Question 1

What are the new billing rules for marriage and family therapists (MFTs) and mental health counselors (MHCs) under Medicare in 2024?

Accepted Answer

As of January 1, 2024, Medicare allows licensed MFTs and MHCs to enroll as providers and bill directly for covered outpatient mental health services. These clinicians can now use standard CPT codes for therapy, including crisis services, behavioral health integration (BHI), and health behavior assessments. Services are reimbursed at 75% of the Medicare Physician Fee Schedule rate. Telehealth is also covered, including audio-only sessions, and providers can practice in settings like private offices, RHCs, FQHCs, and SNFs. Proper licensure, supervised experience, and Medicare enrollment are required.

Question 2

What are the new rules and payments for partial hospital and intensive outpatient programs in the 2024 CMS behavioral health final rule?

Accepted Answer

As of January 1, 2024, Medicare expanded coverage for Partial Hospitalization Programs (PHPs) and Intensive Outpatient Programs (IOPs). PHPs must offer at least 20 hours of services per week, while IOPs must provide 9–19 hours, with individualized care plans and in-person treatment. CMS introduced new payment rates based on service days: one for 3-service days and a higher rate for 4+ service days. These services are now reimbursable in hospital outpatient departments, CMHCs, FQHCs, RHCs, and opioid treatment programs. Specific billing codes and documentation requirements apply based on setting and service type.

Question 3

What must behavioral health practices do to participate in CMS’s Innovation in Behavioral Health (IBH) Model for Medicaid?

Accepted Answer

To join the IBH Model (launching in early 2025), specialty behavioral health practices must:

Enroll Medicaid adults: Serve ≥25 adult Medicaid beneficiaries (≥18) monthly with moderate-to-severe mental health or SUD, through outpatient services.
• Be state-licensed & Medicaid‑enrolled: Meet all state licensing and Medicaid provider requirements.
• Deliver outpatient mental health/SUD care: Operate at the outpatient level, not PHP/IOP or inpatient.
• Join state’s Medicaid IBH effort: Participate only in states selected via CMS cooperative agreements and recruited by state Medicaid agencies.
• Implement care delivery framework: Hold interprofessional care teams, integrate behavioral, physical health & social needs (e.g., housing, food), conduct screenings, and develop health equity plans.
• Adopt health IT & data reporting: Use certified EHR systems, meet data-sharing standards, and submit performance and quality metrics.
• Engage in value-based payment model: Accept Medicaid payment models aligned to Medicare (e.g., per-member-per-month integration support payments including performance‑based bonuses)

Question 4

What are the requirements for compliance programs in private behavioral health practices for Medicare and Medicaid?

Accepted Answer

Private behavioral health practices must maintain a formal compliance program to meet Medicare and Medicaid requirements. Key elements include written policies and procedures, a designated compliance officer, regular staff training, internal audits, and a system for reporting and correcting errors. Practices must also ensure HIPAA compliance and maintain accurate, timely documentation of services. These measures help prevent fraud, support regulatory adherence, and safeguard patient data.