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CMS Announces New Model for the Delivery of Integrated Behavioral and Physical Health Care

With the goal of enhancing health care quality and outcomes for individuals with moderate to severe behavioral health conditions and substance use disorders (SUD), the Centers for Medicare & Medicaid Services (CMS) recently announced it will launch the state-based, voluntary Innovation in Behavioral Health (IBH) Model in fall of 2024.


CMS will circulate a Notice of Funding Opportunity (NOFO) in spring of 2024 and select up to eight states to participate in the IBH Model, which is expected to last for eight years. Selected states will align with their respective state Medicaid agencies (SMAs) on clinical policies for integrated care and work with Medicaid Managed Care Organizations (MCOs) or other partners for model development and implementation. 


IBH Practice Participants


Community-based behavioral health organizations and providers, including Community Mental Health Centers, public or private practices, opioid treatment programs, and safety net providers where individuals can receive outpatient mental health and SUD services (collectively, practice participants) in selected states will be eligible to participate in the IBH Model. Practice participants can use Medicaid and Medicare-aligned payment models and must meet all of the following criteria at the time of application:

  • licensed to deliver behavioral health services (mental health and/or SUD);
  • compliant with all state-specific Medicaid provider enrollment requirements;
  • eligible to receive Medicaid reimbursement;
  • serve adult Medicaid beneficiaries (age 18 or older) with moderate to severe behavioral health conditions; and
  • offer outpatient mental health and/or SUD services. 

CMS also noted in an IBH FAQ that all practice participants will be required to adopt and use health IT standards under the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program over the course of the model period. CMS’s IBH model team will collaborate with ONC to develop specific requirements and guidelines for practice participants.


IBH Model Implementation


The duration of the eight-year model is broken into “pre-implementation” (model years 1-3) and “implementation” (model years 4-8) periods. Awardee states will engage and recruit practice participants to participate in their respective model programs during model year one. In the pre-implementation period, SMAs will receive funding from CMS to support activities such as augmenting statewide health IT infrastructure and creating a Medicaid Alternative Payment Model (APM); Medicare-only practice participants will receive funding for similar pre-implementation activities during this time.


SMAs and Medicare-only practice participants, during the implementation period (model years 4-8), will receive payments to support practice participant implementation of the care delivery framework. Practice participants may earn performance incentives based on a limited set of quality measures; additional information on the scope and structure of these incentives will be provided in the NOFO. 


Practice participants also will conduct initial screenings and assessments of patients for behavioral health conditions, physical health conditions, and health-related social needs (HRSNs) such as housing, food, and transportation as well as provide appropriate treatment and referrals to care specialists and community-based resources. Practice participants must also create Health Equity Plans (HEPs) that will aim to address any applicable health disparities within their respective patient populations.



The IBH Model was developed in connection with the HHS Roadmap for Behavioral Health Integration and is the latest model to be tested by the Center for Medicare and Medicaid Innovation (CMS Innovation Center). Among the goals with the development of the IBH model is to ease the transition from fee-for-service (FFS) to value-based payments. States and potential practice participants will likely be eager to learn what type of detail is offered in the NOFO regarding payment models, including the opportunity for performance-based payments. CMS stated in the FAQ that the IBH Model is unlikely to qualify as an Advanced APM under the CMS Quality Program, which requires certain payment and patient thresholds to be met, but added that it will explore whether the model would qualify as a Merit-based Incentive Payment System (MIPS) APM for MIPS-eligible clinicians.

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Kathryn F. Edgerton is a Member at Mintz and a Certified Information Privacy Professional (CIPP-US) who advises hospitals and other health-related organizations on a broad range of transactional, regulatory, and strategic issues. Her clients include physician organizations, long-term and behavioral health providers, telemedicine providers, home health providers, and medical spas.
Pat focuses his practice on advising health care organizations on regulatory, compliance, data privacy, and transactional matters. He is also a Certified Information Privacy Professional–US (CIPP–US).