September 15, 2010

New York State Office of Mental Health Clinic Reform Regional Implementation Briefing

On October 1, 2010, the New York State Office of Mental Health (OMH) moved forward with its implementation of mental health clinic restructuring and reform, although the State Plan Amendment (SPA) had not yet gained approval from the Centers for Medicaid and Medicare Services (CMS). In the interim, OMH has implemented a temporary billing arrangement for outpatient services provided by mental health clinics. After CMS approves the SPA, OMH plans to reprocess claims through the new system for services delivered after October 1, 2010. Many provider organizations have expressed concern about the transition, not only due to the interim nature of the billing arrangement, but also due to the likelihood of lower Medicaid revenues and uncertainty about their exposure to state and federal audits and the implementation of new federal overpayment disclosure rules that start in January 2010. Despite their concerns, many provider organizations are looking forward to a more equitable reimbursement structure and the ability to provide more than one service per day.