The financial reform that is part of healthcare reform law will not be fully implemented until 2014. Integrated behavioral health and primary care services are being provided now, however, and need to be billed. Organizations across the country are slowly but surely addressing these reimbursement issues.

Although Medicaid is unique in each state, the following four interim billing solutions can make your integrated health program financially viable right now.

Partner with an FQHC

FQHCs generally are reimbursed for behavioral health services on an encounter basis. An encounter can be 10 minutes or 2 hours - but the FQHC is reimbursed at the same rate. By contracting with an FQHC and providing services at its site, you can provide additional services to more people and the FQHC can bill at its encounter rates. This approach brings more reimbursable services to more people needing behavioral healthcare in your community.

Another partnership option is for the FQHC to initiate a "change of scope" to add the mental health site to the FQHC's network of sites. Including this site in the network will allow FQHC staff to come to the mental health site and get reimbursed for providing primary care services to mental health consumers. Usually a 90-day process, a change of scope makes providing primary care services in mental health sites a reality in communities across the country.

Become an FQHC

Over the next four years, the Bureau of Primary Health Care/Health Resources and Services Administration will be developing or expanding new access points across the country. In August 2010, the U.S. Department of Health and Human Services announced the availability of up to $250 million in grants for New Access Points for the delivery of primary health care services for underserved and vulnerable populations under the Health Center Program. The funds, made available by the Affordable Care Act, will be awarded by the Health Resources and Services Administration.

A new access point is a new full-time service delivery site that provides comprehensive primary and preventive health care services. New access points improve the health status and decrease health disparities of the medically underserved populations to be served.

Many Community Mental Health Centers in underserved areas have already been successful in adding FQHC status to their business portfolio. This option is recommended only if there is no existing FQHC in your community or if the community is underserved by an existing FQHC.

Get HBAI Codes Reimbursable in Your State

In summer 2010, a national mental health organization contacted each state's Medicaid office to inquire about the status of the 96000 series of HBAI codes. These important codes allow for behavioral health specialists to bill on the same day a person sees a physician for services ancillary to a primary care diagnosis.

Complete Comprehensive Billing Worksheets

Inaccurate billing information is widespread. For example, a common misconception is that two services in one day are not billable. However, a recently completed survey found that 28 states do allow such billing. It is important to take time to carefully review the Medicaid rules and regulations on integrated health codes in your state. Sample state-by-state integrated care billing worksheets for Medicare and Medicaid are being completed and several state billing grids have been finalized.