Back to Blog List

APA Comments on Proposed CMS Payment Policies for Collaborative Care


Recently, the APA sent a letter to the Centers for Medicare and Medicaid Services (CMS) offering comments on the Medicare Physician Fee Schedule proposed rule for 2017, a rule that for the first time offers physicians payment for working on collaborative care.

In the letter, APA strongly commends CMS for proposing coverage beginning in 2017 for a specific integrated care model — the Collaborative Care Model (CCM). CMS is proposing a host of codes aimed at ensuring payment for coordination of behavioral health care in primary care setting with a psychiatrist as an integral part of that treatment team.

Read APA's Comments

Providing payment for evidence–based collaborative care services is a significant advancement in health policy. The CCM has been shown in more than 80 randomized controlled studies to improve the quality and efficacy of care while also reducing overall health care costs.

While we were pleased to see CMS recognize the vast potential of the Collaborative Care Model, and the importance of compensating doctors who work within it, APA felt compelled to offer several comments and recommendations on the proposed rules.

APA recommended an increase in the proposed payment amount, so that the work of the psychiatric consultant is valued no less than that of the primary care physician. If the rule is implemented as proposed, the payments may not be sufficient to sustain the model and could discourage physicians from participating.

APA also supported the adoption of a new code for general behavioral health care management, which would cover supplementary services psychiatrists provide in the course of treatment for which they currently receive no compensation. Adoption of a new code for additional services would reflect the considerable time, resources and effort that go into caring for patients with behavioral health conditions. However, it is unclear they type of practitioners, services, and circumstances that would be eligible under this new code. We have requested further clarification from CMS is needed before a new code is adopted.

Finally, CMS has proposed coverage for other services of interest to psychiatry, including payment for time spent by psychiatric consultants on services like telepsychiatry following traditional evaluation and management (E/M) visits. Compensating psychiatrists for these services would acknowledge the considerable medical decision-making that goes along with the role of psychiatric consultants in the collaborative care model.

As part of a broader effort to reform the health care system in this country, these proposed rule changes represent a significant step forward, particularly where psychiatry and primary care intersect.

The Collaborative Care Model is one way forward for health care systems to think of new innovative ways to provide improved access to mental health care in this country, and the adoption of the model will have a huge impact on the way that psychiatric services are delivered. APA continues to train psychiatrists in this model with over 700 trained in less than a year. Learn more about collaborative care training opportunities.

We offered these suggestions to CMS because psychiatrists have to be an active and vocal part of the process for adopting these new rules. We will keep you updated as the proposed rules come closer to being finalized, and will continue to work hard to make sure that the rules that are adopted serve the best interests of our patients and our profession.

What APA is Doing for You

This blog post is part of an occasional series highlighting how APA advocates on your behalf to support the profession of psychiatry and put our interests before key policymakers.


Post by Saul Levin M.D., M.P.A.

Saul Levin, M.D., M.P.A., FRCP-E, is APA's CEO and Medical Director. Read Dr. Levin's full biography

Follow Dr. Levin on Twitter

What APA is Doing for You


Comments (0) Add a Comment


Add a comment

Enter the text shown in this image:*(Input is case sensitive)
* - Only comments approved by post author will be displayed here.