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Rebecca Farley

Director, Policy & Advocacy, National Council for Behavioral Health

Medicare to Survey CMHCs for Compliance with Conditions of Participation

September 23, 2014 | Medicare | Comments
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Mental health organizations registered with Medicare as Community Mental Health Centers (CMHCs) should have received a letter from the Centers for Medicare and Medicaid Services confirming their operational status as a CMHC. This is the first step in initiating a survey process to confirm compliance with Medicare’s Conditions of Participation for CMHCs.

Issued in late 2012, the Conditions of Participation (CoP) for Community Mental Health Centers outline operational, clinical, and staffing requirements for organizations that participate with Medicare under the place of service code 53, a designation used for organizations providing partial hospitalization services to Medicare beneficiaries. The CoPs established a survey process by which Medicare will determine whether participating organizations have met these requirements.

In preparation for its upcoming survey, Medicare is now working with states to update its list of active Community Mental Health Centers. About 517 organizations that are currently listed as “active” CMHCs will receive a letter asking them to:

  1. Confirm they are an active CMHC, plan to maintain their CMHC status, and will therefore be surveyed for compliance with the terms of the new CoPs; OR
  2. Voluntarily terminate their CMHC status because they do not or cannot meet the requirements of the CoPs; OR
  3. Identify if the organization is no longer operational or is no longer providing CMHC services.

This process provides an opportunity for Medicare-participating community mental health organizations to evaluate their readiness to meet the CoP criteria or assess whether they should be billing Medicare under a different place of service code. Many mental health providers participate with Medicare under the place of service code 11, for outpatient clinics. The National Council encourages organizations that no longer provide or wish to provide partial hospitalization services to change their place of service code from 53 to 11.

Organizations that confirm their CMHC status with Medicare will be subject to the survey process to verify they are in compliance with the CoPs. Medicare will provide further instructions about the survey process at a future date.

Not sure whether your organization is considered a CMHC under Medicare? Check out our FAQs to determine whether the Conditions of Participation apply to you.