APA’s Government, Policy, and Advocacy Update (December 2023)

For many primary care practices interested in integrating behavioral health care, cost can be a significant barrier, standing in the way of widespread adoption of the evidence-based Collaborative Care Model (CoCM). The Connecting Our Medical Providers with Links to Expand Tailored and Effective (COMPLETE) Care Act (S 1378/HR 5819) would enhance payment rates to incentivize practices to implement CoCM.

The legislation was introduced by Sens. Catherine Cortez-Masto (D-Nev.) and John Cornyn (R-Tex.), as well as Reps. Michelle Steel (R-Cal.), Dan Kildee (D-Mich.), Lizzie Fletcher (D-Tex.), Gus Bilirakis (R-Fla.), August Pfluger (R-Tex.), Susie Lee (D-Nev.) and Marc Molinaro (R-N.Y.). The bill would increase Medicare payment for integrated care codes for three years. It would also facilitate technical assistance to practices implementing CoCM and establish quality measurement reporting for behavioral health integration.

Americans who reside in rural areas receive mental health treatment less frequently compared with those living in metropolitan areas. To improve access to care in rural areas, APA urged Congress to take numerous steps to address workforce shortages and invest in telehealth and integrated care. APA’s comments came in response to a request for information from Rep. Jason Smith (R-Mo.), chair of the House Committee on Ways and Means, in which he sought input on how to improve access to care in rural and underserved areas.

To address the workforce shortage, APA urged Congress to support additional Medicare graduate medical education slots for psychiatry and psychiatric subspecialties with residencies in rural and urban areas alike. “Such an investment in the psychiatric workforce would help our nation begin to chip away at the present workforce shortage and better position us to address the growing crisis of access to mental health and substance use–related care and treatment,” stated the letter, signed by APA CEO and Medical Director Saul Levin, M.D., M.P.A.

APA also encouraged continued coverage of care through a variety of modalities, including in person, telehealth, and audio only, and urged Congress to consider the CONNECT for Health Care Act (HR 4189) and the Telemental Health Care Access Act (HR 3432). These bills would expand coverage of telehealth services under Medicare beyond January 2025.

Additionally, APA noted that integrated care leverages the existing behavioral health workforce to support underserved rural populations. The letter urged passage of the COMPLETE Care Act to incentivize adoption of CoCM.

This summer, the Biden administration proposed new rules to strengthen the 2008 Mental Health Parity and Addiction Equity Act (MHPAEA) (Government Proposes New Rules to Strengthen Parity Law). The rules propose closing loopholes and clarifying the law’s requirements to ensure that patients can access treatment for mental and substance use disorders as easily as those seeking coverage for other types of medical care. Comments closed October 17.

In its comments on the rules, APA shared its strong support for the administration’s efforts to help bring insurers into compliance with MPHAEA immediately. “Studies continue to show that people cannot access benefits for care of [mental health and substance use disorders],” APA’s letter, signed by Levin, stated. “These validate ongoing concerns that insurance plans and insurers are still not compliant with the federal parity law.”

APA recommended some areas in which the rules could be clarified and improved so patients can access the care they need “without encountering illegal and discriminatory barriers to that care.” ■