CalAIM Behavioral Health Initiative Frequently Asked Questions
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Below is a list of frequently asked questions have been collected from technical assistance and informational webinars and submissions to the BHCalAIM@dhcs.ca.gov email. DHCS will update this list on a quarterly basis.
No Wrong Door for Mental Health Services and Co-Occurring Conditions
If under the No Wrong Door policy, a member can retain a pre-existing NSMHS Medi-Cal provider while also receiving SMHS from the MHP, is there a need to adhere to the provider vetting and contracting Continuity of Care (CoC) requirements per BHIN 18-059?
Reference BHIN 18-059 BHIN 22-011
No. The No Wrong Door policy allows members to receive non-Specialty Mental Health Services (NSMHS) (via a Fee-For-Service or Managed Care Plan [MCP] provider) and SMHS (via a Mental Health Plan [MHP] provider) concurrently when all of the services are clinically appropriate, the treatment is coordinated between the delivery systems and the services are not duplicative. CoC rules do not apply to No Wrong Door and there is no need to adhere to the provider vetting and contracting processes outlined in BHIN 18-059. CoC allows members with pre-existing MHP provider relationships who make a request to the MHP to continue receiving SMHS for up to 12 months with an out-of-network Medi-Cal provider or a terminated network provider who would continue delivering SMHS (i.e., an employee of the MHP or a contracted organizational provider, provider group, or individual practitioner).
How do the No Wrong Door and Criteria for Member Access to SMHS policies impact AB 1299 presumptive transfer (PT) requirements?
Reference ACL 18-027 BHIN 21-073 BHIN 22-011
The No Wrong Door policy (BHIN 22-011) and Criteria for Member Access to SMHS policy (BHIN 21-073) do not supersede existing PT requirements. Counties shall continue to follow PT policy guidance outlined in ACL 18-027.
Can a SMHS provider, while they are providing a SMHS to a member, address a co-occurring substance use concern within the SMHS provided to the member?
Reference BHIN 22-011
Yes. For example, during a therapy session, a Specialty Mental Health Services (SMHS) provider may discuss and treat a member's co-occurring substance use; however, the session must primarily address the member's mental health (e.g. symptoms, condition, diagnosis, and/or risk factors), which can include co-occurring substance use disorder. A claim for SMHS, submitted by a SMHS provider, will not be denied for including documentation, including a diagnosis, about a member's co-occurring substance use concern. Note: A provider must only provide services within their scope of practice, and about subject matter that is within their scope of competence.
Can a DMC/DMC-ODS provider, while they are providing SUD services to a member, address a co-occurring mental health concern within the service provided to the member?
Reference BHIN 22-011
Yes. For example, during a counseling session, a Drug Medi-Cal (DMC)/Drug Medi-Cal Organized Delivery System (DMC-ODS) provider may discuss a co-occurring mental health concern; however, the session must primarily address the member's substance use (e.g. symptoms, condition, diagnosis, and/or risk factors), which can include co-occurring mental health conditions. A claim for DMC/DMC-ODS services, submitted by a DMC/DMC-ODS provider, will not be denied for including documentation, including a diagnosis, about a member's co-occurring mental health concern. Note: A provider must only provide services within their scope of practice, and about subject matter that is within their scope of competence.
