Table 6.

Implications of Findings and Proposed Strategies/Solutions for Health Care Organizations

		Key findings	Strategies/possible solutions
Internal and external contextual factors	Buy-in from key stakeholders	Concerns regarding: • Leadership: Administrative burden and profitability of CoCM • Compliance: Proper coding and documentation for CoCM • Billing/IT: Technological infrastructure for time accrual and code entry • PCPs: Obtaining consent and discussing cost sharing with patients • Care managers: Time accrual processes, clinical documentation, and billing code entry	Engage key members of different stakeholder groups early in the process and address diverse concerns associated with implementation of billing
	Selection of the CoCM care team	A number of organizations reported preferentially hiring LICSWs for the behavioral health care manager role to allow for the flexibility to bill traditional FFS codes (e.g., psychotherapy) in addition to CoCM codes	A broad range of providers can serve in the behavioral health care manager role for Medicare CoCM billing; it is best to strategically select the appropriate provider type for your organization’s reimbursement environment
	Payer mix and CoCM reimbursement	Payer mix significantly influences: • The decision to bill CoCM codes to multiple payers or a single payer (Medicare) • The decision to bill only CoCM codes versus billing both CoCM and traditional FFS codes	For an unfavorable payer mix (e.g., few beneficiaries of payers reimbursing for CoCM), consider billing CoCM codes for eligible beneficiaries and traditional FFS codes for CoCM services provided to patients of non-reimbursing payers
CoCM components	Patient consent	There were notable challenges associated with developing a clear process for consent and obtaining PCP buy-in for this task. Additionally, there was concern that patients had a sub-optimal understanding of cost sharing or the general CoCM service after initial consent	Possible solutions include: • Develop scripts and a clear workflow for the consent process • Create EHR documentation templates to ensure that consent is properly documented each time • Train staff on relevant CoCM billing processes and technologies
	Time accrual mechanisms	Jointly accruing time spent by multiple team members over the course of a calendar month poses significant challenges	Use an adapted spreadsheet specifically for time accrual that is accessible by all CoCM team members, while concurrently exploring options for EHR-registry integration or interoperability
	Electronic health record (EHR) and registry integration or interoperability	Integration or interoperability of the registry and EHR may save time with documentation or time accrual but can be costly and complex to develop. Although this was considered helpful by study participants, it was not necessary for billing success	Stand-alone registries can be used successfully to support CoCM billing
	Billing/revenue workflow	Billing once monthly for cumulative patient care time is a major shift in billing workflow that requires careful coordination among multiple clinical and non-clinical staff members. Also, challenges arise because the service is provided jointly by primary care and behavioral health	Possible solutions include: • A virtual EHR clinic accessible to behavioral health and primary care • Regular ledger transfers between departments • Primary care directly hiring behavioral health team members
Financial sustainability		Organizations noted the importance of demonstrating financial sustainability with the CoCM codes, particularly in areas with unfavorable payer mixes for CoCM	Consider continuously evaluating financial sustainability as the number of regional payers reimbursing for the CoCM codes increases