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Effective September 1, 2022, Non-LMHA Providers May Deliver Mental Health Targeted Case Management and Mental Health Rehabilitation Services

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Note: Texas Medicaid managed care organizations (MCOs) must provide all medically necessary, Medicaid-covered services to eligible clients. Administrative procedures such as prior authorization, precertification, referrals, and claims/encounter data filing may differ from traditional Medicaid (fee-for-service) and from MCO to MCO. Providers should contact the client's specific MCO for details.

Effective for dates of service on or after September 1, 2022, nonlocal mental health authorities (henceforth referred to as private providers) may deliver mental health targeted case management (MHTCM) and mental health rehabilitation (MHR) services to persons in traditional, fee-for-service (FFS) Medicaid prior to the persons’ enrollment with a managed care organization (MCO). 

Senate Bill (SB) 1921, 87th Legislature, Regular Session, 2021, directed the Texas Health and Human Services Commission (HHSC) to provide public or private providers of behavioral health services medical assistance reimbursement through an FFS delivery model prior to persons’ enrollment with and receipt of medical assistance services through an MCO. Except for MHTCM and MHR services, both public and private providers of behavioral health services may provide Medicaid services to persons enrolled in FFS Medicaid and managed care. Currently, private providers of MHTCM and MHR services may provide these services only to persons enrolled in managed care, whereas local mental health and behavioral health authorities (LMHAs/LBHAs) may provide these services to persons enrolled in FFS Medicaid and managed care. Therefore, as directed by SB 1921, the MHTCM and MHR state plan benefits have been updated to include a prior authorization process to allow private providers to deliver these services to persons enrolled in FFS Medicaid until the person is enrolled and begins receiving services though an MCO.

Note: MHTCM and MHR claims submitted by private providers for dual-eligible persons will be processed by the Texas Medicaid & Healthcare Partnership (TMHP) in the same manner that dual-eligible LMHA claims are processed to pay cost sharing. These claims will be carved out of managed care and will not be sent to the person’s MCO. MHTCM and MHR claims submitted by private providers for persons with Medicaid-only eligibility (all persons who are not dual-eligible) will be carved in for managed care, meaning that FFS will pay the claims until the person chooses an MCO, and then the claims will be forwarded to the person’s MCO for processing and reimbursement.

Initial Prior Authorization Requirements

Private providers must register to use the HHSC Clinical Management for Behavioral Health Services (CMBHS) clinical record-keeping system before providing services to Texas Medicaid-eligible persons.

Private providers of MHTCM and MHR services must not bill Texas Medicaid for services prior to the establishment of a diagnosis of mental illness and the authorization or reauthorization of services. Eligibility and continued eligibility determinations occur at the facility (provider) that is providing MHTCM or MHR services using the CMBHS software system. Criteria used to make these service determinations are from the recommended level of care (LOC) for the person generated by the CMBHS software system, as derived from the uniform assessment, the needs of the person, and the Texas Resilience and Recovery (TRR) Utilization Management Guidelines. Private providers of MHTCM and MHR services must ensure the following:

  • A qualified mental health professional-community services (QMHP-CS) or licensed practitioner of the healing arts (LPHA) performs a screening for eligibility using the uniform assessment.
  • An LPHA determines the diagnosis, which must include an interview with the person conducted either in person or by telemedicine or telehealth.
  • The clinical needs of the person are evaluated to determine whether the amount of MHTCM or MHR services associated with the recommended LOC, described in the TRR Utilization Management Guidelines, is sufficient to meet those needs.
  • An LPHA reviews the recommended LOC and verifies whether the services are medically necessary.

If the provider determines that the type of MHTCM or MHR services associated with the recommended LOC generated by the CMBHS software system is sufficient to meet the needs of the person, the provider must submit a request for prior authorization according to the recommended LOC. If the provider determines that an LOC other than the recommended LOC is more appropriate for the person, then the provider must submit a prior authorization “deviation” request that includes the following:

  • The word “deviation” with a note that the request is for prior authorization of an LOC that is higher or lower than initially recommended
  • The clinical justification for the request, including the specific reasons that the person requires interventions at a higher or lower level than the recommended LOC (refusal of the recommended LOC by the person receiving services may be noted as part of the justification)

For persons enrolled in managed care, private providers contracted with MCOs must submit prior authorization requests to the MCO with which the person is enrolled. MCOs must follow the requirements set forth in the Uniform Managed Care Manual regarding utilization management for MHTCM and MHR services. MCOs may choose to waive prior authorization submission requirements.

For persons enrolled in FFS Medicaid, private providers of MHTCM or MHR services must obtain prior authorization from the TMHP Prior Authorization Department using the Special Medical Prior Authorization request form and the information obtained from the CMBHS software system. When completing the Special Medical Prior Authorization request form for prior authorization, private providers must complete the following sections of the form as follows:

Section A: Client information: Complete as indicated on the form.

Section B: Requested procedure or service information

  • The type of request is “Other.”
  • The expected dates of service are the start and end dates provided by CMBHS.
  • The procedure-related Current Procedural Terminology (CPT) code is the code for MHTCM or codes for MHR services and the appropriate modifiers.
  • The comments text box must indicate whether the prior authorization request is an initial assessment or reassessment.

Section C: To be completed by the requesting physician or requesting provider

  • The diagnoses are the International Classification of Diseases, Tenth Revision (ICD-10) primary diagnosis and any related ICD-10 diagnosis codes.
  • The statement of medical necessity section must indicate the recommended LOC generated by the CMBHS software system. If the request is a deviation from the recommended LOC, then the provider must include the following:
  • The word “deviation” with a note that the request is for prior authorization of a LOC that is higher or lower than the recommended LOC
  • The clinical justification for the request, to include the specific reason or reasons that the person requires interventions outside the recommended LOC (refusal of the recommended LOC by the person receiving services may be noted as part of the justification)
  • If requested by the TMHP Prior Authorization Department, a copy of the Child and Adolescent Needs and Strengths (CANS) or Adult Needs and Strengths Assessment (ANSA) functional assessment.
  • Complete provider information as indicated on the form.
  • The Special Medical Prior Authorization request form must be signed and dated within 30 calendar days of the expected start date of services.

All plans of care are subject to retrospective review.

Reauthorization Requirements

At a minimum, providers must ensure that a QMHP-CS administers the uniform assessment and obtains a recommended LOC from the CHMBS software system for the person receiving the MHTCM or MHR services:

  • Every 90 calendar days for persons 20 years of age or younger.
  • Every 180 calendar days for persons 21 years of age or older.

Note: Providers must follow the same process that is used for initial authorization for reauthorization of services at the specified intervals indicated above (i.e., every 90 or 180 calendar days, as applicable.)

For more information, call the TMHP Contact Center at 800-925-9126.