The Centers for Medicare and Medicaid Services issued a proposed rule this week that would establish conditions of participation for community mental health centers (CMHCs).
"This rule proposes new provisions that will protect the tens of thousands of Medicare beneficiaries who receive care from a CMHC every year," said CMS Administrator Donald Berwick in a statement. "Memorializing the best practices of behavioral healthcare in new Medicare standards gives us the unique opportunity to be sure that safe and effective client-focused care is available to all clients in all communities."
CMHCs provide partial hospitalization services to Medicare beneficiaries, including physician services, psychiatric nursing, counseling and social services. The Medicare benefit offers an alternative to in-patient treatment.
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CMS' proposed rule includes:
• Establishing qualifications for CMHC employees and contractors.
• Requiring CMHCs to notify clients of their rights and to investigate and report violations of client rights. These proposed requirements also promote continuity of care by emphasizing the need for communication regarding client needs at the time of discharge or transfer.
• Convening of a treatment team, developing an active treatment plan, and coordinating services to ensure an interdisciplinary approach to individualized client care.
• Creating a Quality Assessment and Performance Improvement (QAPI) program. The QAPI program will require CMHCs to identify program needs by evaluating outcome and client satisfaction data and making changes, as necessary, to improve their quality of care.
• Setting organization, governance, administration of services, and partial hospitalization services requirements, with an emphasis on governance structure.
"We think that what CMS has done here is a good start," said Chuck Ingoglia, MSW, vice president, public policy, National Council for Community Behavioral Healthcare. "It's trying to make sure that organizations that are participating in this program are providing good services, that they're meeting the needs of clients, that they have processes in place to measure their performance, so we think all of those are steps in the right direction."
Ingoglia notes that the proposed rule doesn't address the need for updating the definition of what is a community mental health center. He said NCCBH hopes that the definition, which hasn't been looked at since 1980, continues to be addressed by Congress.
"Our field needs to be treated like the rest of medicine," he said. "With such an old definition, I don't think that's serving us well. What's important about the conditions of participation is that most other provider types in Medicare have conditions of participation. We think it's important that we play by the same rules and have the same opportunities as other types of providers."
CMS is accepting public comments on the proposed rule until Aug. 16. Those interested in commenting should go to www.regulations.gov and search for rule CMS-3202-P.