– by Jocelyn Bayliss, Program Lead, Provider Network Management & Tina Gallagher, Market Manager, Provider Network Management

In April 2023, CMS issued a final rule that added two new specialty types, clinical psychology and clinical social work, to network adequacy standards.

Addition of Specialty Types and Amendments to Access Standards

The notice advised that CMS was finalizing the January 2022 proposed rule to strengthen network adequacy requirements related to behavioral health services by:

  • Adding clinical psychology and licensed clinical social work as specialty types under § 422.116, and making new specialty types eligible for the 10-percentage point telehealth credit as allowed under § 422.116(d)(5)
  • Amending CMS general access to services standards in § 422.112 to explicitly include behavioral health services

Updated Health Service Delivery Tables

On October 18, 2023, CMS updated the Health Service Delivery tables to include network adequacy requirements for the two additional behavioral health services provider types(MA) (§§ 422.112 and 422.116).

Network Adequacy Requirements

Effective from January 1, 2024, Medicare Advantage (MA) organizations must demonstrate compliance with network adequacy for the following behavioral health specialty types:

  • Psychiatry
  • Clinical psychology
  • Clinical social work
  • Inpatient psychiatric facility service

Application Preparation

Plans preparing to submit MA initial or service area expansion applications for CY 2025 on February 14, 2024, must ensure they’ve met CMS network adequacy and access requirements for these additional service types and be prepared to implement the final rule. 

Looking Ahead

On November 6, 2023, CMS proposed regulatory changes to improve access to behavioral healthcare by adding certain behavioral health provider specialties to the MA network adequacy standards. These are anticipated to include outpatient behavioral health, which would be included in network adequacy evaluations and can include:

  • Marriage and family therapists
  • Mental health counselors
  • Opioid treatment program providers
  • Community mental health centers
  • Other behavioral health and addiction medicine specialists and facilities

Health plans and provider organizations should prepare their provider networks to meet proposed future requirements.

If you’re looking for expert assistance to ensure network compliance with the new requirements, or need help adding specialty types to your network, reach out to ATTAC Consulting Group. Our national team of provider network development experts is here to support you in achieving your goals and optimizing your network.