A fortnight ago, darkness began to engulf us because of early fall sunsets. We need to be very careful that the same thing does not happen in our professional lives.
Last year, CMS issued final regulations governing Accountable Care Organizations (ACOs) under Medicare. These final regulations recognize hospitals, primary care practices, federally qualified health centers (FQHCs), and rural health centers as qualified entities to form ACOs. They do not, however, recognize behavioral healthcare provider organizations as qualified entities. The Coalition for Whole Health objected strenuously to the exclusion of mental health and substance use care entities in its response to these intermediate final regulations; these comments were not heeded by CMS in the final regulations. Now, we need to be concerned how Medicaid will handle ACOs created to develop health homes.
This Medicare exclusion does not prohibit mental health and substance use care organizations from being included as part of an ACO. Yet, it does prevent them from forming ACOs to create health homes led by behavioral healthcare entities.
These restrictions create additional obstacles for the mental health and substance use care fields under the Affordable Care Act. However, they are not insurmountable. In military culture, soldiers frequently are placed in circumstances where they are “forced to lead from the rear”. This means that circumstances have arisen in which the nominal unit commander is not actually in charge, but rather the unit is being led by underlings who are more knowledgeable about current field conditions. Leading from the rear will be required as behavioral health entities confront the circumstances created by the new ACO regulations.
Several primary strategies are available to mental health and substance use care entities to lead ACOs from the rear. These include: