talization (a service that allows a patient to get inpatient hospitallevel treatment during the day), and outpatient therapy. But sometimes patients need a more intense service than outpatient therapy, but less than the level of hospital-level care a hospitalization would provide – for example, a patient with debilitating depression, which causes them to struggle with daily tasks, but at the same time does not require hospitalization. For the first time, thanks to Congressional action, CMS is proposing to pay for this intermediate level of care, called "Intensive Outpatient Program" (IOP), which can be performed by hospital outpatient departments, community mental health clinics, Federally Qualified Health Centers, or Rural Health Clinics. CMS is also proposing to provide payments for intensive outpatient services provided by opioid treatment programs. This new benefit category would significantly expand access to behavioral health services.

CMS is also proposing changes to promote access to behavioral health for underserved communities. We are proposing to change the required level of supervision for behavioral health services furnished "incident to" a physician or NPP's services at RHCs and FQHCs to allow general supervision, rather than direct supervision. We believe this could expand access to counseling and cognitive behavioral therapy, particularly in rural or underserved communities where care can be hard to find. Additionally, we propose to continue to allow opioid treatment providers to provide certain services via telephone or audio-only technology, which could improve access to care, particularly in rural and other underserved areas challenged by stable broadband options.

PAYING MORE ACCURATELY FOR BEHAVIORAL HEALTH SERVICES

Finally, CMS is proposing changes to more accurately value and pay for behavioral health services. When a person has significant psychological distress, crisis services may be necessary. Crisis services outside of clinical settings – where behavioral health practitioners meet patients in crisis where they are – can be especially important and effective. Through the implementation of legislation, CMS is proposing to increase the value of psychotherapy for crisis services to pay 150% of the usual Physician Fee Schedule rate when this crisis care is provided outside of health care settings, which better reflects the costs that behavioral health practitioners incur to provide these services. CMS is also proposing to increase the payment rate for substance use disorder treatment in order to better reflect the costs of the counseling services and to increase payment for psychotherapy services.

Finally, significant amounts of the nation's behavioral health care services are provided by primary care providers. Still, CMS has not always accounted for the complexity of primary and other longitudinal care with Medicare payments. CMS is now proposing to provide additional, appropriate payments for providers delivering

primary and longitudinal care, which could help ensure patients get appropriate treatment and referrals for behavioral health care.

CONCLUSION

Individually, each of the proposed changes we have described here would help to make an essential contribution towards strengthening behavioral health care for people with Medicare, and taken as a whole, we are optimistic that we can make a profound and sustained difference in the behavioral health treatment of millions of Americans. •

ABOUT THE AUTHORS:

Dr. Meena Seshamani is the Director of the Center for Medicare at Centers for Medicare & Medicaid Services, where she is responsible for operations and policy for the health care coverage of 63 million Americans in the Medicare program. She led the Office of Health Reform at HHS over both of President Obama's two terms in office, driving regulations implementing the Affordable Care Act, and supporting legislative action around insurance coverage, Medicare, and Medicaid reform. She has strong relationships across health care stakeholder groups, from consumer representatives to insurance executives. Dr. Douglas Jacobs is the Chief Transformation Officer in the Center for Medicare at the Center for Medicare and Medicaid Services (CMS). In this role, he helps to lead center-wide efforts to move the health care system towards value-based care, advance health equity, and promote delivery system transformation. Medicare is the nation's largest payer, responsible for more than 1 in 5 health care dollars spent in the US and responsible for covering more than 63 million Americans. Prior to this role, he was the Chief Medical Officer and first Chief Innovation Officer for the Pennsylvania Department of Human Services (DHS), where he helped oversee the state's Medicaid program. Dr. Jacobs is a board-certified Internal Medicine Physician and has continued seeing patients throughout the pandemic.

ABOUT THE CENTERS FOR MEDICARE AND MEDICAID SERVICES

The Centers for Medicare and Medicaid Services (CMS) provides health coverage to more than 100 million people through Medicare, Medicaid, the Children's Health Insurance Program, and the Health Insurance Marketplace. The CMS seeks to strengthen and modernize the Nation's health care system, to provide access to high quality care and improved health at lower costs.