Washington, DC – The Association for Behavioral Health and Wellness (ABHW) today responded to the U.S. Centers for Medicare and Medicaid Services’ (CMS’s) proposed policies for CY2027 under the Medicare Physician Fee Schedule (PFS). Access to comprehensive, evidence-based mental health (MH) and substance use disorder (SUD) services is critical to enhancing patients’ health and overall well-being.
In particular, the CY2027 PFS can help improve patient access through:
- Streamlined payments for SUD services
- Strengthening the Psychiatric Collaborative Care Model
- Improving chronic disease prevention through smoking and tobacco cessation services
“ABHW applauds CMS for focusing the PFS on what matters most: ensuring that Medicare beneficiaries can access high-quality, evidence-based behavioral health care,” said Debbie Witchey, President and CEO of ABHW. “These elements of the PFS, in particular, can help improve access to a wider range of services for a larger portion of the population.”
Bundled payments for SUD services. Ensuring robust access to SUD services in office-based settings helps integrate SUD care with patients’ primary and specialty care. Bundled payment models are already in use by a number of health plans; we encourage CMS to conduct a comprehensive survey of these models to evaluate how they can best support Medicare beneficiaries. Given the unique geographic and demographic health needs of different communities, ABHW encourages CMS to adopt a flexible approach to bundled payments for SUD services through the testing of multiple models that seek to incorporate core SUD services with additional mental health, case management, and chronic condition services.
Psychiatric Collaborative Care Model (COCM). ABHW agrees with CMS’s desire to improve behavioral health integration with primary care and welcome these refinements to valuation inputs. These refinements do not address all the barriers to COCM adoption, though. ABHW encourages CMS to address longstanding administrative barriers, particularly around billing for COCM, by creating a mechanism to allow behavioral health providers to bill directly for their services. This would lessen the paperwork burden of COCM and incentivize greater provider uptake, improving access upstream.
Smoking and tobacco cessation services. ABHW applauds CMS’s support for smoking and tobacco cessation and screening, brief intervention, and referral to treatment (SBIRT) services. These services are important tools in improving patient health and reducing the risk of serious conditions like lung cancer, heart disease, and diabetes. We encourage the agency to establish clear expectations around documentation and the necessary components for counseling services.
“As we observe Suicide Prevention Awareness Month in September, we are reminded that more than 1 in 5 Americans struggle with their mental health. With these and other innovative measures, CMS can expand its toolbox to improve access and outcomes in one of the most critical health needs facing this country,” Witchey says.
###
ABOUT THE ASSOCIATION FOR BEHAVIORAL HEALTH AND WELLNESS
ABHW is the leading health plan association working to improve access and quality of care for mental health and substance use disorders. ABHW’s members include national and regional health plans who care for approximately 200 million people. Together, we work to reduce stigma and advance federal policy on mental health and substance use disorder care. ABHW member companies include Aetna Behavioral Health, Elevance Health, Centene Corporation, Evernorth, a Cigna company, Health Care Service Corporation, Kaiser Permanente, Lucet, Magellan Health, Molina Healthcare, Optum, and PerformCare, a subsidiary of AmeriHealth Caritas. To learn more, visit www.abhw.org and follow us on BlueSky and LinkedIn.
