WHA submitted written comments November 17 to the Department of Health Services (DHS) on the implementation of Gov. Scott Walker’s October 24 direction to DHS to improve access to treatment for mental health and substantive abuse disorders by increasing the Medicaid reimbursement for behavioral health services. WHA’s written comments can be found here..
In its written comments, WHA thanked the Governor and DHS for this important investment of $7 million in state funds to increase Medicaid reimbursement rates for professionals providing outpatient mental health and substance use disorder services.
However, as DHS implements that increase, WHA urged DHS to include evaluation and management billing codes for psychiatrists, APNP-psych and psychiatric physician assistants in the list of procedure codes that will receive a reimbursement increase. WHA raised the evaluation and management billing code issue with DHS shortly after the October reimbursement announcement, and DHS invited WHA to formalize its feedback in written comments.
WHA specifically highlighted the need to include evaluation and management billing codes because there is often a misperception that all behavioral health billing codes are psychotherapy codes.
“Following national coding standard changes in 2013 that deleted dedicated psychiatric evaluation codes, the vast majority of outpatient services provided by psychiatrists are now billed on evaluation and management codes applicable to all health conditions and providers,” says Matthew Stanford, WHA general counsel. “WHA wants to ensure the services psychiatrists provide to Medicaid enrollees are not overlooked when DHS implements this much-needed reimbursement increase for behavioral health services.”
According to feedback provided to WHA by its members, evaluation and management billing codes make up at least 80 percent of psychiatrists’ outpatient visits for Medicaid patients.
WHA also noted data in its comment letter that documents the critical shortage of physicians specializing in psychiatry, including that Wisconsin’s psychiatrist supply can only meet 25 percent of the need for services, which ranks Wisconsin 8th worst in the nation. WHA received feedback from members that the psychiatry shortage is far more critical than any other behavioral health professional shortages in Wisconsin.
Because of the more acute shortage of psychiatrists compared to other behavioral health professionals, WHA also expressed concern about a draft implementation proposal that would pay physicians specializing in psychiatry, APNP-psych, and psychiatric physician assistants at the same rates as other behavioral health providers without prescriptive authority and lesser education and training requirements. Currently, psychiatrists, APNP-psych, and psychiatric physician assistants receive a higher reimbursement than non-prescribing psychotherapists.
“Lacking identifiable benefits or policy rationale for moving from a four-tiered payment system to a two-tiered payment system that does not recognize differences in professional training levels, practice permissions such as prescriptive authority, salary expenses, and provider shortages, WHA does have concerns about adopting such a change,” said Stanford in written comments to DHS. “It is unclear how such a change will help improve access to care, and such a change may have unintended negative consequences in Wisconsin’s efforts to address its acute shortage of physicians specializing in psychiatry.”
DHS has indicated it intends to implement the outpatient behavioral health reimbursement increase for Medicaid services January 1.