Recently, the United States Centers for Medicare and Medicaid Services (CMS) announced a new demonstration model, the Innovation in Behavioral Health (IBH) Model. The IBH model aims to improve outcomes for adults with mental health and substance use disorders (MH/SUD) by enhancing behavioral health provider capacity to integrate physical health care into their practice settings and services.
In the press release announcing the new model, CMS notes that the IBH model enables a “no wrong door” approach, which means that irrespective of the way patients enter the health care system, they have access to all available services. IBH simultaneously aims to reduce overall program expenditures.
Under the IBH Model, behavioral health practices will offer person-centered care by screening for and addressing behavioral health conditions and physical health conditions. Since patients with moderate to severe behavioral health conditions may already visit a behavioral health provider, CMS expects that the behavioral health practice will help to facilitate close collaboration with the patient’s primary care provider, other physical health providers, and health-related social need partners to support the whole-person health.
Similar to the Financial Alignment Initiative and the States Advancing All-Payer Health Equity Approaches and Development (AHEAD) Models, the IBH will involve collaboration between CMS and the Medicaid agency from individual states. Therefore, the first phase of the model will involve selection of states to participate. The Centers for Medicare and Medicaid Innovation (CMMI) plans to issue a Notice of Funding Opportunity in the Spring of 2024, with eligibility restricted to state Medicaid agencies. CMMI will then select up to eight state Medicaid agencies to participate and lead their state’s involvement in the Model, including state-specific provider selection processes.
Under the IBH Model, CMMI will provide infrastructure funding to providers that participate in in Medicare and the chosen states will provide similar funding for Medicaid-only provider practices. While the Model will involve Medicare and Medicaid funding and providers who participate in one or the other program, it will not be limited to patients who are dually eligible for Medicare and Medicaid.
During years 1-3 (the pre-implementation period), funding will be used to bolster the health information technology infrastructure capacity, telehealth tools to support delivery of integrated care, and practice transformation activities. During years 4-8 (the implementation period, expected to run from Q4 2027 to Q3 2032) IBH providers will receive a risk-adjusted Medicare per-member per-month Integration Support Payment (ISP) for screening, assessment, and coordination of MH/SUD and physical health conditions, as well as needs related to health-related social needs, such as housing and food insecurity. IBH providers will also be eligible for performance-based payments to help incentivize quality outcomes. While details about the funding for the Model have not yet been released, they are expected to be included in the Notice of Funding Opportunity or as part of the state selection process.
For providers that are currently participating in the Certified Community Behavioral Health Clinic (CCBHC) programs, Medicaid Health Homes programs, and other programs that support the integration of physical and behavioral health, they should be able to further enhance their integration strategies by participating in the IBH Model as well.
“Through this model, CMS will support behavioral health practices to provide integrated care and help meet people’s behavioral and physical health and health-related social needs, like housing, food and transportation, all of which can negatively impact a person’s ability to manage their care,” said CMS Administrator Chiquita Brooks-LaSure.
IBH Model May Be Like the HITECH Act, for Behavioral Health Providers
Behavioral health providers were not eligible to receive funds to support health information technology adoption under the Health Information Technology for Economic Clinical Health Act (HITECH Act) and have historically been behind physical medicine providers in the use of electronic health records and similar technologies. The IBH Model will hopefully allow for more behavioral health providers to expand their use of health information technology and telehealth technologies.
By improving health information technology, behavioral health providers may be better able to participate and thrive in public and private managed care programs. Telemedicine has also proven to be an important component of patient care, in part due to patient demand, expanding regulatory flexibility, and ongoing and worsening MH/SUD and safety net primary care provider shortages.