CMS unveils new behavioral health model using a 'no wrong door' approach

The Centers for Medicare & Medicaid Services announced Thursday the Innovation in Behavioral Health Model, a new approach that is designed to test for improving outcomes for adults with mental health and substance use disorder.

Beginning this fall, the model is intended to funnel adults in Medicare and Medicaid to the "physical, behavioral and social supports" they need, according to a press release. Community-based practices under IBH will create care teams with behavioral and physical health providers. The proposal embraces a no wrong door approach that allows people to obtain all services they need no matter how they first seek out care. Screenings, assessments and referrals to other services will be available.

While the practice participant enrollment period begins this year, the implementation period takes place from 2027 to 2032, a fact sheet (PDF) released by CMS says. States have not yet been selected to participate.

What differentiates this model from others is the approach, CMS officials told media publications during a press briefing. Typically, behavioral health is shoehorned into primary care settings. Since this is a community-based effort, the model calls for "weaving" physical health needs into behavioral health organizations," explained Liz Fowler, CMS Deputy Administrator, during a briefing with reporters.

"It's almost like a reverse integration," she said.

HHS Deputy Secretary Andrea Palm also highlighted previous agency efforts through workforce recruitment of primary care clinicians, reducing the technology gap between providers and integrating primary care with behavioral health. Officials emphasized how the new model is state-based and led by Medicaid agencies

“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 in a press release.

CMS anticipates the model will reduce overall program expenditures and improve health IT capacity building through infrastructure payments.

One quarter of people with Medicare experience mental illness and 40% of people with Medicaid experience mental illness or substance use disorder, according to KFF. CMS officials say fragmented care and high out-of-pocket costs negatively impact enrollees, particularly those in rural settings, low-income populations or part of marginalized groups.

IBH will be tested by the Center for Medicare and Medicaid Innovation, and it is expected to take place in up to eight states for eight years. States currently participating in CMS-administered programs can participate in IBH.

A Notice of Funding Opportunity will be released this spring. CMS said it is looking into whether IBH will qualify as a Merit-based Incentive Payment System Alternative Payment Model.

Participants must be community-based organizations or safety net providers that are licensed by a state to deliver behavioral health services, meet Medicaid provider enrollment requirements and are eligible for Medicaid reimbursement, and provide mental health or substance use disorder services in outpatient care for Medicaid beneficiaries.

CMS Deputy Administrator Meena Seshamani, M.D., also highlighted on the call a proposal requiring Medicare Advantage plans to include an "adequate" number of behavioral health practitioners in-network as a way to improve behavioral health outcomes in the country.