It has (finally) happened. This week’s groundbreaking 2024 Medicare Final Rule has officially been posted by the Centers for Medicare & Medicaid Services (CMS). Notably, it confirms several Telehealth.org predictions that Medicare is poised to be the single most significant payer for telehealth services this decade.
This article will detail the two most relevant aspects of this rule for behavioral professionals: addressing health-related social needs and expanding access to behavioral health services. Grasping the implications of this development is crucial for behavioral telehealth practitioners, as it will help them obtain ample reimbursement for delivering telehealth services. Implementing this long-anticipated rule is poised to transform the healthcare landscape, offering new opportunities and challenges for professionals in behavioral health.
Understanding the 2024 Medicare CMS Final Rule
The 2024 CME Final Rule signifies CMS’s commitment to patient-centered care, which includes but is not limited to telehealth. First and foremost, it introduces substantial coding and payment changes to better account for resources involved in delivering comprehensive care through multidisciplinary teams. This commitment aligns with the HHS Social Determinants of Health Action Plan and the Biden-Harris Cancer Moonshot initiative, aiming to provide covered patient navigation services to every American with cancer.
Expanding Coverage for Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs)
A significant aspect of this 2024 Medicare CMS rule is the inclusion of Marriage & Family Therapists (MFTs) and Mental Health Counselors (MHC) in Medicare Part B coverage and assuring payment under the Medicare Physician Fee Schedule. Additionally, addiction professionals meeting specific requirements can now enroll in Medicare, significantly enhancing access to critical behavioral health services.
For more specific information about how MFTs, MHCs, and addiction professionals will soon be reimbursed for Medicare services, see this week’s telehealth.org article titled, CMS Approves $$$ Medicare Reimbursement for Addiction Specialists, Counselors, & MFTs.
Behavioral Health Integration Codes
CMS is making corresponding changes to Behavioral Health Integration codes to ensure comprehensive coverage. This adjustment empowers MFTs and MHCs to bill for these essential services, promoting holistic patient care.
Behavioral Health Integration (BHI) Codes. These are specific codes used in healthcare billing and reimbursement. They are associated with services integrating behavioral health (mental and emotional well-being along with substance use) with primary healthcare.
Comprehensive Coverage. This phrase ensures that all aspects of a patient’s healthcare needs are addressed. Healthcare services should focus on physical, mental, and emotional well-being in this context.
CMS. The Centers for Medicare & Medicaid Services (CMS) is a US government agency responsible for administering healthcare programs, including Medicare and Medicaid.
Making Corresponding Changes. CMS is modifying or updating the BHI codes to align with healthcare policy and practice changes. These changes are intended to reflect the evolving healthcare landscape better.
Empowers MFTs and MHCs. MFTs and MHCs are behavioral health professionals who specialize in addressing mental and emotional health concerns. The adjustment allows these professionals to provide and bill for behavioral health integration services.
Billing for Essential Services. With these changes, MFTs and MHCs can submit claims for reimbursement when they provide essential behavioral health integration services as part of a patient’s overall healthcare. This means they can be compensated for the valuable care they deliver.
Promoting Holistic Patient Care. By enabling MFTs and MHCs to bill for these services, CMS encourages a holistic approach to patient care. This approach recognizes that mental and emotional well-being are integral to a person’s health. It ensures that patients receive comprehensive care that addresses their physical and behavioral health needs.
Psychotherapy for Crisis Services
Section 4123 of the CAA, 2023, introduces new HCPCS codes for psychotherapy for crisis services, complete with an enhanced payment structure. These services can be furnished in various service sites, expanding the reach of crisis mental health care.
Health Behavior Assessment and Intervention (HBAI) Services
Another key development is broadening access to HBAI services to include other behavioral professionals. CMS is allowing clinical social workers, MFTs, and MHCs to bill for these services in addition to psychologists. The aim is to help address the urgent need to address the psychological, behavioral, and social factors associated with physical health problems. Health Behavior Assessment and Intervention (HBAI) Services are a set of healthcare services designed to evaluate and address the psychological, behavioral, emotional, cognitive, and social factors contributing to an individual’s physical health problems. The primary goals of HBAI Services are as follows:
Assessment. HBAI services include a comprehensive assessment of an individual’s behavioral and psychological factors that may affect their physical health. This assessment helps healthcare providers better understand the patient’s overall well-being.
Intervention. Based on the assessment findings, healthcare professionals develop and implement intervention strategies to address the identified behavioral and psychological factors. These interventions may include counseling, therapy, education, and support to improve the patient’s physical health outcomes.
Integration. HBAI services aim to integrate behavioral and mental health care with primary healthcare services. These services promote a holistic approach to healthcare by addressing physical and behavioral health aspects.
Prevention. HBAI services also play a role in preventive care. They help individuals identify and modify unhealthy behaviors, manage stress, and develop coping strategies to prevent the onset or worsening of physical health conditions.
Patient-Centered Care. These services are typically tailored to the individual’s unique needs and circumstances. Healthcare providers work closely with patients to develop personalized plans for improving their health and well-being.
Examples of conditions that may benefit from HBAI services include chronic illnesses like diabetes, heart disease, obesity, and chronic pain. Patients dealing with stress, anxiety, depression, substance abuse, and other behavioral health issues that impact their physical health can also benefit from these services.
Valuation for Timed Behavioral Health Services
CMS recognizes the importance of accurately valuing time-based behavioral health services. They’re implementing a four-year transition plan to adjust the work RVUs for psychotherapy codes, ensuring fair compensation for these services by billing based on the time spent providing them.
Implementing a four-year transition plan. CMS is in the process of putting into action a detailed plan that spans four years. This plan likely includes various steps and adjustments to ensure a smooth and gradual transition.
To adjust the work RVUs for psychotherapy codes. Within this plan, one of the key actions is to modify the work Relative Value Units (RVUs) associated with psychotherapy codes. RVUs are a measure used to determine the relative value or worth of medical services in the Medicare fee schedule.
Ensuring fair compensation for these services. The ultimate goal of these adjustments is to guarantee that behavioral health professionals receive fair and equitable compensation for the time and effort they invest in providing psychotherapy services. In other words, CMS wants to ensure that providers are paid appropriately.
Expanding the Hospice Interdisciplinary Group
Section 4121(b) of the CAA, 2023, mandates the inclusion of social workers, MFTs, or MHCs in hospice interdisciplinary groups (IDGs). CMS is modifying the hospice Conditions of Participation (CoPs) to facilitate their participation.
MFTs and MHCs in Rural Health Clinics and Federally Qualified Health Centers
Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) offer their services in Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs). This expansion of eligible professionals is achieved by revising definitions and criteria. The aim is to enhance access to mental and emotional healthcare services in underserved and rural communities by increasing the pool of qualified providers who can work in these facilities.
Section 4121(b) of the CAA, 2023. This section mandates that hospice interdisciplinary groups (IDGs) must include social workers, Marriage and Family Therapists (MFTs), or Mental Health Counselors (MHCs). The goal is to address hospice patients and their families’ emotional and psychological needs by including these behavioral health professionals in the care planning.
CMS’s Modifications to the Hospice Conditions of Participation (CoPs). CMS is adjusting the hospice Conditions of Participation (CoPs) to comply with the mandate.
These modifications facilitate the involvement of social workers, MFTs, and MHCs in IDGs, promoting a more holistic approach to hospice care. They include updates to CoPs language, roles, and responsibilities to ensure these professionals can actively contribute to patient-centered care.
The Future of Digital Therapies
Amidst these transformative changes, CMS is looking to the future. They’re actively seeking input on digital therapies, including digital cognitive behavioral therapy, as potential additions to future rulemaking.
The 2024 CME Final Rule is a watershed moment in healthcare, addressing health-related social needs and expanding access to behavioral health services. These changes emphasize comprehensive, inclusive, and holistic healthcare, marking a significant leap forward in patient-centered care.
Stay tuned for more updates on the ever-evolving world of healthcare. If you found this article informative, please consider sharing it with others who may benefit. Keep abreast of telehealth news by subscribing to one or more of Telehealth.org’s 57 newsletters. Together, we can do our part to help shape the future of healthcare.
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