Prioritize Mental Health and Substance Use Integration in Advanced Primary Care

Across Administrations, CMS has pursued reforms designed to build up primary care as a key strategy for achieving better care at lower costs, especially in Medicare. For example, CMS developed new Advanced PrimaryCare Management (APCM) codes in Medicare to better compensate primary care providers for their work in coordinating longitudinal care management [1].Other efforts focus on providing more incentives for primary care in value-based payment arrangements [2]. To date, these efforts have not fully compensated primary care for the costs and effort to implement evidence-based models ofMH/SUD care integration. MH/SUD must be central to reforms promoting advanced primary care.

CMS should set quantitative goals for access and quality related to integrated MH/SUD care. CMS should publicly report progress toward these goals so that stakeholders can engage in identifying and addressing barriers. To promote progress, CMS should build on the APCM codes to recognize the importance of delivering evidence-based integrated MH/SUD care and compensate accordingly. CMS should also further incentivize primary care to take on relevant quality improvement activities on MH/SUD integration (such asCompletion of Collaborative Care Management Training Program or Implementation of Integrated Patient Centered Behavioral Health Model, among others). Across programs, CMS should pay for quality performance for both screening and outcomes focusing on MH/SUD (such as Preventive Care and Screening: Screening for Depression and Follow-Up Plan, Initiation and Engagement of Substance UseDisorder Treatment, and Screening for Social Drivers of Health, Improvement orMaintenance of Functioning for Individuals with a Mental and/or Substance UseDisorder or Depression Remission at Twelve Months, and Consumer Assessment ofHealthcare Providers and Systems). In value-based payment arrangements, CMS should waive the costs of MH/SUD integration from counting against shared savings, or otherwise include the expected spending in the shared saving benchmark calculations.