In Brief: Recently enacted legislation is poised to expand the behavioral health workforce by 225,000 providers.
Starting January 1, 2024, mental health counselors (MHCs) and marriage and family therapists (MFTs) will become eligible to receive reimbursement under Medicare Part B as well as Medicare Advantage (MA) plans for services provided to Medicare beneficiaries. The Mental Health Access and Improvement Act, signed into law on December 29, 2022, by President Biden, closes the gap that has prevented MHCs and MFTs from being recognized as Medicare providers. Prior to this change, the Centers for Medicare & Medicaid Services (CMS) limited the Medicare reimbursement of master’s-level behavioral health clinicians to licensed clinical social workers.
The implementation of Medicare eligibility for MHCs and MFTs will increase the behavioral health workforce by an estimated 225,000 providers nationally and expand much-needed access to behavioral health services for Medicare beneficiaries. This landmark legislation is the result of decades-long advocacy efforts to get CMS to recognize the advanced training and clinical expertise of MHCs and MFTs.
In addition, the CMS 2024 MA and Part D Final Rule imposes new minimum standards on MA payers to include psychologists and licensed clinical social workers in the evaluation of network adequacy. This is another tangible example of how CMS is prioritizing access to behavioral health services for Medicare beneficiaries.
What does this mean for behavioral health provider organizations?
- Medicare’s expanded eligibility may create an entirely new revenue source for some behavioral health provider organizations. Provider groups not contracted with an MA plan due to the previous limitations on Medicare-eligible license types should contact major MA plans in their service area to initiate contracting and understand requirements. (Note: Some MA payers may require enrollment with Medicare prior to participating with their plan.) MA contracting, even when there is an existing commercial agreement in place, can take three to six months due to the multistep process of application, rate negotiation, credentialing, and payer system loads.
- Provider groups with existing MA payer agreements should evaluate their contracted rates to ensure reimbursement is favorable for master’s-level clinicians, and initiate payer rate renegotiations as necessary.
- When negotiating rates, providers should approach payers with a partnership mindset while setting expectations for reimbursement at or above 100% of Medicare or alignment with current contracted commercial rates. In some markets, reimbursement at 100% of Medicare may actually be higher than rates offered by some commercial plans.
- CMS requires MA payers to maintain behavioral health provider network adequacy as a condition of operating and selling MA plans in eligible counties. Payers will increasingly be interested in provider organizations that serve more than just commercially insured populations, creating opportunities for enhanced collaboration between providers and payers in rural and under resourced areas.
Edited by: Matt Maslin
Published May 3, 2023