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Chuck Ingoglia

President & CEO, National Council for Mental Wellbeing

Medicaid Managed Care Regulation Authorizes States to Reimburse Behavioral Health IT

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Last month, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule on Medicaid and Children’s Health Insurance Program managed care. Buried within that rule, was language that would allow states to reimburse behavioral health providers, among others, for the adoption and use of interoperable health information technology through Medicaid. This would be an incredibly important opportunity for provider groups that were left out of the electronic health record (EHR) incentive program back in 2009.

The 650-page proposed rule was the first major update to applicable regulations since 2003, and touched on a number of key issues (see a full breakdown here.) The use of EHR incentives for previously excluded providers was mentioned specifically as an avenue for states to incentivize delivery system reform to deliver higher quality care in a cost-effective manner. CMS reiterated the flexibility states have in requiring managed care plans to participate in important delivery system reform or performance improvement initiatives, including “broad-based provider health information exchange projects.”

A few things to make clear:

  1. This is only a proposed rule – nothing is final yet. The proposed rule is currently open for public comment for another six weeks. CMS is expected to issue a final rule sometime later this summer or early fall. Until the final rule, it is difficult to speculate whether or not such an opportunity would be available to states in the future.
  2. This is not an expansion of the EHR Incentive Meaningful Use program. CMS made mention of EHR financial incentives as an example of action states could take to incentivize broader goals of the proposed rule. This is by no means an outright expansion of the Meaningful Use program. The National Council continues our advocacy on Capitol Hill to build support for including behavioral health providers in Meaningful Use incentives.
  3. States would still have to decide to fund it. The inclusion of this language is an important step forward for behavioral health advocates who have been looking for a way to incentivize EHR adoption since 2009. However, should this language remain in the final rule, it would still require action and funding from states to see this opportunity come to fruition.

Comments on the proposed rule are due by July 27, 2015. The National Council welcomes your thoughts and suggestions as we begin preparing our comments. We will be sure to share our comments with our members before submission.