19 January, 2023 14:20

Integrated Care Services

The first grant opportunity, designed to “improve uptake and patient access to integrated care services” would provide up to $2 million per grantee to promote the integration of physical and behavioral health care, a concept that the legislative text defines as “bidirectional integrated care.” Specifically, the funding is designed to help practices set up the psychiatric collaborative care model which many RHCs will recognize as the G0512 special payment code. For folks who may have been hesitant to try this particular care management code in the past, this grant may provide the impetus you need to begin offering this service.

Grantees would be able to use the money to hire staff and/or contract with health care providers or other entities offering care management and behavioral health consultation. The legislation also mentions that funding can be used to purchase or upgrade software needed to provide behavioral health integration.

As most of you are aware, there is an extra wrinkle to consider for RHCs when integrating behavioral health care with physical health care. Specifically, RHCs are currently statutorily prohibited from being primarily engaged in “the treatment of mental disease.” Furthermore, CMS has not provided clear ways to measure physical care relative to behavioral health care and some RHCs have run into issues on their survey because they were providing too much
behavioral health care.

Considering the clear policy intent of Congress to integrate behavioral health with primary and specialty physical care, and the blurring of lines between behavioral health care and physical health care, NARHC is working to change this law. The “RHC Burden Reduction Act” which we hope to have introduced in the next few months, would amend the statute to allow an RHC to provide a majority of behavioral health care if the RHC is located in a mental health-HPSA. Getting this language passed should make it much easier for RHCs to provide “bidirectional integrated care” without fear of jeopardizing their RHC status.

This opportunity was funded at $60 million for the next five years.

Continuing Education Support

The second grant opportunity expands eligibility of an older grant program to pay for the continuing medical education of health care providers that work at RHCs. The legislation does not specify a maximum amount per grantee, but it does appropriate $5 million over three years to fund this opportunity.

Grantees should be able to use this funding to pay for “distance learning, continuing educational activities, collaborative conferences, and telelearning activities.” The text makes it clear that this funding can be used to pay for “educational activities that include a clinical training component, including in-person patient care.”

Rural Health Clinic Behavioral Health Initiative

The Consolidated Appropriations Act of 2023 unfortunately did not fund the RHC-specific Behavioral Health Initiative. Despite being proposed by the Biden Administration in their 2023 budget and being funded in both the House and Senate’s draft appropriations bills, the Rural Health Clinic Behavioral Health Initiative was not funded in the final legislation.

While we are grateful to be eligible entities for these other grant programs, we are fearful that a larger-than-equitable share of the awards may go to entities and facility types that have more experience writing grant proposals and managing grant funds. Furthermore, because the RHC program has so many distinctive features relative to our fee-for-service and FQHC peers, from survey and certification to cost reporting to billing and coding, an RHC-specific grant might allow us to better target some of the unique challenges that we confront.

NARHC is hopeful that the Biden Administration will propose this RHC-specific grant funding again in 2024, and we will continue to work with Congress to create a grant that can specifically target the RHC program.

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On the whole, we are excited to see these new funding opportunities be made available to RHCs. We have a general view that federal resources made available to safety-net providers must equitably include RHCs and we believe that particularly since COVID, Congress is doing better job of incorporating RHCs into their policymaking.

NARHC will be sure to monitor announcements from HRSA and HHS regarding these funding opportunities, and as soon as we have more details we will post them to our “Announcements and Opportunities” forum.

Nathan Baugh
Executive Director
National Association of Rural Health Clinics