The Blue Cross Blue Shield of Massachusetts Foundation today released a report prepared by Bailit Health Purchasing that identifies key policy and regulatory barriers to the integration of medical and behavioral health services in the Commonwealth.
Developed with input from more than 20 provider organizations, the report focuses on licensing, privacy, and reimbursement rules that were written at a time when primary care, behavioral, and mental health services were provided separately and independently. The report concludes that the current requirements “conflict, overlap and duplicate one another, making it very difficult to navigate among the various requirements to create an integrated program.”
“As a Commonwealth, we need to do better on behavioral health and provide to those in need integrated, coordinated services that support recovery to the greatest extent,” said Audrey Shelto, President of the Foundation. “Through its comprehensive discussion of the barriers to care, we hope that this report will support policy makers in creating needed change.”
Behavioral health reform was identified as one of the top five issues for MassHealth, the state's Medicaid program, in a previous report by the Massachusetts Medicaid Policy Institute (MMPI), a program of the Blue Cross Blue Shield of Massachusetts Foundation.
Building on this prior research, the new report identifies three top priorities as seen by providers:
- Fixing payment policies for behavioral health integration activities, which often inhibit dual treatment of physical ailments and mental illness.
- Development of a universal consent form that can be used by all providers across the continuum of care, along with clarification of state and federal consent requirements.
- Integration of substance use treatments records with physical health and mental health records to facilitate communication among providers.
While highlighting specific challenges, the new report identifies opportunities to restructure licensing and reimbursement requirements to foster greater integration of care. At the same time, the Foundation's report acknowledges that changing privacy requirements to enhance care may be more challenging to address because of concerns about stigma associated with behavioral health issues.
Among the challenges identified in the report, providers seeking licenses find that it can take months to assemble required documentation and receive approvals from the state Department of Public Health. In addition, unlike several other states, Massachusetts requires re-licensing every two years without the chance for the state to consider an organization in compliance based on its record or accreditation from national organizations.
Co-located facilities trying to provide physical and behavioral health services to patients who often need both are subject to complex regulations that limit the kind of services that can be provided. A community health center looking to add mental health services, for example, is required to meet the full staffing and licensure requirements required for a complete mental health facility. In addition, a mental health clinic seeking to add physical health services must submit original architectural drawings for their facility – although a building may be decades old and the drawings impossible to locate.
Billing, payment, and reimbursement rules are written so as to constrain different types of clinicians from working together, and make it difficult to charge for two services provided on the same day. As a result, clinics have an incentive to bring a patient back for multiple visits, which can burden and discourage patients, undermine the effectiveness of care and increase costs.
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About the Blue Cross Blue Shield of Massachusetts Foundation
The mission of the Blue Cross Blue Shield of Massachusetts Foundation is to expand access to health care for low-income and vulnerable individuals and families in the Commonwealth. The Foundation was founded in 2001 with an initial endowment from Blue Cross Blue Shield of Massachusetts. It operates separately from the company and is governed by its own Board of Directors.
About Bailit Health
Bailit Health is a consulting firm dedicated to ensuring insurer and provider performance accountability on behalf of public agencies and private purchasers. The firm was founded in 1997 by former senior executives of the Massachusetts Executive Office of Health and Human Services.
