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Substance Use Disorder

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Integration is a hot topic and buzzword in health care. And, integrated primary and behavioral health care is the best approach to care for people with complex health care needs. But do you have an elevator speech when someone asks you about integrated care? What do you tell new staff during orientation and how do you communicate the value to potential partners and your board of directors? Join this webinar to go back to the basics of primary and behavioral health care integration and learn how to effectively communicate the importance of integrated care and the benefits to the people you serve.

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Last week Insurance Commissioner Teresa Miller reiterated to consumers that enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA) is a priority for her department. Miller also encouraged consumers to understand what benefits they are entitled to under the law and to file complaints with the Insurance Department if they believe they are not getting proper insurance coverage. “The Pennsylvania Insurance Department takes this law very seriously, and we will us our statutory authority to enforce parity requirements on plans over which we have jurisdiction,” said Commissioner Miller.

The MHPAEA of 2008 requires health insurance plans to contain the same level of coverage for mental health and substance use disorders as for medical or surgical care. This coverage includes quantitative limitations (copays, deductibles, and limits on inpatient or outpatient visits that are covered) and non-quantitative limitations (pre-authorizations, providers available through a plan’s network, and what a plan deems “medically necessary”).

One important step toward a well-integrated system of health care, both physical and behavioral, is full implementation of the letter and spirit of MHPAEA. RCPA is actively working with health care advocates as part of the state’s Parity Coalition to assure consumers and providers/practitioners that Medicaid, CHIP, and private health plan coverage include quantitative and non-quantitative parity.

For more information on the MHPAEA or to file a complaint or ask a question, visit the insurance department website or call 877-881-6388.

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Your feedback is greatly needed. The US Department of Labor (DOL) has issued its final overtime rule which increases the threshold related to the overtime exemption. This has caused great concern among RCPA members as there is no additional funding being proposed to cover the cost of this change. RCPA will be submitting testimony and testifying in front of the Senate Labor and Industry and Senate Appropriations Committees on Tuesday, June 21 regarding this issue. In preparation for this important Senate hearing, we are asking members to complete this SURVEY no later than Wednesday, June 15, so that we have data to present in addition to our concerns.

If you have already taken the survey, you do not need to provide feedback again. We appreciate your attention and input regarding this very important issue. Thank you.

Please contact RCPA Director of Government Affairs Jack Phillips with any questions.

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The commencement of Certified Community Behavioral Health Clinics through Pennsylvania’s Department of Human Services, and the growing movement of individual providers to create medical homes to provide clients with co-located mental health and primary care providers in one facility, holds tremendous promise and opportunity for the coordination and enhancement of delivery of care to clients. These new provider relationships in shared office and facility spaces create new legal issues for providers under the federal Stark law and Anti-kickback statute. Providers must ensure that they do not inadvertently run afoul of these important federal fraud and abuse laws.

RCPA will offer a webinar presented by Renee H. Martin, JD, RN, MSN, a partner in the firm of Dilworth Paxson, LLP. This webinar will describe the legal requirements providers must be aware of under these federal laws and help to apply that knowledge in structuring financial relationships for use of these shared spaces. The webinar is intended for provider organizations’ executive staff, project planners, and legal counsel.

Stark Law and Integrated Health Care Webinar
Wednesday, June 29
12:00 – 1:00 pm
Register today

  • RCPA member registration is $25
  • Non-member registration is $40

Presenter: Ms. Martin exclusively practices health care law and advises both individual and institutional health care providers on regulatory and transactional matters. A significant portion of her practice centers on mental health and substance abuse law, including HIPAA, informational privacy, and fraud and abuse compliance. Ms. Martin has assisted in the formation of regional health information centers and mental health medical homes, working closely with federally qualified health centers and mental health providers.

RCPA will now distribute INFOS and ALERTS covering research, delivery and training models, policy issues, and other topics that will inform our members about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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The Department of Human Services has issued Bulletin 99-16-04, Enrollment of Co-Located Providers. This bulletin informs providers of the process for enrollment or revalidation of providers that are in co-location arrangements. The bulletin addressed the process for Medicaid enrollment and revalidation for service providers that are “using the same distinct street address as a different currently enrolled provider.” It also addresses situations in which a provider is located within another provider’s offices and is accompanied by the department’s Co-Location Attestation form.

To further support members developing or providing co-located service provider relationships in a shared office and facility space, RCPA will conduct a Lunch and Learn webinar on June 29, focused on the legal issues for providers under the federal Stark law and Anti-Kickback statute. This webinar will describe the legal requirements providers must be aware of under these federal laws and apply that knowledge in structuring financial relationships for use of these shared spaces. Look for webinar information and registration in an RCPA INFO.

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For providers that may be adding behavioral health services to a primary care practice, you’ll need to be sure you’re getting reimbursed for these new services. That means knowing what you can bill for, learning a web of new codes and numbers, identifying which staff can be reimbursed for providing these services, and training staff to code services appropriately. National Council is inviting primary care providers and their behavioral health partners to join integration experts from primary care centers for a webinar on the practical ins and outs of billing for behavioral health services, to a variety of third-party payers, including Medicare and Medicaid.

Participants need to be ready to discuss the menu of billing options available that can match your center’s needs. After this webinar, participants will:

  • Identify billing options for integrated behavioral health services;
  • Ask questions to identify if Medicaid and Medicare numbers are appropriately linked to the mental health services provided; and
  • Employ tips for working with clinical and billing staff at the same time.

This webinar will be held on Monday, June 6, at 2:00 pm. Practitioners and providers can register here.

RCPA will now distribute information on integrated health care. RCPA INFOS and ALERTS will cover research, delivery and training models, policy issues, and other topics that will inform our members (and their physical health care partners) about collaborative, integrated, and co-located health care. To subscribe to this distribution list, select this link and check “Integrated Care.” This will add to your existing email preference selections.

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RCPA has become aware that there have been higher than normal claims denials by both Medicare and Medicaid related to certain diagnoses. Those diagnoses are Schizophrenia and Post Traumatic Stress Disorder (PTSD) as defined by the DSM-V and ICD-10.

The DSM-V only identifies Schizophrenia Not Otherwise Specified (NOS) and PTSD NOS, versus the ICD-10 which offers eight schizophrenia diagnoses and three PTSD diagnoses. As a result, our practitioners are likely choosing Schizophrenia or PTSD NOS, since they are mostly using the DSM-V. Billing staff have options of eight or three diagnoses respectively, but will use what the practitioner has selected, the only DSM-V diagnosis available. It is highly probable that the individual being evaluated meets something other than NOS. There are very specific criteria for the NOS diagnosis which can certainly be used as the criteria is met, but when the criteria is not met, the claims are accurately denied. RCPA wants to hear from you about how this is affecting your business.

The second billing issue is related to electronic health records (EHR) that have not yet loaded the ICD-10 codes for billing. It is our understanding that there are at least two vendors doing business in Pennsylvania who have not loaded the ICD-10 billing codes into the EHR. RCPA wants to hear from members about how they are billing in the absence of the EHR, not having the ICD codes, and other universal billing concerns.

Please find more information about claims rejections here. Send comments to Sarah Eyster by Friday, April 15.

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