On June 17, 2024, the Center for Medicare and Medicaid Innovation (CMMI) at the Centers for Medicare and Medicaid Services (CMS) released a notice of funding opportunity (NOFO) for the Innovation in Behavioral Health (IBH) model to states investing in behavioral health integration. This new eight-year state application-only initiative aims to address the needs of adult Medicaid and Medicare enrollees with moderate to severe mental health conditions and substance use disorders (SUD through application). The IBH model seeks to achieve whole-person care for Medicare and Medicaid enrollees by incorporating physical health, behavioral health, and health-related social needs (HRSN) through new care delivery models supported by value-based payment (VBP) methodologies. Interested states must apply for IBH by September 9, 2024.
State Medicaid agencies will administer the IBH model in collaboration with state agencies overseeing mental health and SUD services. Starting in January 2025, up to eight states will be eligible to receive $7.5 million in cooperative agreement funding over the model’s eight-year flight period. The initial three years will be a pre-implementation phase, during which states will recruit practices, design care delivery and payment models, and build necessary infrastructure. Full implementation of the model will commence in January 2028.
States have flexibility to implement IBH statewide or in select regions. Participating practices will have the flexibility to serve their Medicaid populations exclusively or their Medicaid and Medicare populations. The model presents a significant opportunity to transform behavioral health care delivery by ensuring the comprehensive management of patient’s physical and mental health needs in addition to an explicit option to use funds on staffing and infrastructure.
Key Features of IBH
- Care Integration: The IBH model aims to incentivize whole-person care by incorporating physical health, behavioral health, and health-related social needs (HRSN) through new care delivery models.
- Payment Approach: The model is supported by value-based payment (VBP) methodologies, which align financial incentives with improved patient outcomes in addition to regular reporting to guarantee funding for Medicare and Medicaid enrollee reimbursements.
- Infrastructure Funding: Up to eight states will be eligible to receive $7.5 million in cooperative agreement funding, allowing the funding of telehealth infrastructure, population health management tools, staffing & workforce investments, and creation of new clinical workflows.
Considerations for State Medicaid Agencies
- Alignment with Existing Initiatives: States already participating in initiatives like the CCBHC demonstration or Health Home program should consider how IBH can complement and enhance their current integrated care models. Though EHR adoption supports were off the table after the HITECH act, state Medicaid organizations may use IBH funding to modernize including the adoption and enhancements of electronic health records.
- Sufficiency of Infrastructure Funding: Planning and implementing IBH will require significant resources. States must assess whether the available funding over eight years is sufficient to meet federal requirements and support state-level infrastructure needs.
- Provider Interest and Commitment: Successful implementation of IBH depends on securing commitments from behavioral health providers. States must gauge interest and ensure provider communities are invested in seeing the model through.
- Weighing the Requirements: Organizations will only be held responsible for upside risk for Medicare performance-based treatment. Here, too, payments are based in part (10 percent) on the quality strategy incorporating standard and patient-reported outcomes. States are also required to participate in federal IBH evaluation initiatives.
Conclusion
The Innovation in Behavioral Health (IBH) model presents a new opportunity for states to enhance care delivery for Medicaid and Medicare enrollees with severe mental health conditions and substance use disorders. By integrating physical health, behavioral health, and social needs, the IBH model aims to provide comprehensive, value-based care through a single organization. States must carefully consider the alignment with existing initiatives, the adequacy of funding, and the interest and commitment of providers as they prepare their applications.
The IBH model offers a path to more integrated, equitable, and cost-effective care for states looking to transform their behavioral health care systems. The deadline for applications is September 9, 2024. The application can be found here.