Beginning January 1, 2023, Medicare will increase and improve protection of sure companies and suppliers to advance entry to prevention and remedy companies for substance use problems (SUD) and psychological well being companies. These adjustments, carried out within the 2023 Doctor charge schedule closing rule (Last Rule) revealed final week, additional the objectives of the Facilities of Medicare and Medicaid Providers (CMS) in its 2022 Behavioral Well being Technique, as follows:
- Launched flexibility in supervision necessities to permit behavioral well being clinicians of varied varieties to invoice extra readily for his or her companies;
- Beneath the Psychiatric Collaborative Care Mannequin, a scientific psychologist or scientific social employee can function the point of interest of care integration slightly than a doctor as beforehand required;
- Modified methodology for methadone remedy reimbursement; and
- New billing code to permit for longer periods of psychotherapy given the elevated want for behavioral well being companies in reference to SUD remedy.
The mixture of the opioid disaster and the COVID-19 pandemic have led to document want for behavioral well being remedy. As beforehand mentioned, Medicare doesn’t cowl a full vary of companies, suppliers, and settings for behavioral well being remedy. In an try to fulfill its objectives of enhancing entry and high quality of psychological well being companies, the Last Rule contains quite a lot of adjustments that modernize and increase Medicare protection.
Behavioral Well being Treating Supplier Flexibilities
CMS up to date laws to offer extra flexibility concerning the kinds of practitioners which will present behavioral well being care companies, which can handle vital behavioral well being staffing shortages, notably in rural areas. CMS acknowledged that there aren’t any direct billing codes to reimburse many kinds of behavioral well being specialists reminiscent of Licensed Skilled Counselors (LPCs) and Marriage and Household Therapists (MFTs). CMS famous it didn’t have the authority to create new statutory classes for reimbursable practitioner varieties. As a substitute, they amended the direct supervision requirement for these kind of suppliers such that their companies will be billed “incident to” a doctor’s companies, however with out the necessity for steady, bodily supervision of a doctor. Moreover, CMS established a brand new code to encourage the mixing of psychological well being companies. Beneath the Psychiatric Collaborative Care Mannequin, a scientific psychologist or scientific social employee can function the point of interest of care integration slightly than a doctor, as beforehand required.
Reimbursement Enhancements for Methadone and Opioid Remedy Packages
Within the Last Rule, CMS additionally updates numerous billing codes associated to behavioral well being and SUD remedy. First, CMS up to date the methodology to find out the reimbursement charge for methadone (a steadily prescribed drug for critical opioid use dependence). CMS was reluctant to depend on the voluntary reporting of common gross sales value information for methadone as a result of it might end in a decrease reimbursement for the upcoming 12 months. Involved that this is able to restrict availability of methadone at a time when opioid drug overdoses proceed to soar, CMS adopted the cost charge from 2021, with an annual replace for inflation. CMS additionally up to date the speed for particular person remedy offered in an Opioid Remedy Program (OTP), generally known as a methadone clinic, to permit for longer periods at 45 minutes. Commentary to the Last Rule acknowledges that sufferers recognized with Opioid Use Dysfunction and receiving companies in an OTP usually require and profit from a psychotherapy session longer than the common affected person (which has traditionally been lined for a 30 minute psychotherapy session). CMS famous that research have discovered that the common size of a remedy session in the course of the preliminary months of remedy in an OTP is 50 minutes. Accordingly, the change to reimbursement for 45 minute remedy periods in an OTP is especially vital as a result of it permits Medicare to reimburse suppliers for an period of time that higher approximates precise time spent.
Second, whereas CMS solicited feedback on whether or not there’s a hole in coding for intensive outpatient (IOP) companies, the Last Rule didn’t embody any adjustments on this space. Although CMS acknowledged the receipt of a number of feedback advocating for the advantages of IOP, notably for SUD remedy, CMS mentioned it might contemplate these feedback in future rulemaking.
On steadiness, it’s anticipated that these adjustments carried out by the Last Rule will improve entry and high quality of behavioral well being and SUD sources for Medicare beneficiaries throughout the nation and are welcome steps in the direction of assuaging the shortage of entry to remedy that has been exacerbated by the COVID-19 pandemic and opioid epidemic. Suppliers and buyers in nationwide behavioral well being platforms ought to welcome the extra clinician flexibility and reimbursement enhancements evidenced by the Last Rule.
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