Incentivize CCBHCs and FQHCs to encourage care integration
Recommendation
Congress should incentivize Certified Community Behavioral Health Clinics (CCBHCs) and Federally Qualified Health Centers (FQHCs) to strengthen mental health and substance use disorder (MH/SUD) and primary care integration through a voluntary integration bonus payment.[1] FQHCs and CCBHCs should be allowed to same-day bill to encourage integration.[2][3]
Background/summary
Formal, fully integrated partnerships between FQHCs and CCBHCs can empower both physical and MH/SUD providers to deliver a more comprehensive range of services and improve care delivery.[1][4] CCBHCs were first deployed by the Department of Health and Human Services (HHS) as a demonstration program in eight states to improve access to MH/SUD care at the community level, and have since been expanded to over 46 states and U.S. territories with over $120 million in funding made available.[5][6]
In 2016, HHS created a voluntary quality bonus payment for CCBHCs that meet certain state-determined performance requirements and federally required performance objectives.[8] However, these requirements do not reflect integration and do not apply to FQHCs, removing incentives for FQHCs to pursue integration.[1] Congress should encourage formal partnerships and increased integration between CCBHCs and FQHCs through a voluntary integration bonus program. Additionally, to further improve integration, FQHCs and CCBHCs should be allowed to bill for both physical and MH/SUD services on the same day, which is referred to as same-day billing.[7] Several explicit Medicaid policies prohibit billing for MH/SUD and physical health services on the same day.[7] Congress should amend rules to allow same-day billing for MH/SUD and physical health services to empower providers to increase care integration.
citations
1. Bipartisan Policy Center. Tackling America’s Mental Health and Addiction Crisis Through Primary Care Integration. Last Accessed March 2021.
2. U.S. Senate Committee on Finance. Bipartisan Mental Health Care Provisions. (Press Release). Last Accessed November 10, 2022.
3. CEO Alliance. A Unified Vision for Transforming Mental Health and Substance Use Care. Last Accessed August, 2022.
4. U.S. Department of Health and Human Services, Centers for Medicare and Medicaid Services. Behavioral Health Integration Services. Last Accessed March 2021.
5. U.S. Department of Health and Human Services. HHS selects eight states for new demonstration program to improve access to high quality behavioral health services. Last Accessed December 21, 2016.
6. U.S. Department of Health and Human Services. HHS Announces Over $120 Million In Funding Opportunity for Certified Community Behavioral Health Clinics Providing Mental Health and Substance Use Disorder Care Across the Country. Last Accessed March 23, 2023.
7. National Institutes of Health, National Library of Medicine, National Center for Biotechnology Information. Limits on same-day billing in Medicaid hinders integration of behavioral health into the medical home model. Last Accessed February 2016.
8. U.S. Department of Health and Human Services. Certified Community Behavioral Health Clinics Demonstration Program. Last Updated 2021.