Last spring, a demonstration program was launched to begin implementation of the Excellence in Mental Health Act. So what is this law? How will it affect behavioral and mental health providers, and what strategies might be effective in putting this law to work for their advantage?
Let’s start with the basics. The Excellence in Mental Health Act (S. 264/H.R. 1263) is bi-partisan legislation that creates a new standard similar to Federally Qualified Health Centers (FQHC). Known as Certified Behavioral Health Centers (CBHCs), this new, volunteer pathway raises standards in terms of delivering services and meeting requirements with respect to reporting, standards of care, and oversight. The goal of the CBHC status is to create a foundation for a whole-person approach to health that recognizes community behavioral healthcare organizations’ experience and potential in treating complex patients with difficult healthcare needs.
The demonstration program is a 2-year, 8-state pilot project in which organizations that meet CBHC criteria will be eligible for an enhanced payment rate through Medicaid, under a Prospective Payment System developed by each participating state. The 8 states will be selected through a competitive application process with preference given to states that provide the most complete scope of services under Medicaid, and demonstrate the potential to expand services without increasing net federal spending. Selected states will be required to develop a prospective payment system for reimbursing CBHCs.
Full criteria to participate in the pilot program as a CBHC will be issued by the Department of Health and Human Services in September, 2015. Let’s take a look at some of the expected requirements.
Organization—Clinic must be a non-profit, part of a local government behavioral health authority or operating under the authorization from the Indian Health Service.
Staffing—Staff must have diverse disciplinary backgrounds, state-required licenses and accreditation, and be culturally and linguistically trained to serve the needs of the clinic’s population.
Availability and accessibility of services—Services, including crises management services, must have 24-hr- per-day availability. Payment structure must include a sliding fee scale, and services cannot be withheld or limited based on an individual’s ability to pay or place of residence.
Scope of Services—A CBHC must provide the following services, either directly or through a formal relationship with another provider:
- Crises mental health services, including 24-hr mobile crisis teams, emergency crisis intervention services and crisis stabilization
- Screening, assessment and diagnoses, including risk assessment
- Patient-centered treatment planning or similar process, including risk assessment and crisis planning
- Outpatient mental health and substance use services
- Outpatient clinic primary care screening and monitoring of key health indicators and health risk
- Targeted case management
- Psychiatric rehabilitation services
- Peer support, counselor services and family supports
- Intensive, community-based mental health care for members of the armed forces and veterans, particularly those members and veterans located in rural areas
Reporting—Reporting of encounter data, clinical outcomes, quality data, and any other data required by HHS.
Care Coordination—Care coordination to ensure seamless transitions for patients across the full spectrum of health services including acute, chronic and behavioral health needs. Care coordination requirements shall include partnerships of formal contracts with the following:
- Federally-qualified health centers (and rural health clinics as applicable) to provide FQHC services not provided directly through the CBHC
- Inpatient psychiatric facilities and substance use detoxification, post-detoxification step-down services, and residential programs
- Other community regional services, supports and providers
- Department of Veterans Affairs Medical Centers and other facilities
- Inpatient acute care hospitals and hospital outpatient clinics
Strategy for successful CBHC Certification
While the full certification requirements from HHS will be needed before we can map out a thorough strategy to meet the pilot program guidelines, one necessary component is obvious. There will be a clear need for effective care coordination in order to achieve and maintain CBHC status. When looking at coordination across all providers in the care continuum, interoperability will be key for any technology platform within the continuum.
EHR, Case Management and consumer applications will need to not only share data on an individual with each other, but with every other provider that delivers services to the individual. This makes delivery of data as a service through a Service Oriented Architecture (SOA) a very attractive option to remove the technical and administrative barriers between organizations.
Seamless data sharing through SOA will help a clinic aspiring to achieve CBHC status in three ways:
- It can help to directly meet the care coordination requirement outlined above.
- It can raise visibility into an individual’s care support structure to help meet reporting requirements.
- It can facilitate partner relationships to fill in service gaps, meeting the comprehensive care delivery requirement that CBHC status will demand.
While the Excellence in Mental Health Act is a long way from full implementation, it is taking promising steps to improve delivery of care in mental health. And the introduction of an FQHC standard to behavioral health providers will provide clinics with an opportunity to drive excellence within their own sphere of care.