposal represents a significant advancement in the decades-long battle to recognize these behavioral health professionals as essential professionals in US behavioral care. See Medicare Telehealth Reimbursement: Act Introduced to Allow Counselors to be Reimbursed by Medicare and the heated discussion inspired in this Telehealth.org Blog.

Focus on Behavioral Health

The proposed change to the Physician Fee Schedule is one of a series of efforts to expand the behavioral health workforce in response to the COVID-19-related mental health crisis. On March 1, 2022, State of the Union Address, President Biden announced a strategy to address our national mental health crisis as part of his Administration’s Bipartisan Unity Agenda. At about the same time earlier this year, CMS issued its Behavioral Health Strategy to adopt a data-informed approach that removes existing barriers to care and promotes person-centered behavioral health care. The strategy underscores the importance of strengthening quality, access, equity, and effective data integration to prevent and treat mental health and substance use disorders, along with acute and chronic pain. Medicare plays a critical role in implementing these new behavioral health proposals, with almost $1 trillion in claims and providing benefits to more than 63 million Americans.

CMS Reimbursement

CMS is proposing that licensed professional counselors (LPCs), marriage and family therapists (LMFTs), and other behavioral health practitioners provide health services under general (rather than direct) supervision. As it is now, Medicare reimbursement extends to MFTs, and LPCs who provide services under a physician or a nonphysician practitioner (NPP), if the physician or NPP is on-site and if the services occur as a result of the treatment of a physician or NPP. The newly proposed 2023 Physician Fee Schedule would introduce an “exception” to that supervision requirement, allowing MFTs, LPCs, and other behavioral practitioners to provide “incident to” services without a physician or NPP on-site.

Regarding clinical psychologists and licensed clinical social workers, CMS reimbursement proposes an enhanced role with integrated behavioral health services on a patient’s primary care team. The July 7, 2022 CMS announcement proposes creating a new General BHI service delivered by clinical psychologists (CPs) or clinical social workers (CSWs). The new service would be responsible for monthly care integration where the mental health services furnished by a CP or CSW serve to focus the care integration. The new CMS proposal includes a psychiatric diagnostic evaluation to serve as the initial visit for the new general BHI service. With these measures, CMS proposes to fund the integrated care model, whereby CPs and CSWs are paid to function within primary care teams. The CMS reimbursement plan is further detailed in a July 7, 2022 document titled, Strengthening Behavioral Health Care for People with Medicare.

The Medicare reimbursement  plan also proposes to pay for:

• Pain management and treatment — including person-centered care planning, medication management, and coordination between providers — is a team-based, comprehensive program for managing and treating chronic pain.
• Medicare Shared Savings Programs have succeeded in providing high-quality behavioral health care.
• An increase in payment rates to Opioid Treatment Programs reflects the added time often needed for treating opioid use disorder.
• Opioid Treatment Programs for services performed by mobile units, such as vans, without obtaining a separate registration
• The initiation of buprenorphine (which treats opioid use disorder) over telehealth, rather than only in-person to improve access.

Conclusion

If the proposed 2023 Physician Fee Schedule is passed, Medicare and Medicaid beneficiaries will have greater access to professionals with expertise in behavioral health care. As detailed in Telehealth.org’s Permanent Expansion of Medicare Telehealth Reimbursement Announced by CMS, reimbursement was recently approved for telephone and video-based telehealth when serving Medicare beneficiaries receiving behavioral care.

While CMS refers to soliciting comments at the end of the many documents cited above, links are missing for providers to make those comments in the current CMS announcements. If you see such links posted anywhere, please be an active member of our Telehealth.org community and take a moment to paste them below. Your thoughts and observations are also invited.

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