GA-Wendy White Tiegreen

Document ID: CMS-2011-0080-0004
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: May 16 2011, at 12:00 AM Eastern Daylight Time
Date Posted: May 18 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: May 16 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 11 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80cdc756
View Document:

This is comment on Proposed Rule

Medicare and Medicaid Programs: Opportunities for Alignment under Medicaid and Medicare

View Comment

Fee-for-Services-Behavioral Health: Frequently HHS sets expectations (such as NCCI, etc) that are based upon "Medicare" logic. Medicare for instance utilizes CPT coding. States then may adopt elements of these HHS expectations as "Medicaid" requirements without specific consideration to sub-elements of the state plan for behavioral health (many of which use HCPCs coding instead of CPT coding). This creates administrative barriers for providers and ultimately then barriers in service access for persons in medical need.