CMS Proposes Rule to Reimburse for Psychiatric Collaborative Care

Medicare plans to begin reimbursement next year for collaborative care services, according to an announcement last month by the Centers for Medicare and Medicaid Services (CMS).

In the proposed Medicare Physician Fee Schedule rule, CMS has included coverage for “Psychiatric Collaborative Care Management Services.” The decision will support payments to psychiatrists for consultative services they provide to primary care physicians in the collaborative care model (CoCM). The model was developed by the late Wayne Katon, M.D., and Jürgen Unützer, M.D., M.P.H., at the AIMS Center of the University of Washington. It is the only evidence-based model of its kind and has been proven effective in more than 80 randomized, controlled trials.

The proposed rule was published in the Federal Register on July 15. CMS will accept comments on the proposed rule until September 6 and will issue its final rule later this year.

The new codes open the door to greater adoption of the CoCM model by removing a principal barrier—the lack of a structure for reimbursement of consulting physicians who participate in the model. Development of codes and payment for them has been a major APA priority.

“This is a huge win for APA, psychiatrists, as well as patients with mental health and substance use disorders,” said APA CEO and Medical Director Saul Levin, M.D., M.P.A.

In the CoCM, the primary health care provider employs a behavioral health care manager to provide ongoing care management for a caseload of patients with diagnosed mental health or substance use disorders. The psychiatrist provides the primary care practice with expert advice and consultation through regular case review and recommendations for treatment and medication adjustments. In especially difficult cases, the psychiatrist may also provide direct treatment.

APA is in the process of analyzing the proposed values for the codes to determine whether they are sufficient to support the CoCM model. APA leadership and staff will have more than one avenue through which to properly value the codes—through comments submitted to CMS and through APA’s participation in the Relative Value Update Committee (RUC) valuation process.

The RUC, created by the AMA in 1991, advises CMS about changes in the “relative value units” used in the formula for determining physician payment under Medicare. The 29-member committee—with representatives from the AMA, APA, and other specialties—offers recommendations about the relative value units that result in payment for every reimbursable code in the Current Procedural Terminology Manual and helps to derive values for newly introduced procedures that receive codes.

“The APA administration is continuing to review the rule for specifics and will work with CMS to ensure that there is adequate compensation to support the work of psychiatrists in collaborative care networks,” Levin said.

Medicare coverage for collaborative care services and adoption of the related codes is an important step in the evolution of integrated care. It is part of a larger strategy that CMS says is designed to pay physicians for value of care provided (as opposed to paying for the volume of services) and to reward physicians to spend more time with patients. In the proposed rule, for instance, CMS is also proposing that Medicare pay for cognitive and functional assessment and care planning for patients with cognitive impairment, including patients with Alzheimer’s.

“Today’s proposals are intended to give a significant lift to the practice of primary care and to boost the time physicians can spend with their patients listening, advising, and coordinating their care—both for physical and mental health,” CMS Acting Administrator Andrew Slavitt said in a statement on the CMS website. “If this rule is finalized, it will put our nation’s money where its mouth is by continuing to recognize the importance of prevention, wellness, and mental health and chronic disease management.”

These Psychiatric Collaborative Care Management Services may be billed on a monthly basis by the primary care provider who employs a behavioral health care manager and has a separate financial arrangement to reimburse the psychiatrist. These are the temporary “G” codes for 2017 that have been included in the proposed rule:

• GPPP1: Initial psychiatric collaborative care management, with 70 minutes of behavioral health care manager time.

• GPPP2: Subsequent psychiatric collaborative care management, with 60 minutes of behavioral health care manager time.

• GPPP3: Additional 30 minutes of behavioral health care manager activities.

These are similar to the Psychiatric Collaborative Care Management codes that the CPT Editorial Panel approved for use starting in 2018.

The CPT coding proposal was brought by APA, with the assistance and participation of several other medical specialty societies, including the American Academy of Child and Adolescent Psychiatry, the American Academy of Family Physicians, and the American College of Physicians.

Importantly, APA received a grant from CMS through its Transforming Clinical Practice Initiative to train psychiatrists and primary care physicians in the CoCM and to encourage systems to implement the model. Training will be provided online and at APA meetings, including the upcoming IPS: The Mental Health Services Conference in Washington, D.C., in October. ■