CMS Medicare Advantage Behavioral Health Policies

Everything to Know About Behavioral Health Policies in Medicare Advantage

Behavioral health is a vital component of comprehensive healthcare, especially for seniors and individuals with disabilities who depend on Medicare Advantage (MA) plans for their insurance coverage. The Centers for Medicare & Medicaid Services (CMS) highlight the importance of this by requiring behavioral health services as a fundamental part of network adequacy standards. For those working in the health insurance industry, it is essential to understand the details of behavioral health policies within Medicare Advantage to ensure compliance and to design plans that meet the needs of beneficiaries.

CMS Behavioral Health Strategy

Leading the charge, CMS has developed and implemented policies designed to cater to the unique needs of Medicare Advantage enrollees. This initiative is exemplified by the CMS Behavioral Health Strategy, which aims to ensure that high-quality behavioral health services and supports are accessible to CMS beneficiaries and consumers. Central to this effort is the ongoing expansion of behavioral health services that Medicare Advantage (MA) organizations must offer.

Expansion of Behavioral Health Services in Medicare Advantage

In the last two years, CMS has broadened the spectrum of behavioral health services covered under Medicare Advantage to include:

  1. Clinical Psychology
  2. Licensed Clinical Social Work
  3. Outpatient Behavioral Health

These specialties have been integrated alongside the existing services: Psychiatry and Inpatient Psychiatric Facility care.

Behavioral Health Network Adequacy Requirements

To ensure these services are effectively delivered, CMS evaluates the behavioral health specialties according to the Medicare Advantage Network Adequacy standards.

Provider Specialty Network Adequacy Requirements

CMS has established specific standards for behavioral health Provider Specialty types, which include Psychiatry, Clinical Psychology, and Licensed Clinical Social Work. These standards include:

Facility Specialty Network Adequacy Requirements

Facility specialties, include Inpatient Psychiatric Facility Services and Outpatient Behavioral Health, are subject to network adequacy evaluations. The criteria for these evaluations consist of:

Behavioral Health Network Adequacy Special Circumstances

Eligibility for 10% Credit Point: Psychiatry, Clinical Psychology, Clinical Social Work, and Outpatient Behavioral Health services qualify for a 10% credit point towards the percentage of beneficiaries residing within the published network adequacy time and distance standards. This credit applies if an MA organization’s contracted network involves telehealth providers who offer additional telehealth benefits beyond those required by statute for covered services.

Exception Requests: In scenarios where it’s challenging to meet the network adequacy criteria due to a lack of providers or facilities, MA organizations may submit a network adequacy exception request.

Initial Application and Expansion Allowances: During the application phase of an Initial Application or a Service Area Expansion, MA organizations may use allowances to assist in meeting network adequacy standards.

Compliance Requirement Reminder: Applicants must fully comply with network adequacy standards by January 1 of the contract year.

HSD Table Submissions

Guidelines for Behavioral Health Specialties

MA organizations are subject to network adequacy evaluations at crucial junctures, including during an initial application, service area expansion application, and a triennial network adequacy review. A pivotal component of this evaluation is the submission of network data via Health Service Delivery (HSD) tables, which must include all five behavioral health specialties.

MA organizations must submit two HSD tables for each contract:

  1. A Provider HSD Table
  2. A Facility HSD Table

Restrictions on Provider Listings

MA organizations are restricted from using a single provider to fulfill multiple provider network requirements. For example, a provider cannot be listed with the specialty of psychiatry, clinical social work, or clinical psychology, and also as an Outpatient Behavioral Health facility.

Medicare Advantage Provider Data Accuracy Requirements

Outpatient Behavioral Health Requirements

In response to growing concerns about ghost networks and anticipated legislation such as The Requiring Enhanced & Accurate Lists of Health Providers Act, CMS implemented more stringent requirements to verify the reliability of provider data, particularly for Outpatient Behavioral Health. The new rules mandate that providers must have rendered services to a designated number of patients within the past year, with proof of service available upon request.

Annual Verification Responsibilities

Provider Data Verification and Directory Updates

Beyond the mandated behavioral health requirements, MA organizations are required to provide transparent and accurate portrayals of their provider networks. Integral to this is the upkeep of up-to-date online and printed directories. These resources must be made available to members by October 15th of each year, within 10 days following a new member’s enrollment, and at any time upon request during the calendar year. Additionally, an MA organization’s website must offer a user-friendly search function for all provider data elements to ensure ease of access for members.

To maintain compliance with federal mandates, MA organizations must outreach and receive provider verification quarterly to confirm the accuracy of the information listed in their provider directories. These routine checks are crucial for the validity and reliability of the data provided to enrollees.

Mandatory Provider data elements to verify:

Updating Directory Information

It is incumbent upon MA organizations to promptly update their directories when they are notified of changes to any provider’s details. The updates must be performed within 30 days of receiving new or corrected information.