CMS created new fee-for-service Medicare payment codes to increase the delivery of integrated behavioral health care, but these codes were used minimally in their first two years. Providers most often billed for general case management that does not require BHM or psychiatrist consultation, suggesting insufficient infrastructure and processes to support more robust BHI services. Indeed, early adopters of BHI codes have struggled to implement feasible and sustainable staffing, care delivery, and billing practices.3 Other codes for similar enhanced coordination services (e.g., Chronic Care Management) also experienced low initial take-up, though not to the same extent.4 This suggests that the structural investments required for BHI services may be particularly challenging.
Current reimbursements may be insufficient to catalyze BHI service adoption.5 For the more resource-intensive BHI service codes (i.e., those requiring psychiatrist consultation and 60–70 minutes of care delivery by a BHM), other mechanisms might be required to support upfront structural investments, such as a per-member per-month payments based on number of patients potentially eligible for BHI services (i.e., based on diagnosis). Organizationally, practices with low or uncertain BHI service volumes could explore sharing personnel and contract structures with other local practices, and consider how to utilize staff that can deliver and bill for both behavioral health and other types of care management.3
Use of BHI codes in the first two years was low, but grew steadily. Identifying the characteristics of participating provider organizations, and the clinical utilization patterns of BHI service users, will help inform payment policy and organizational implementation strategies that can support BHI as part of more comprehensive care management infrastructure.