On January 18, 2024, the Centers for Medicare & Medicaid Services (CMS) announced a new Innovation in Behavioral Health (IBH) payment model centered on community behavioral health providers. The model structure, summarized in figure 1, intends to achieve:
- Multipayer alignment.
- Integration of behavioral health, physical health, and health-related social needs (HRSNs).
- Improvements in health equity.
CMS anticipates that this person-centered approach will improve care for the estimated 25% of Medicare beneficiaries experiencing mental illness and the 40% of adult Medicaid beneficiaries experiencing mental illness or substance use disorder (SUD). [1]
Figure 1: IBH Model Overview
Model Significance
While further financial and methodological details are needed to fully evaluate the IBH model, the components shared to date promise notable movement toward recognizing the vital role of behavioral health providers and streamlining value-based participation for providers. Specifically, the team at ECG is excited to see the following characteristics implemented in this model:
1. Behavioral Health–Centric: The IBH model is one of the first CMS models to place behavioral health providers at the center of care coordination and management, recognizing the primary support role these providers play for beneficiaries with moderate to severe behavioral health needs. This will create opportunities for behavioral health providers to develop a comprehensive care approach, receive funding for support activities, and have a greater impact on the related physical and community aspects of patient health.
2. Focus on Equity through Integration of HRSNs: The PMPM payments within the IBH model are intended to reimburse for not only behavioral and physical health care, but also the integration of HRSN evaluations and referrals. This is a fairly new concept compared to traditional value-based models and signals CMS’s continued dedication to improving health equity. It also represents progress toward reimbursing for the non-health-related support services that many providers have been delivering without compensation.
3. Meaningful Payer Alignment: CMS’s inclusion of multipayer alignment goes a step further than many historical models by requiring, not recommending, alignment between Medicare and Medicaid. This aligns with CMS’s stated goals of streamlining value-based care models, but also provides an opportunity to improve care for the dual-eligible population, who often suffer from poor health outcomes and a lack of coordination. Achieving payer alignment will also alleviate administrative burden on participating providers by creating a unified methodology and standardized quality measures.
4. Longitudinal Results: The IBH model offers providers the ability to focus on long-term outcomes, with the model running a full eight years, through Q3 2032. While models have historically focused on shorter time periods (with the possibility of being extended), the guarantee of a longer demonstration will allow practice participants to more meaningfully invest in patient care while ensuring they are able to realize the results of care interventions. This also shows that CMS understands the time required to bend the cost curve and impact patient outcomes.
Key Considerations
The Notice of Funding Opportunity for SMAs is expected in spring 2024, with practice enrollment set to begin in Q4 2024. As behavioral health providers in awarded states evaluate participation, ECG recommends starting with four key considerations, as outlined in figure 2. These components will help behavioral health providers evaluate whether they are ready to assume risk and identify any potential gaps in their readiness for value-based care.
Figure 2: Key Participation Considerations
About ECG
ECG has dedicated teams focused on behavioral health contracting and managed care strategy, in addition to value-based care readiness and opportunity evaluation. Contact us to learn more about how we can help your behavioral health organization understand value-based agreements, evaluate potential opportunities, develop a strategy, and prepare for participation.
Learn More About our Behavioral Health Services.
Edited by: Matt Maslin
1 Source: CMS press release, found here.
Published February 12, 2024
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