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Consolidated Appropriations Act of 2023 Changes Impacting Rural Health Clinics

The Consolidated Appropriations Act of 2023, also known as the “Omnibus” package, was signed into law by President Biden on December 29, 2022. Rural Health Clinics (RHCs) need to be aware of some of the changes that will impact them including new grant opportunities and behavioral health provisions.

Opportunities for Rural Health Clinics from the Consolidated Appropriations Act of 2023

Included in the Omnibus package, here are the highlights that Rural Health Clinics need to know:

  • Effective January 1, 2024, Medicare will cover two additional provider types: Marriage and Family Therapists (MFT) and Mental Health Counselors.
    • These providers type will now be considered reimbursable in the RHC setting, and their services will generate an all-inclusive rate payment.
  • Also, effective January 1, 2024, RHCs will be recognized as an eligible provider of the newly created “intensive outpatient services” treatment category.
    • These treatment programs will bridge the gap between patients who only need typical office visits to manage their condition and those who need more intensive, in-patient services. This treatment category will provide a middle ground for patients in need of such services. Details are still forthcoming regarding this special payment category.
  • The proposed 4% “PAYGO” Medicare payment reduction originally set to take effect January 1, 2023, was delayed for another two years. The 2% sequestration reduction from Medicare is still in effect.
  • RHC Telehealth flexibilities allowed during the PHE have now been extended through December 31, 2024. This includes use of the G2025 code used to bill for RHC distant site telehealth services, as well as the in-person visit requirement for mental health telehealth services.
  • $5 million of funding was included to establish an Office of Rural Health at the Centers for Disease Control and Prevention (CDC).

Grant Opportunities for Rural Health Clinics

In addition to these provisions, a handful of grant opportunities for RHCs will be made available during the 2023 fiscal year:

Up to $2 million per grantee will be available to “improve and uptake and patient access to integrated care services”.

  • This grant is intended to promote the integration of physical and behavioral care by assisting clinics in setting up the psychiatric collaborative care model (CoCM). RHCs are able to bill for these service under G0512, however certain health care providers and staffing are required in order to meet the program requirement for this services.
  • Grant funds would be able to be used to hire necessary staff, or contract with vendors who provide care management services, or to purchase necessary software upgrades in order to provide behavioral health integration. This grant opportunity was funded at $60 million over the next five years.

The second grant opportunity would provide continuing medical education funding for providers working in RHCs.

  • This opportunity expands eligibility of an older grant program, and a total of $5 million is available over three years. There is currently no specified maximum reward per grantee.

Behavioral Health Provisions Impacting Rural Health Clinics

A number of the provisions in the 2023 Omnibus package are behavioral health related. This poses a potentially larger issue for RHCs who currently are limited in the amount of behavioral health they are able to provide.

RHCs are statutorily prohibited from being primarily engaged in providing mental health services, and there is a glaring grey area when it comes to how primary care versus mental health should be defined. These issues, though they have always existed, are being forced back into the spotlight as CMS expanded mental health providers who are covered in the RHC, and as states expand payment for mental health services on the Medicaid side.

Contact Us

If your RHC has questions about implementing behavioral health into your existing practice, or if you are considering opening a new RHC that integrates primary care and behavioral health services, please reach out to Blue & Co.’s RHC expert or your local Blue & Co. Advisor.

Amanda Dennison, CPC, MBA, CRHCP, Manager
adennison@blueandco.com
502-992-3518

Todd Schiavone, Director
tschiavone@blueandco.com
502-992-3506

Austin Fisher, CPA, Senior Manager
afisher@blueandco.com
317-275-7438

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