CMS’ New Behavioral Health Model Illustrates Ongoing Effort To Push Value-Based Care, Integration Forward

The Innovation in Behavioral Health (IBH) Model propels the industry towards value-based care and further integration with the rest of the health care system.

The new model is an effort by the Centers for Medicare & Medicaid Services (CMS) to marshal public resources into a coordinated whole for those with severe behavioral health issues. Specifically, the model will connect adults with mental health conditions or substance use disorders (SUDs) to physical, behavioral and social supports, prioritizing a collaborative care model between behavioral health and physical health providers.

The model also goes in the opposite direction of most integration programs. Instead of integrating behavioral health in physical care settings, the IBH Model calls for physical health and social support to be integrated into behavioral health, an idea becoming increasingly common in the mainstream of health care.


The new program also conceptualizes the end game of integration efforts, according to experts in the field.

“CMS is really pushing for integration to try to be more than the sum of its parts,” Johanna Barraza-Cannon, director at ATI Advisory, said during a webinar. “The idea is to try to create an integrated stream of care for someone who has behavioral health needs to address [behavioral and physical health needs.] In addition to that, these integrated models are also thinking about the social support that is necessary.”

Those with moderate to serious addiction or mental health issues often face aggravating physical health issues. The two worsen each other, and when siloed as they are today, behavioral health and physical health care providers can’t address the totality of a patient’s needs.


Clinically, poorer health outcomes are apparent for people with serious mental illness. But Barraza-Cannon also highlighted operational complications that bifurcated behavioral health and physical health hands to patients, providers, payers and state agencies.

“If you think about having behavioral health needs and physical health needs and needing to visit two doctors’ offices and make two sets of appointments and not having those doctors talk to each other and not having a behavioral health doctor understand the physical chronic conditions and vice versa — it makes caring for a patient very difficult,” Barraza-Cannon said.

The IBH Model seeks to empower state-level officials to create health care hubs within behavioral health provider organizations that address behavioral health, physical health and social support needs. Announced Jan. 18, the to-be-enacted program seeks to fill this void in the health care system using behavioral health as the entry point rather than vice versa.

The reaction to the model has been generally positive.

“Integrating care for behavioral health with primary care is long overdue,” National Council for Mental Wellbeing President and CEO Chuck Ingoglia said in a news release. “The [IBH Model] is the culmination of nearly 20 years of National Council thought leadership and advocacy.”

Congresswoman Doris Matsui (D-Calif.) praised the new model. She has long been an advocate for providing federal funding for electronic health records (EHRs) in behavioral health.

In August 2023, she reintroduced a bill to provide funding for the meaningful use of EHRs by behavioral health providers that parallels the historic 2009 HITECH Act that facilitated the adoption of EHRs by hospitals and other segments of health care. Behavioral health providers were largely left out of that effort.

“The benefits are clear – connected, coordinated care leads to better health outcomes and better overall quality of care,” Matsui said in a statement. “Today’s announcement is a critical step in the right direction for behavioral health IT.”

Many questions remain about how this looks in practice. And in part, that’s on purpose, as this new model seeks to bring several aspects of health to bear all in one spot.

How will the IBH Model work?

The finer details of the IBH Model are presently unknown and may only be filled in once states start working on the model. CMS will release more information later this spring in a notice of funding opportunity (NOFO). The gaps are intentionally left open to allow states and the partners they will bring in the flexibility to adopt it locally.

Further, the model is a test, a point CMS and its officials made repeatedly in announcing the IBH Model.

“We will continue to test approaches that close the gaps between how behavioral and physical health are treated,” Andrea Palm, deputy secretary for the U.S. Department of Health and Human Services, said in a news release. “Our goal is always to improve the overall quality of care and outcomes for patients and this model brings us one step closer.”

In the fall, CMS will select eight states to participate in the program. It will run for eight years, five of which will encompass the implementation period. The three-year wind-up of pre-implementation features several moving parts.

State Medicaid agencies will have to select public or private behavioral health and physical health organizations to participate in the IBH model. Agencies will also have to establish a stable of social services and organizations to address likely social determinants of health issues.

The state will have to develop a program to help behavioral health providers build their technology infrastructure to facilitate the coordination of care and services with multiple organizations. States will fund organizations that only provide care to the Medicaid population. CMS will fund IT needs organizations that participate in Medicare.

The basic timeline CMS has laid out for the IBH model looks like this:

— State awardee pre-implementation period, Q4 2024 to Q3 2027

— Practice participant enrollment period, Q4 2024 to Q3 2025

— Practice participant pre-implementation period, Q4 2025 to Q3 2027

— Implementation period, Q4 2027 to Q3 2032

Eventually, behavioral health providers must screen, assess and coordinate behavioral and physical health needs through an interprofessional care team. CMS and states will also help fund the development of these teams.

In order to participate in the IBH Model, organizations must be enrolled in the state’s Medicaid program or meet Medicaid requirements. They must also have the means to provide outpatient mental and/or substance use disorder (SUD) treatment to those with moderate to severe conditions. This can include certified community behavioral health centers (CCBHCs) and opioid treatment programs (OTPs). Both are specific clinic types that are defined by state and federal laws.

In a separate fact sheet released with the IBH Model announcement, CMS highlighted the hope that the program would deepen value-based care innovation, alignment among payers and more Medicaid alternative payment models (APMs). 

“Through a predictable mix of investments and learning supports, [the IBH Model] will create a glide path for community-based BH practices to progress from fee-for-service (FFS) to value-based payments,” the fact sheet states.

Brian Fuller, managing director of value-based care design and delivery practice at ATI Advisory, said on the webinar that the IBH model fits into a growing portfolio of experiments led by the Center for Medicare and Medicaid Innovation (CMMI). The program is on-trend with CMMI’s issue-specific test models. These include the States Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model and the Transforming Maternal Health (TMaH) Model.

The model also intends to better triangulate the use of Medicare and Medicaid at the local level.

“Certainly, it’s an ongoing illustration of CMMI’s commitment to value-based care and its acceleration,” Fuller said. “It’s yet another model, another opportunity for the industry to engage directly in value-based care.”

Fuller and Barraza-Cannon hypothesized that adding programs like the IBH model may someday lead to the end of behavioral health as its own separate and distinct part of the health care ecosystem.

The model represents yet another powerful entity within health care, the federal government, realizing the importance of opening the silos that split up behavioral health and physical health, Barraza-Cannon said. She noted that it would not have been common practice for primary care providers to consider behavioral health issues 15 years ago seriously.

“It’s now hard to think about them separately, but we have to get our payment systems to think that way too,” Barraza-Cannon said, adding payment systems can be a barrier to integration.

Fuller noted that “changing incentives of reimbursement changes behaviors in health care,” adding that changing funding behaviors are required to facilitate those changes in a way similar to the IBH Model.

The model also accelerates the concept of bi-directional integration. In August 2023, the Substance Abuse and Mental Health Services Administration (SAMHSA) released its strategic priorities for the coming years. That plan included additional integration of physical health care into behavioral health. At that time, other experts noted that those with serious behavioral health conditions can have a “medical home” within behavioral health.

Other models, including the collaborative care model, already have strategies in place that call for many of the elements detailed in the IBH Model with the extension of reverse integration, with physical health integrating into behavioral health. But within that model, experts previously told BHB that these collaborations often struggle because they don’t easily remain top-of-mind for busy, potentially burned out providers.

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