GA-Wendy White Tiegreen

Document ID: CMS-2011-0080-0005
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: 80cdc75a
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This is comment on Proposed Rule

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

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Fee-for-Service-Behavioral Health: Medicare does not recognize the same type of credentialed practitioners that Medicaid state plans can recognize (in accordance with that state's law). This is particularly problemmatic for Addiction services and for Mental Health Professional Shortage Areas. In some rural jurisdictions, there may not be a psychiatrist or LCSW accessible and another state-certified practitioner may be the only option for managing a behavioral health issue. So in many cases, a Licensed Professional Counselor may provide a Medicare-covered benefit, but it will not be reimbursed by Medicare the licensed person providing the service is not a recognized Medicare practitioner. Additionally, the behavioral health field is rich with literature supporting individuals with "lived experience" who can be "certified" practitioners (with training and demonstration of the necessary skill set)-Medicare does not recognize these very necessary professionals.