Q: Is the “front door” the only way that people can enter the behavioral health system?
A: No. The “front door” is designed to serve as a streamlined and accessible way to connect people to the appropriate clinical assessment and treatment when they may not otherwise know where to turn.
Q: What kind of assistance will the “front door” provide?
A: An individual or their loved one can call or “chat” through a centralized, single phone number/website. A staff person will answer the call/chat and will gather information to help determine what help is indicated; a brief clinical assessment may be conducted when appropriate. The front door staff then will help the caller navigate and connect to the appropriate next steps, which may include referral to a Community Behavioral Health Center (CBHC) or other outpatient provider, referral to mobile crisis intervention, or connection to other behavioral health services.
Q: How will the proposed “front door” interface with existing call lines such as 211, 911, and the Bureau of Substance Addiction Services (BSAS) Substance Use Disorder (SUD) helpline?
A: Once implemented, the “front door” will be a statewide resource, available by phone and online/mobile “chat,” for triage and connection to appropriate behavioral health services. EOHHS intends to ensure seamless connection between the “front door” and other resources such as the BSAS SUD helpline, Mass 211 line, and the National Suicide Prevention Lifeline.
Q: Will individuals experiencing early signs of mental illness be eligible to access the “front door”?
A: The “front door” will be an entry point to treatment for all individuals, regardless of their diagnosis or prior experience or history with behavioral health treatment. The front door will help individuals or their loved ones figure out where and how to find help when they need it.
Q: Are individuals required to be approved for DMH services to use the “front door”?
A: No. The “front door” is intended to function as an entry point to treatment for all individuals, regardless of their diagnosis, prior experience or history with behavioral health treatment or insurance coverage.
Community Behavioral Health Centers
Q: What are the key service components of the Community Behavioral Health Centers (CBHCs)?
A: The CBHCs will be a new provider designation that will serve as an entry point for timely, flexible, person-centered, high-quality mental health and addiction treatment on an urgent and ongoing basis. Key service components of CBHCs will focus on quality and outcomes, including offering trauma-informed care and evidence-based practices. These services include:
- Integrated mental health and addiction treatment
- Extended hours, including evenings and weekends
- Same-day access to intake and brief assessment, urgent and crisis treatment including medications, and drop-in treatment and support(e.g., group sessions, peer supports)
- 24/7 mobile and community crisis response with Community Crisis Stabilization for youth and adults
- Telehealth and flexible service delivery locations (e.g., home, school, etc.)
- Peer supports
- Care coordination
- Ability to serve all ages, including child and family-specific treatment models and models for older adults
- Ability to meet a variety of language needs and serve individuals from diverse cultural backgrounds
- Evidence-based and evidence-informed treatments to meet individual needs, including interventions and close coordination for individuals with BH needs who are involved with other systems, including the justice system or children in the care and custody of the Commonwealth.
Q: How will CBHCs be paid under the MassHealth program?
A: MassHealth will provide payment through a flexible, bundled encounter-based payment model for outpatient and urgent evaluation and treatment. A Request for Information (RFI) was released in Summer 2021 to collect feedback and inform the rate development and service components included in the encounter bundle, and to gather input on the rate structure for 24-7 community and mobile crisis services. There will also be a pay-for-performance component of CBHC payment.
Q: How will MassHealth monitor quality of service delivered by CBHCs and will there be a value-based payment component to the CBHC payment structure?
A: MassHealth will include a pay-for-performance element of the CBHC payment structure, based on well-established quality and outcomes measures. The first year of this program will be pay for reporting in order to establish baselines and implement new data collection and reporting processes. CBHCs will also be required to report several additional performance measures, including timeliness of initial evaluations, urgent, crisis, and routine visits, as well as member experience.
EOHHS will provide additional details and seek feedback on the proposed quality strategy in upcoming information sessions on the CBHC program.
Q: Will MassHealth’s managed care entities contract with the CBHCs?
A: Yes. CBHCs will be contracted to serve MassHealth members across all managed care and fee-for-service (FFS) programs.
Q: Will commercial insurers contract with CBHCs?
A: Commercial insurers are strongly encouraged to contract with CBHCs and to adopt the CBHC care delivery and reimbursement model to ensure that all Massachusetts residents have access to CBHCs regardless of insurance coverage. EOHHS is engaging directly with commercial health insurance carriers, as well as with the Division of Insurance (DOI), Group Insurance Commission (GIC) and the Massachusetts Health Connector to encourage commercial adoption of key elements of the Roadmap, including contracting with the new network of CBHCs.
Q: Will CBHCs be located in all regions of the Commonwealth?
A: Yes. EOHHS intends to procure a network of CBHCs that will cover all areas of the Commonwealth. Regions will not be defined by county designation.
Q: How will the CBHCs relate to the restructured crisis system?
A: CBHCs will be procured in conjunction with the re-procurement of the Emergency Services Program/ Mobile Crisis Intervention (ESP/MCI) system. New Youth Community Crisis Stabilization (CCS) services will also become available, alongside the existing Adult CCS service, as part of the enhanced ESP/MCI system. In addition to outpatient and urgent treatment, all CBHCs will provide 24/7 community and mobile crisis services, including ESP/MCI and CCS, for a defined geographic area. The geographic regions assigned to CBHCs may be similar to current ESP/MCI regions or may be modified.
Q: What is the process and timeline for the CBHC procurement?
A: Under its contract with MassHealth, the Massachusetts Behavioral Health Partnership (MBHP) will support the procurement of a network of designated CBHCs. EOHHS anticipates that CBHCs will apply 2021 and will be selected and fully implemented in 2022.
Q: Will the state offer financial support for providers to implement the CBHC model?
A: EOHHS will provide up to $10M in start-up grants for entities that are selected to become CBHCs to prepare for implementation. Applicants may apply for this funding at the time of application to become a CBHC. More details on this will be provided with the release of the CBHC procurement. In addition, CBHC rates will be designed to support high-quality, outcomes-oriented, and individualized care delivery.
Q: What is the difference between CBHCs and the national Certified Community Behavioral Health Clinic (CCBHC) model?
A: CBHC service delivery expectations are similar with CCBHC service delivery expectations. Both models focus on delivering a continuum of outpatient, urgent, and crisis mental health and SUD services on an open-access basis and in a person-centered, evidence-based manner. Key differences include that CBHCs will be required to deliver specialized services for children and youth, which is not required in the national CCBHC program. In addition, the CBHC requirements and encounter rate will not include supported employment, targeted case management, intensive outpatient, or day treatment. CBHCs may offer some of these services, but they will not be included in the CBHC scope of services or encounter rate. CBHCs will be required to facilitate referrals to needed behavioral health services not provided by the CBHC. EOHHS anticipates that participation in the CBHC model will create synergies for providers that are pursuing SAMHSA CCBHC designation.
Q: Will CBHCs be required to have partnerships with other service providers?
A: CBHCs will be expected to maintain formal referral partnerships with specialty behavioral health providers to ensure member access to certain services that are not directly delivered by the CBHC, such as methadone treatment and naltrexone injection, Children’s Behavioral Health Initiative (CBHI) services, and certain evidence-based practices. CBHCs will have flexibility to determine the structures of these partnerships.
Q: How will CBHI services, performance specifications and payment methodologies be incorporated into CBHCs? Will CBHCs provide ICC? MCI?
A: CBHCs will not be required to deliver Intensive Care Coordination (ICC), Family Support and Training (FS&T), In-Home Therapy (IHT), Therapeutic Mentor (TM), or In-Home Behavioral Services (IHBS), but they will be expected to maintain strong referral partnerships with CBHI providers and facilitate access to those services as needed. Each CBHC will deliver 24/7 community and mobile crisis services, including Mobile Crisis Intervention, for a defined geographic region.
Q: How do the CBHCs intersect with Behavioral Health Community Partners (BH CPs)?
A: Aligning the roles and relationship of behavioral health community partners with the development of CBHCs is under active discussion with stakeholders as part of the development of MassHealth’s 1115 waiver renewal. We strongly encourage any BH CP that is eligible to respond to the upcoming CBHC procurement.
Q: Will there be future opportunities for providers to become CBHCs after the initial procurement?
Q: Will existing clinics that are not selected to become CBHCs be able to offer services after the procurement of the new regional CBHCs?
A: Yes, existing providers may maintain their scope of services for current clients. Clients will continue to select provider(s) and will not be automatically transferred to CBHCs.
Q: Does the state plan to make investments in community-based providers that do not become CBHCs, including clinics that have small volume?
A: Yes, EOHHS plans to make investments for community-based behavioral health providers outside of CBHCs. For example, MassHealth intends to identify and provide increased funding for a network of behavioral health providers that offer urgent care/rapid access with timely follow up appointments. MassHealth also plans to review and make updates to base rates for outpatient behavioral health treatment in its fee-for-service and managed care programs.
Additionally, EOHHS will expand investments in outpatient SUD treatment, including expanding the Office-Based Addiction Treatment (OBAT) model, and developing a MassHealth payment method to support the Bridge Clinic model, which delivers rapid, low barrier access to medication and therapy to treat SUD.
Q: How does the Roadmap support OP/diversionary services, such as Psychiatric Day Treatment (PDT), Structured Outpatient Addiction Program (SOAP), and Intensive Outpatient Program (IOP), that may be delivered outside of a CBHC?
A: Through its upcoming 1115 demonstration waiver renewal, EOHHS intends to expand the MassHealth fee-for-service benefit to include several diversionary services which are currently covered only in managed care. These include Program of Assertive Community Treatment (PACT), SOAP, and IOP.
Behavioral Health Urgent Care
The following pertains to MassHealth Behavioral Health Urgent Care, updated April 4, 2022
Q: Must MCEs contract with all Mental Health Centers (MHCs) designated as Behavioral Health Urgent Care providers (“Behavioral Health Urgent Care providers”) if such providers are not already within the MCE’s provider networks?
A: No, however, ACPPs, MCOs, and the BH Vendor must contract with all Mental Health Centers in their network that are designated as Behavioral Health Urgent Care providers at a rate that reflects a 15% increase over the plan’s otherwise negotiated rates for all applicable procedure codes described in Table 1 of Bulletin 83.
Staffing and Service Delivery
Q: Must staffing composition during Behavioral Health Urgent Care extended appointment availability be the same as staffing composition during regular hours?
A: MassHealth expects Behavioral Health Urgent Care providers to remain open at typical operating capacity during extended appointment availability hours and to have adequate staff to meet Members’ needs during all hours of operation.
Q: Must Behavioral Health Urgent Care providers provide interpretation and translation services during extended appointment availability hours?
A: Yes, appointments that occur during extended hours must employ the same interpretation and translation services as those that occur during typical operating hours.
Q: Must Behavioral Health Urgent Care providers offer services to Members of all ages during extended appointment availability times?
A: Behavioral Health Urgent Care providers must offer services to the population of Members typically served at that location during all hours of operation, including during extended appointment availability.
Q: Can the designated Behavioral Health Urgent Care providers provide urgent MAT evaluations through a partnership agreement with another provider?
A: MassHealth prefers the Behavioral Health Urgent Care providers to perform urgent MAT evaluations onsite, however, MAT evaluations may be provided through a partnership agreement with another provider. Whether provided directly by the Behavioral Health Urgent Care provider, or in partnership with another provider, all urgent MAT evaluations must occur within the specified timeframe.
Q: What are the required extended appointment availability hours?
A: Please refer to Bulletin 76.
Q: May Behavioral Health Urgent Care providers meet the requirement to offer extended appointment availability by providing appointments during extended appointment availability via telehealth?
A: Behavioral Health Urgent Care providers must be open during extended hours. All decisions regarding the appropriateness of telehealth interventions must be made based on Member need, and in collaboration with the Member/Member’s family.
Q: How is “urgent behavioral health need” defined and is there any diagnostic guidance or required screening tool?
A: Urgent behavioral health needs are characterized by changes in behavior or thinking, role dysfunction, emerging intent of self-injury, or threats to others, but do not include immediate risk of harm to self or others. A determination of an urgent behavioral health need should be made by the triaging or treating provider in consultation with the individual seeking treatment or their caregiver or guardian. This does not include emergencies. MassHealth does not require the use of a specific screening tool to make this determination.
Q: Does the “same or next day” requirement for initial diagnostic evaluations start on the date of first contact?
A: Yes. If the need is determined to be urgent, an appointment for initial diagnostic evaluation must be scheduled for the same or next day after the member’s first contact, including calls or visits in-person to schedule an appointment. Urgent psychopharmacology appointments and MAT evaluations shall be completed within 72 hours of the diagnostic evaluation and based on a psychosocial assessment. All other treatment appointments must occur within 14 calendar days of first contact.
Q: Which code modifiers can be billed with the BH UC modifier?
A: Providers may bill any eligible and applicable modifiers in addition to the BH UC modifier, GJ, when billing the procedures codes described in Table 1 of Bulletin 83.
Q: What is the best practice for billing multiple modifiers?
A: BH UC providers should refer to each health plan’s specific billing guidance when billing with multiple modifiers.
Q: When must data collection systems be operational, and when will the quarterly data reports be due?
A: MassHealth’s Behavioral Health Vendor will establish a reporting system and due dates on MassHealth’s behalf. MassHealth anticipates that providers will have adequate notice to set up systems to gather the required data.
Q: If an appointment is offered within the designated time frame and the Member declines that appointment, how should the Behavioral Health Urgent Care provider report this?
A: The reporting requirements are outlined in Bulletin 76. The Behavioral Health Urgent Care provider must make best efforts to respond to Members’ needs when scheduling appointments.
Q: Must the Behavioral Health Urgent Care providers meet certain reporting benchmarks or percentages?
A: Benchmarks will be established based on data collected during the first year of Behavioral Health Urgent Care operation. Behavioral Health Urgent Care providers may be required to meet those benchmarks in subsequent years of operation.
Q: How will the crisis system intersect with the new CBHCs?
A: The Emergency Services Program/ Mobile Crisis Intervention (ESP/MCI) system will be re-procured in conjunction with the procurement of the CBHC system. New Youth Community Crisis Stabilization (CCS) services will also become available alongside the existing Adult CCS service, as part of the enhanced ESP/MCI system. In addition to outpatient and urgent treatment, all CBHCs will provide 24/7 community and mobile crisis services, including ESP/MCI and CCS, for a defined geographic area. The geographic regions assigned to CBHCs may be similar to current ESP/MCI regions or may be modified.
Q: What does the future of crisis services in the Emergency Department vs. in the community look like?
A: Hospital Emergency Departments (EDs) will be newly required to take responsibility for the provision of behavioral health crisis services in the ED. Specifically, EDs will be expected to provide for crisis evaluation and intervention when individuals present in the ED, while CBHCs will deliver mobile and community-based response as well as follow up care. The goal is to shift the crisis continuum into the community and ensure broad access to community-based and mobile crisis care, with a strong connection to follow-up outpatient services through the CBHCs. The shift in ED expectations will be implemented simultaneous to the launch of the new CBHC-based system for 24/7 community and mobile crisis services.
Q: How will EOHHS strengthen the delivery of community and mobile crisis services?
A: The Roadmap proposes a stronger 24/7 community and mobile crisis intervention response to provide a robust alternative to the ED for individuals experiencing a behavioral health crisis, with the goal of shifting an even greater share of crisis intervention encounters into the community rather than the ED. In order to achieve this:
- Accountability for regional 24/7 community and mobile crisis response will be integrated with CBHCs that have the capacity to provide Community Crisis Stabilization for adults and youth, as well as follow-up and ongoing outpatient treatment as appropriate.
- The MassHealth payment model for ESP/MCI will be designed to support enhanced community-based response, crisis intervention, and follow-up. EOHHS plans to take advantage of enhanced federal funding for mobile crisis intervention in the American Rescue Plan to support increased funding for community-based encounters.
- The 24/7 community and mobile crisis system will be available to all residents, regardless of what type of insurance they have. EOHHS is engaging stakeholders, including commercial insurance carriers, to determine how best to achieve this goal.
Q: Are there plans to pursue enhanced federal match for mobile crisis in the recently enacted American Rescue Plan and invest in community services?
A: Yes, EOHHS will seek to maximize and leverage all federal funding available to support the ESP/MCI programs.
Q: How does the Roadmap address the particular needs of individuals involved in the criminal justice system and support arrest diversion?
A: EOHHS recently released an RFR for Behavioral Health Supports for Justice Involved individuals, a statewide program to assist individuals who are current Inmates or Detainees, or on Probation or Parole in navigating and successfully engaging with health care services, with an emphasis on Behavioral Health Services. The Roadmap further expands access to quality services for individuals with involvement in the criminal justice system in several ways. These include: requiring CBHCs to facilitate access to tailored services for individuals who are justice involved and to maintain communication relationships with Probation and Parole, Court, Houses of Correction, Department of Correction, and the District Attorneys’ offices to appropriately support individuals navigating the system. The Request for Proposals (RFP) for CBHCs will also require respondents to propose how they will partner with EMS and law enforcement to support diversion.
Acute and Post-Acute Services
Q: What is EOHHS doing to address Emergency Department (ED) boarding and support the increased demand for inpatient psychiatric services in light of the pandemic?
A: During the COVID pandemic there has been a significant increase in patients waiting in EDs for inpatient psychiatric treatment as a result of increased need for acute psychiatric treatment and constrained bed capacity. EOHHS is providing one-time startup funding incentives and supplemental payments (equivalent to 25-30%+ rate add-ons) to increase inpatient capacity, totaling approximately $40 million in state fiscal year 2021. At this time, more than 250 new treatment beds have been committed by hospitals across the Commonwealth, including more than 80 beds for children and adolescents. These treatment beds start to come online in the spring of 2021, and we expect additional beds to open over the course of the year. The MassHealth supplemental funding for expanded child/adolescent inpatient psychiatric bed days will continue through FY23.
EOHHS also provided 10-20% across-the-board rate increases for inpatient psychiatric stays during the first COVID surge in 2020 and is continuing to provide enhanced funding for inpatient psychiatric treatment for COVID-positive patients and dedicated COVID-positive inpatient psychiatric units.
Looking forward, MassHealth is convening a workgroup of general hospitals and freestanding psychiatric hospitals to inform development of new reimbursement methodologies for inpatient psychiatric treatment. This workgroup began in April 2021.
EOHHS also anticipates that expanded access to community-based urgent treatment supported through the Roadmap (e.g., CBHCs, behavioral health urgent care/rapid access) will help to further alleviate ED boarding.
Q: Is EOHHS expanding peer-run respite programs?
A: As a part of the emergency response to the COVID-19 pandemic, DMH has contracted for additional respite beds across the state, including a new respite program in Central Massachusetts operated by a peer run organization. These new respite beds are not limited to DMH clients, and their priority is to serve individuals being discharged from inpatient psychiatric treatment who have complex needs.
Q: What elements of the roadmap target the needs of children with intellectual/developmental disabilities?
A: EOHHS will require that CBHCs provide services for individuals with Autism Spectrum Disorder and those with Intellectual or Developmental Disabilities (ASD/IDD) who have co-occurring behavioral health conditions.
Starting in July 2020, EOHHS launched a specialty consultation service that allows ESP/MCI crisis clinicians to consult with ASD/IDD specialists to improve their ability to appropriately treat youth and young adults with ASD/IDD who are in behavioral health crisis. Through the Roadmap, EOHHS will expand access to the ASD/IDD expert consultation service to other ambulatory service providers and settings.
In addition, EOHHS is working with providers to increase the number of inpatient psychiatric units with specialized capacity to treat children and adolescents with ASD/IDD. Twenty-four such beds are slated to open in late 2021.
Q: What provisions does the Roadmap include to improve behavioral health equity?
A: The Roadmap addresses behavioral health inequities through several key strategies:
- Diversifying the workforce to be more reflective of the Commonwealth’s residents, including through student loan repayment incentives for clinicians with diverse cultural, racial, ethnic, and linguistic competence.
- Expanding coverage of peers for mental health and addiction.
- A multi-lingual “front door,” including ASL interpreters.
- Providing treatment when and where people need it to reduce disparities in access to behavioral health services related to transportation, time off from work and childcare by expanding the availability of integrated behavioral health services within primary care, extending broad telehealth coverage, and requiring extended hours, including weekends, at CBHCs and behavioral health urgent care.
- Providing culturally competent care. Require CBHCs to provide services in clients’ preferred language (including ASL). Require CBHCs to provide tailored services for populations such as individuals who are justice involved, individuals with ASD/IDD, and youth in the care and custody of the Commonwealth.
- Offer training for behavioral health providers in evidence-based practices (e.g., trauma-informed therapies) that better meet the needs of Massachusetts’ diverse populations.
Services Across the Lifespan
Q: How will older adults be supported through the initiatives described in the Roadmap?
A: All CBHCs will be expected to meet the needs of individuals across the lifespan either directly within the provider organization or through formal relationships with other provider organizations with expertise in serving this population. For older adults, this includes providing services in a client’s home or other community environments when appropriate and having connections with local Aging Service Access Points and other community-based aging services providers to help facilitate and coordinate services. The Roadmap also contemplates the drafting and dissemination of a resource guide of older adult behavioral health supports.
Q: How will the Roadmap strengthen services for children and youth?
A: EOHHS considered the specific needs of youth and families throughout the design of the Roadmap and takes an interagency approach to addressing challenges faced by youth and families in accessing specialized services that meet their needs. CBHCs will be required to provide a robust set of youth-specialized outpatient services. These services will be staffed with youth-trained clinicians and able to deliver particular evidence-based practices for children and adolescents, such as structural family therapy and Adolescent Community Reinforcement Approach (A-CRA).
As part of the CBHC network, EOHHS will introduce new Youth Community Crisis Stabilization Services to provide intensive short-term clinical treatment and stabilization to help divert youth from avoidable trips to the ED or inpatient hospitalization.
The Roadmap also includes a strategy to support integrated behavioral health in primary care practices through flexible value-based payments as part of MassHealth’s upcoming 1115 waiver renewal. These integrated primary care models will include specific requirements and standards for children, youth, and families. For example, MassHealth will set heightened expectations for participating primary care providers (including pediatric practices) to have behavioral health clinicians integrated within the practice, to continue doing universal behavioral health and developmental screenings for children, to coordinate with schools and social services as appropriate for children, and to provide peer supports for families.
EOHHS will also expand school-based intensive outpatient services, based on the Bridge For Resilient Youth in Transition (BRYT) model shown to reduce the need for inpatient services by leveraging funding through the school-based Medicaid program, and modernize the Child and Adolescent Needs and Strength (CANS) assessment tool interface to reduce administration burden of child-treating clinicians.
Q: How is the Roadmap addressing the needs of youth in the custody of the Department of Youth Services (DYS)?
A: During the development of the Roadmap, EOHHS engaged stakeholders who work with youth involved with DYS and their families. Stakeholders identified as a priority the need for youth in DYS facilities to engage in community-based behavioral health treatment as part of their transition back to the community. In 2020, EOHHS implemented a policy that allows youth in DYS custody and their families to access community-based behavioral health treatment usually covered by MassHealth, including CBHI services, prior to the child’s transition back to the community, to enhance continuity of care and engagement in services.
Q: Does the Roadmap include initiatives related to provider training, such as training in the delivery of evidence-based practices?
A: EOHHS will partner with higher-ed to train clinicians on evidence-based clinical practices to enhance the provision of treatment services. Funding will also be available for MassHealth-enrolled behavioral health providers to support training for peers, including Recovery Coaches and Certified Peer Specialists, as well as Community Health Workers.
Q: Will EOHHS continue to offer student loan repayment opportunities for behavioral health providers?
A: As part of MassHealth’s Delivery System Reform Incentive Payment (DSRIP) program, authorized under its 1115 demonstration waiver, MassHealth currently provides student loan repayment for certain clinicians working in safety net settings. As part of its proposal to renew its 1115 waiver, MassHealth will propose to continue providing student loan repayment for behavioral health clinicians, while targeting the program to increase diversity in the clinical workforce and promote equity. Under the proposal MassHealth will be seeking authority to offer student loan repayments to behavioral health clinicians who make a multi-year commitment to practicing at a provider organization that serves a significant number of MassHealth members, prioritizing clinicians with diverse cultural and linguistic competency. The proposed loan repayment program will be designed to complement other existing loan repayment programs, including loan repayment administered by the Department of Public Health that is available to a range of health care providers
Substance Use Disorder
Q: How does the Roadmap strengthen 24-hour substance use disorder (SUD) services?
A: DPH and MassHealth will introduce new regulatory flexibilities and enhanced clinical standards for 24-hour SUD providers in 2022. These include licensure updates to allow flexibility in ATS/CCS beds to allow providers to more easily flex beds and provide continuity of care, and requirements that 24-hour SUD providers improve capacity for medication for addiction treatment (MAT), medication management, and treatment of co-occurring medical and mental health conditions. These enhanced clinical standards have been supported by rate increases for EOHHS contracted programs.
Q: Will MassHealth be expanding the types of providers that can provide and bill for Recovery Coach services?
A: In 2021, EOHHS plans to expand the MassHealth Recovery Coach service to settings outside of SUD clinics. MassHealth behavioral health providers that are able to meet the requirements to deliver the Recovery Coach service, including supervisory and infrastructure requirements, will be able to provide and bill for the Recovery Coach service. MassHealth anticipates releasing additional guidance on these changes in the near future.
Q: How will funds from the Substance Use Disorder Federal Reinvestment Trust Fund be used to support providers that expand MAT?
A: The SUD Federal Reinvestment Trust Fund will be used in multiples ways to support and expand access to MAT, including investing in the expansion of OBAT and Bridge Clinic services, and supporting low threshold MAT in outpatient settings. The SUD Trust will also support the expansion and enhancement of the 24-hour addiction treatment system, which will further expand access to MAT. In FY22, approximately $70 million from the SUD Trust will support efforts within the Roadmap that align with the statutorily authorized uses of SUD Trust funds.
Q: How will MassHealth support integrated behavioral health delivered in the primary care setting?
A: MassHealth plans to increase support for behavioral health integration in primary care in two phases. In the first phase, starting in mid-2021, MassHealth will expand direct reimbursement for integrated primary care services. Specifically, MassHealth plans to reimburse for the Medicare behavioral health integration and psychiatric collaborative care management codes, in order to facilitate multi-payer alignment and support a range of integrated care models. As a second phase, as part of the 1115 waiver renewal, MassHealth may shift to a sub-capitated approach for advanced primary care practices starting in 2023. Participating practices would be expected to meet specific standards for integrated behavioral health activities and would receive flexible funding to support that activity, with additional investment for practices with a demonstrated ability to meet the higher standards. MassHealth is engaging stakeholders through workgroups and public meetings to shape the design of the advanced primary care standards and sub-capitation model as part of its 1115 waiver renewal development process
Q: How will the Roadmap streamline the licensure requirements for clinics to support implementation of these initiatives?
A: DPH is currently updating the Health Care Quality Clinic Licensure and BSAS Licensure regulations, and both are under final review after receiving public comment. DPH has collaborated with other state agencies and programs including the Department of Mental Health, MassHealth and the Department of Corrections to reduce administrative burdens, including:
- Streamlining the approval process for facilities operated/licensed by the Department of Mental Health, DPH’s Bureau of Health Care Safety and Quality, or any penal facility operating a separate/identifiable SUD treatment program.
- Removing superfluous requirements from current regulations and providing direct citations to those requirements, in order to keep the regulations focused on SUD-related services.
- Requiring all providers to furnish mental health services, including screening and crisis intervention for patients with co-occurring disorders.
- Creating “Co-occurring Enhanced” as a residential service type, ensuring patients with both substance use and mental health disorders receive appropriate services to address both types of disorders.
Q: How will the Roadmap simplify and reduce the administrative processes associated with provider credentialing?
A: EOHHS is working across the MassHealth program, the Division of Insurance and commercial insurance carriers to promote administrative simplification in the credentialing and enrollment process. MassHealth is actively working to adopt universal credentialing standards and processes across MassHealth fee-for-service and managed care plans in alignment with commercial carriers. As a second phase, MassHealth is considering a standardized behavioral health provider network for members enrolled in managed care, paired with simplified enrollment, contracting and utilization management processes. MassHealth is engaging stakeholders through workgroups and public meetings to solicit input on this approach as part of its 1115 waiver renewal development process.
Q: Does MassHealth plan to update the Mental Health Center (MHC) regulation to support successful implementation of the Roadmap?
A: Yes. To support implementation of the Roadmap and to align with updates planned for the DPH Clinic Licensure and BSAS regulations, MassHealth is planning revisions to the MHC program regulations. These include:
- Emphasizing the allowance for integrated treatment of both mental health and substance use disorders, including requiring SUD screening at intake
- Allowing brief assessments in order to begin client treatment on the same day, with comprehensive assessment to be completed upon subsequent visits
- Requiring after-hours answering service
- Specifying crisis intervention responsibilities and explicitly allowing for operation of an open access program model
- Creating more flexibility in staffing by incorporating allowance of LMFTs, LMHCS, LADCs, and other peers/paraprofessionals into the service model
- Requiring that if a social worker is part of the core multi-disciplinary team, they be independently licensed. Other social workers on staff must be supervised by an LICSW.
MassHealth will request authority under an amendment to its 1115 demonstration waiver to permit clinics, like mental health centers, to provide services outside the clinic, allowing clinics greater flexibility to deliver services at sites in the community.
Q: Will MassHealth continue to pay for clinical services delivered by qualified non-licensed staff working under the supervision of a licensed clinician?
Q: Which of the Roadmap initiatives will commercial plans be required to adopt?
A: Wherever possible, EOHHS seeks to align payment strategies and coverage across payers. Toward that end, EOHHS is engaging directly with commercial health insurance carriers, as well as with the Division of Insurance (DOI), Group Insurance Commission (GIC) and the Massachusetts Health Connector to align across the public and private payer systems. This includes encouraging commercial adoption of key elements of the Roadmap, such as contracting with the new network of Community Behavioral Health Centers and expanding coverage of peer supports and services provided by clinicians in training who are supervised by an independently licensed clinician. DOI is also requiring commercial providers to maintain accurate and timely updated provider directories to ease the burden of accessing an appropriate provider.
In addition, the 24/7 community and mobile crisis system will be available to all residents, regardless of what type of insurance they have. EOHHS is engaging stakeholders, including commercial insurance carriers, to determine how best to achieve this goal.
Glossary of Terms
- A-CRA- Adolescent Community Reinforcement Approach
- ACO- Accountable Care Organization
- ASD- Autism Spectrum Disorder
- ATS- Acute Treatment Services
- BH CP- Behavioral Health Community Partner
- BRYT- Bridge for Resilient Youth in Transition
- BSAS- Bureau of Substance Addiction Services
- CANS- Child and Adolescent Needs and Strength
- CBAT- Community Based Acute Treatment
- CBHC- Community Behavioral Health Center
- CCBHC- Certified Community Behavioral Health Center
- CCS- Community Crisis Stabilization
- CMHC- Community Mental Health Center
- CSP- Community Support Program
- CSS- Clinical Stabilization Services
- DBT- Dialectical Behavior Therapy
- DMH- Department of Mental Health
- DOI- Division of Insurance
- DPH- Department of Public Health
- ED- Emergency Department
- EOHHS- Executive Office of Health and Human Services
- ESP- Emergency Services Program
- FFS- Fee for Service
- FS&T- Family Support and Training
- GIC- Group Insurance Commission
- ICC- Intensive Care Coordination
- IDD- Intellectual and Developmental Disability
- IHBS- In-Home Behavioral Services
- IHT- In-Home Therapy
- IOP- Intensive Outpatient Program
- LADC- Licensed Alcohol and Drug Counselor
- LMFT- Licensed Marriage and Family Therapist
- LMHC- Licensed Mental Health Counselor
- LTSS- Long Term Services and Supports
- MAT- Medication for Addiction Treatment
- MBHP- Massachusetts Behavioral Health Partnership
- MCI- Mobile Crisis Intervention
- MCO- Managed Care Organization
- OBAT- Office-Based Addiction Treatment
- OTP- Opioid Treatment Program
- PACT- Program of Assertive Community Treatment
- PDT- Psychiatric Day Treatment
- RC- Recovery Coach
- RFA- Request for Application
- RFP- Request for Proposal
- SAMHSA- Substance Abuse and Mental Health Services Administration
- SCO- Senior Care Options
- SOAP- Structured Outpatient Addiction Program
- SUD- Substance Use Disorder
- TM- Therapeutic Mentor