CMS Issues Conditions of Participation for Community Mental Health Centers

By Lance O. Leider, J.D., The Health Law Firm

On October 28, 2013, the Centers for Medicare and Medicaid Services (CMS) announced a Final Rule establishing conditions of participation (CoPs) for Medicare-certified community mental health centers (CMHCs). The Final Rule is CMS 3202-F. These conditions are the health and safety regulations Medicare providers must meet in order to participate in the Medicare program and receive reimbursements. The stated purpose of the CoPs is to improve client care, establish requirements for staff and provider operations, and encourage clients to participate in their own treatment. According to CMS, many CMHCs are currently not required to meet any health and safety standards.

To read the Final Rule from the CMS, click here.

A CMHC is a provider that meets applicable licensure and certification requirements in the state in which it is located and […]

Department of Health and Human Services Announces Mental Health Parity Final Rule

By Lance O. Leider, J.D., The Health Law Firm

On November 8, 2013, the U.S. Department of Health and Human Services (HHS) Secretary Kathleen Sebelius announced the promulgation of the agency’s final rule related to parity of coverage of mental health and substance use treatment. According to Sebelius: “For way too long, the healthcare system has openly discriminated against Americans with behavioral health problems.”

The purpose of the regulations is to close the gaps in coverage that permit insurance carriers to treat mental and substance-abuse related treatment different from traditional medical and surgical benefits.

Among the key provisions of the regulations are the elimination of separate mental health deductibles, co-insurance, etc.; elimination of limits on lifetime benefits; as well as several other measures insuring that mental health benefits are treated on par with traditional medical and surgical benefits.

Compliance with the final rule will be required […]

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