1) What type of external guidance did CMS solicit when developing this model?
The CMS Innovation Center sought input for the model from a range of behavioral health experts, including advocacy groups, provider and beneficiary groups, state Medicaid agencies, and other interested parties from across the country, as well as the Substance Abuse and Mental Health Services Administration (SAMHSA), the Center for Medicaid and CHIP Services (CMCS), the Indian Health Service (HIS), and the Office of the National Coordinator for Health Information Technology (ONC). Topics discussed during these conversations include payment innovation, funding use, health IT, workforce, and care integration. CMS plans to continue to consult with states, providers, beneficiaries, and other experts and interested groups during the life of the model to support effective implementation and proactively address any emerging hurdles. We appreciate their guidance on a successful model design.
2) Can states currently participating in the Certified Community Behavioral Health Clinic Medicaid Demonstration (CCBHC) participate in the IBH Model?
Yes. States currently participating in the Certified Community Behavioral Health Clinic (CCBHC) Prospective Payment System (PPS) Demonstration, or CCBHC Planning Grants, programs administered by CMS and the Substance Abuse and Mental Health Services Administration (SAMHSA), can apply to participate in the Innovation in Behavioral Health Model (IBH Model). CCBHCs can bolster their existing efforts to integrate behavioral and physical health care while also receiving needed reimbursement for serving Medicare beneficiaries, including those dually eligible for Medicaid and Medicare.
3) What support will the model provide for practice participants to build health IT capacity?
The IBH Model will assist behavioral health practices in improving interoperability, encouraging providers to securely and efficiently transmit and exchange patient health information at the point of care. Additionally, all practice participants are required to adopt and use health IT standards under the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program over the course of the model period. The IBH model team is working with ONC to develop requirements and guidelines for practice participants.
4) Will this model qualify as an Advanced or Merit-based Incentive Payment System (MIPS) Alternative Payment Model (APM)?
We do not anticipate that the IBH Model will qualify as an Advanced APM; however, we will explore whether the model would qualify as an MIPS APM for MIPS eligible clinicians.
5) When will more details on state participation be released?
Further details on how states can participate are expected to be released in early 2024 when the Notice of Funding Opportunity (NOFO) is released.