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CMS Innovation Designed to Transform Behavioral Health

A New Approach to Behavioral Health by Integrating Care and Advancing Health Equity


March 6, 2024 – The Centers for Medicare & Medicaid Services (CMS) recently unveiled the Innovation in Behavioral Health (IBH) Model. This initiative seeks to bridge the gap between physical and behavioral health care by ensuring a holistic approach to care for Medicare and Medicaid populations. By integrating physical, behavioral, and social supports, the IBH Model also aims to foster a more comprehensive, patient-centered healthcare system.

In this blog, we explore the details of the IBH Model, examining its potential to revolutionize the way individuals with mental health conditions and/or substance use disorders receive care. While this is being presented as an innovation, it is intuitive but requires removing significant barriers. As advocates, we are excited to see the advancement of integrated care into the behavioral health space, as well as the utilization of value-based payments to incentivize participants to address health-related social needs and focus on delivering high-quality, coordinated care. But, advocates are also concerned that the carve out of BH services appear to be working well in some states. You can check out our full advocate’s perspective at the end of the blog to learn more on our thoughts of how this initiative will impact consumers and quality of care!

The Link Between Behavioral and Physical Health

The interconnection between behavioral and physical health is a critical aspect of whole-person healthcare. Unfortunately, in traditional care models, payers are siloed which limits the coordination and integration of care. Individuals grappling with mental health conditions or substance use disorders (SUDs) frequently face challenges in accessing the integrated care necessary for managing their health effectively. The issue with this is that there is a strong link between physical and behavioral health

Individuals with mental health or substance use disorders are at a higher risk of developing chronic physical conditions. On the other hand, people with chronic physical ailments often experience behavioral health issues. We’ve covered this in more detail in past blogs, but it is important to realize that both physical and behavioral health play a large role in overall health outcomes. 

It is especially important to address these issues for the Medicare and Medicaid populations as this population experiences disproportionately high rates of mental health conditions and/or substance use disorders (SUD). The IBH Model introduced by CMS represents a pivotal shift towards acknowledging and addressing this gap and aims to dismantle the silos that have historically separated these domains of care.

The Innovation in Behavioral Health (IBH) Model: A Deep Dive

While the finite details of the Innovation in Behavioral Health (IBH) Model are still unknown, it is designed to bring the integration of behavioral health into broader healthcare services. CMS intends the model to address the complex needs of individuals with mental health conditions and/or substance use disorders, and to create a more person-centered, integrated care experience for this population. 

At the heart of the IBH Model are four key program pillars: care integration, care management, health equity, and health information technology. One of the central features is utilization of community-based behavioral health practices as the hub for integrated care. These clinics work as part of a care management team and are tasked with providing a broad range of services, including crisis mental health services, substance use treatment, primary care screening and monitoring, and peer support. In addition, they also coordinate with other providers to serve all the needs of the beneficiaries. 

A pivotal goal of the IBH Model is to enhance access to behavioral health services and improve care coordination. What is unique about this model is that it puts community behavioral health providers at the forefront of care integration and coordination. Studies have shown community centered behavioral health centers (CCBH) have been successful. However, in other models, this responsibility typically falls on primary care providers, but the IBH model puts BH providers in charge of screening individuals and linking them with other healthcare providers. This integrated approach will help reduce barriers to accessing behavioral health services and ensure that individuals receive timely and appropriate care. Another unique aspect of the IBH Model is that traditionally, the CMS-backed Community Centered Behavioral Health Clinics integrate care into a single location. This new model takes a different approach where services can be delivered at different locations. It will require enhanced coordination, which is why there is also funds included to improve Health IT infrastructure capacity, such as electronic health records (EHRs), interoperability standards, and telehealth. 

The IBH Model is expected to run for eight years and includes a pre-implementation period that will run from years one through three. CMS intends to select up to eight states to participate in cooperative agreements amongst those that apply to the Notice of a Funding Opportunity. From the states selected, practice participants must be community based BH organizations that meet the following criteria: 

  • Licensed by the state to deliver BH services (either mental health and/or SUD).
  • Meet any state-specific Medicaid provider enrollment requirements and be eligible for
  • Medicaid reimbursement.
  • Provide mental health and/or SUD services at the outpatient level of care to adult Medicaid beneficiaries (age 18 or older) with moderate to severe BH conditions.

More information on the specifics of the IBH Model will be released in spring 2024 with a notice of funding opportunity (NOFO), but there is flexibility baked into the model to ensure states can model their individual programs in the best way to suit their local populations.

Value-Based Care, Health Equity, and Social Determinants in the IBH Model

The Innovation in Behavioral Health (IBH) Model is as example of value-based care. It is designed to enhance health equity, address social determinants of health, and streamline care coordination. This approach highlights the importance of delivering high-quality, integrated care and shifts community-based behavioral health practices from fee-for-service (FFS) to value-based payments. 

A distinguishing aspect of the IBH Model is its innovative approach to payment and service delivery by placing a much higher focus on value-based payments. It does this by incentivizing providers to focus on the quality and outcomes of the care they deliver rather than the volume of services provided. IBH will create a path for community-based BH practices to progress from fee-for-service (FFS) to value-based payments. It also achieves Multi-Payer Alignment. States will be responsible for designing and implementing a Medicaid Alternative Payment Model (APM) for their unique state context that will get Medicaid and Medicare to align on key model design elements, such as payment model and quality measures. This shift encourages personalized care plans and innovative treatment methods that are more likely to yield positive health outcomes. By aligning financial incentives with patient health outcomes, the IBH Model promotes a healthcare system that prioritizes patient well-being and efficient use of resources.

The IBH Model also makes a commitment to advancing health equity. It recognizes the disparities that exist within behavioral health services and seeks to eliminate these through targeted interventions. Behavioral health providers will conduct screenings for health-related social needs (also known as social determinants of health) and refer individuals to appropriate community-based services. Practices will also need to develop health equity plans (HEP) that stipulate how they will address disparities that impact their service populations. By connecting patients with community resources and support services, the model acknowledges that addressing these social determinants is essential for achieving optimal health and well-being.

Advocates Perspective

The Innovation in Behavioral Health (IBH) Model embraces the principles of value-based care and health equity. By integrating behavioral health with physical health services and addressing the social determinants that impact health outcomes at the behavioral health provider level, the IBH Model offers a comprehensive approach to care that is both innovative and patient centered. As this model unfolds, it has the potential to transform the behavioral health landscape, making services more accessible and effective for all individuals, especially those who have historically been underserved. As we move forward, the lessons learned from the implementation of the IBH Model will undoubtedly provide valuable insights into the future of integrated and value-based healthcare delivery. However, we will need to closely monitor how this compares to the states where behavioral health services are carved out to determine how truly effective the IBH Model is.


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About the Author

Fady Sahhar brings over 30 years of senior management experience working with major multinational companies including Sara Lee, Mobil Oil, Tenneco Packaging, Pactiv, Progressive Insurance, Transitions Optical, PPG Industries and Essilor (France).

His corporate responsibilities included new product development, strategic planning, marketing management, and global sales. He has developed a number of global communications networks, launched products in over 45 countries, and managed a number of branded patented products.

mandy sahhar

About the Co-Author

Mandy Sahhar provides experience in digital marketing, event management, and business development. Her background has allowed her to get in on the ground floor of marketing efforts including website design, content marketing, and trade show planning. Through her modern approach, she focuses on bringing businesses into the new digital age of marketing through unique approaches and focused content creation. With a passion for communications, she can bring a fresh perspective to an ever-changing industry. Mandy has an MBA with a marketing concentration from Canisius College.