Most states have separate rules governing Medicaid-reimbursed medical care and behavioral health care services, including rules that cover provider qualifications, program sites, record-keeping, and payment mechanisms. While many providers are making major investments in new electronic health record systems, these systems generally do not offer the capacity to fully integrate information about a clients health, mental health, and substance abuse conditions and services. In part this is because each public agency requires providers to use its own system for electronic billing and documentation of services to obtain Medicaid reimbursement. This is particularly true if mental health services are administered through a carve-out arrangement. There is often little or no guidance available for partnerships that integrate the delivery of Medicaid-covered primary care and behavioral health services for the same people, in the same location.
The partnership arrangements described here are generally strong, but some FQHCs would like to obtain Medicaid reimbursement for integrated care, including mental health services, provided by their own staff. While in some communities a single organization operates as both an FQHC and a provider of Medicaid-reimbursed mental health services, FQHC providers in some other communities do not understand how to put in place the complex systems needed for the same provider organization to be reimbursed for some services through the FQHC mechanism and other services through programs that receive Medicaid reimbursement for services that are covered as MRO benefits.