Mental health providers and advocates are welcoming long-awaited Medicare regulations that set standards for community mental health centers that get reimbursed for partial hospitalization.
Some are concerned, however, that the rules will allow the centers to skimp on hiring psychiatrists and social workers, and that reimbursement for the service is too low to make the conditions worth following.
Partial hospitalization is a level of service that requires patients to come to a facility for several hours a day for treatment, rather than once a week for a short period of time for outpatient treatment. Under the new rule, community mental health centers that bill Medicare for partial hospitalization must follow the same conditions of participation that govern hospitals providing these services.
As of 2012, the CMS estimated that there were 100 certified community mental health centers that billed Medicare for partial hospitalization services without any universal standard guiding the care they provided. Combined, the organizations were serving 22,700 individuals nationwide, the federal agency calculated.
The American Psychiatric Association is concerned that the final version issued last week will allow those centers to avoid paying professionals with advanced degrees because it allows peer specialists (people who have received mental health services and get training to help others) to serve on treatment teams.
That’s a change from the 2011 draft rule, which required teams composed of medical professionals with advanced degrees and licenses.
“It’s a little disconcerting to us that they are allowing a broader cadre of professionals to be eligible to serve on the teams,” said Julie Clements, deputy director of regulatory affairs at the American Psychiatric Association.
In addition to setting professional qualifications, the rule lays out standards for client rights, admission, initial evaluation and organization governance.
Other observers had a more positive view of the rule, suggesting that having standards in place could lead to greater reimbursement for these services from private insurers.
“They’ll be able to say we meet the minimum standards, so if you pay for our services, you know what you’re getting,” said Mark Covall, president and CEO of the National Association of Psychiatric Health Systems.
Compensation from private insurers would also establish some much-needed credibility for community organizations that provide partial hospitalization, according to Charles Ingoglia, senior vice president of public policy at the National Council for Community Behavioral Healthcare.
“For a long time, there has been a lot of fraud and abuse associated with this, and that’s not good for anybody,” Ingoglia said.
There is a chance that few community mental health organizations will choose to participate—the number providing the service has already dropped because of the low rate that Medicare pays them for it, said Larry Meikel, president Association for Ambulatory Behavioral Healthcare. “There is no incentive for them to come back, unless rates go up,” he said.
Community organizations now receive $109 per day compared with $200-$230 in recent years, Meikel said. Hospitals offering these services have also seen rates drop, he said, but they are still getting $228 a day for comparable services.
The CMS estimates that adhering to the conditions will cost a community center approximately $30,000 the first year of implementation and $22,000 in subsequent years.