Hybrid behavioral health providers could be in a prime spot to help weather regulatory changes and enter the value-based care space.
And having a brick-and-mortar presence could be a lifesaver for providers as the The U.S. Drug Enforcement Administration (DEA)’s stance on telehealth prescribing continues to fluctuate. Still, providers could face significant operational challenges regardless of their footprint. One provider looking at this challenge is Mindpath.
Mindpath Health, which was formed in 2021 through the merger of outpatient mental health companies Mindpath Care Centers and Community Psychiatry, and is one of the largest providers in the country. The operator is backed by Los Angeles PE firm Leonard Green & Partners.
BHB sat down with Dr. Diego Garza, senior vice president of strategy for Mindpath Health, to chat about regulations, value-based care and the future of telehealth.
This article has been edited for length and clarity.
BHB: Would you like to introduce yourself a little bit further?
Garza: Mindpath Health is one of the largest outpatient mental health organizations in the nation. We specialize in psychiatry and psychotherapy. We also do interventional psychiatry. We have a presence in six different states. Our whole model is anchored on a patient-centered approach to increase the quality of mental health services.
I know you’re passionate about many behavioral health-related things. I’m excited to dig in. Let’s start with some recent news we’ve covered at BHB. The DEA recently proposed a special registration framework and announced a final rule that gives providers six months to treat patients via telehealth. This framework has been paused for review by the new administration, but it could very possibly go through. What was your initial reaction to the announcement?
Garza: I think overall, mixed feelings, mixed reaction. Everybody’s mind and thought process is trying to analyze what the rule actually intends for us to do. But overall, the initial reaction is that what the DEA proposed, especially with respect to the framework, is unnecessarily complex. It will likely create more barriers to access care for an already very vulnerable patient population.
I’ve heard that from other folks as well in my coverage. If it does go through, how would it impact Mindpath?
Garza: This is going to be operationally complex to enact, but there are a few things that we are worried about, mostly. To list some of the key concerns that we have, for example, the 50% cap on telehealth for prescribing schedule 2 substances. The main question that we have here is, how are the health outcomes of the population going to change with this versus what’s happening right now?
Other concerns that we have are related to the state-based restrictions. We believe that with how much the practice of telemedicine has evolved, we do not necessarily believe that restricting access this way is in the patient’s best interests.
Another piece is a mandatory 50-state restriction drug monitoring program check, which, without a national system in place, would likely not be doable or operational in the short term.
And the rule mentions that it’s a requirement, but it doesn’t give us a pathway for completion. I do believe, in terms of Mindpath itself, some hybrid companies, such as ours, are going to be better set up to comply with the regulations. However, it will still be very operationally complex, and it will be more complicated to engage patients who otherwise would have been reached through the telemedicine flexibilities we observed during the pandemic, which remain in place to this day.
I think that if the rule is finalized the way it’s drafted, it will significantly handicap patients who are already engaged in meaningful treatment. It’s going to limit access to mental health care for patients of all ages and all socioeconomic classes who rely on telemedicine to receive that treatment. Don’t get me wrong, I think we do understand why there is a need for more strict regulation around telemedicine practice, but we have to keep in mind that whatever we do, or whatever the VA ends up doing, is going to impact actual patients’ lives.
And when you say that some providers are better set up to comply with the regulations than others, who are you talking about there? Who’s going to potentially struggle to comply?
Garza: All of us are going to struggle to enact this rule. Practices that have already enacted a model where there are in-person, services are going to be better positioned to comply with this rule versus the practices are fully telemedicine only, and that don’t have a physical location for the patients to get that part of the rule when a patient can come and kind of check the box on that part of their rule.
I know you sat in on a DEA session in the past. What was that experience like?
Garza: It was a very interesting experience. We’re very appreciative that the DEA took time to invite us to join them in their thought process. That’s something we haven’t necessarily seen in the past, and it feels like it’s a step in the right direction. So the session itself was very productive. We saw a lot of mental health providers and experts talking about the benefits or or the downfalls of this rule, of the proposed rule. So it was a very interesting couple of days where we got to hear why or why not these rules should be enacted.
We’ll all be looking really closely to see what the future of that framework is. Let’s turn to reimbursement structures and one of the most talked about theoretical parts of mental health care, behavioral health care in the industry; we often talk about value-based care. BHB has a whole event talking about value-based care, but providers largely still operate on a fee-for-service basis. This is something we talk about a lot, but what’s the current status of value-based care from where you sit?
Garza: Great question. It’s something that’s very close to me and my daily work; I’ve been helping with the effort around value-based care for Mindpath for several years now. We have seen an increase and decrease [in interest in value-based care], and kind of it comes in and out of conversation, right? So we talked about it and tried some things, but the reality is [behavioral health] still exists in a largely fee-for-service model.
The question here is, how do we begin that transition? If that solution is going to happen, how do we do it right? And from our perspective, I think it’s about time that all of us mental health providers start measuring the appropriate outcomes approach payers with a set of metrics that you think define value or quality in the space, and then match those against what they think defines value and quality in the space, and truly reach an agreement that where we put the patient’s best interests at heart and move from there.
I think we’re in an era now where we all should be leveraging data analytics. We have to understand our patient population, what drives quality, what drives cost, and how do we work on creating a compelling case that can enable a true partnership with payers?
I think the ideal partner that we’re all looking for is a partner that’s willing to invest in the processes, willing to invest in the data set, willing to spend time analyzing data and having conclusions on what’s best for the patient population in question and grant them organ that’s going to look different per patient population. It might look different for my patient population in terms of general psychiatric psychotherapy when you compare against a specialized clinic on eating disorders or substance use disorders.
But still have to work towards standardization in a way that allows us to compare and truly drive meaningful change in the behavioral health arena.