At a public meeting of the Office of Healthcare Affordability’s (OCA) Investment and Payment Work Group, staff outlined a proposed behavioral health and primary care module intended to measure behavioral health services delivered in primary care settings and to support future investment decisions. OCA said the module requires a claim to meet four tests to be counted as behavioral health in primary care: a primary behavioral health diagnosis (except for screening/assessment claims), a provider with a primary care taxonomy, a primary care place of service, and a service code in an outpatient professional primary care subcategory.

The measurement design and a proposed expansion of the “primary care” provider taxonomy to include some behavioral health professionals prompted sustained concern. Debbie Lindes, OCA’s health care delivery system group manager, described the four-test approach and said the taxonomy expansion aims to capture behavioral health professionals who commonly work in integrated primary care settings. Lindes also noted the module will include some non-claim payments, such as payments for primary care–behavioral health integration and a portion of capitation payments allocated by encounter-based formulas.

Several work group members said the taxonomy expansion risks counting typical outpatient behavioral health visits that are not part of integrated primary care teams. Kevin (work group member) challenged the approach with a concrete example: a 30‑minute psychotherapy session billed from an office by a psychologist could be included under the proposed rules because an “office” place-of-service code lacks the granularity to distinguish a primary care clinic from a private behavioral health practice. “Now I’m really worried,” Kevin said, arguing that expanding the taxonomy to include licensed clinical social workers and clinical psychologists could inflate the primary care subset and undermine a tight measure of primary care spending.

OCA staff acknowledged the limitation of the place-of-service codes and explained a partial mitigation: the coding rules limit inclusion to shorter sessions (e.g., 30‑minute visits) that are more common in primary‑care–integrated behavioral health models. Staff also noted that claims with collaborative care management CPT codes—unique codes for team‑based integrated models—are already captured and are less ambiguous.

Other work group participants suggested analytic safeguards rather than immediate taxonomy expansion. Mary Jo (work group member) suggested the module could be reported both ways — with and without the expanded taxonomy — so stakeholders could compare results. Dr. Soni (work group member) said she preferred erring on the side of exclusion: “I would choose option 1. Exclude folks who might be integrated,” because starting from a known inflated measure makes it harder to assess true integration progress.

OCA said no final decision has been made. Staff emphasized that the methodological questions will be considered during the public comment period on OCA’s proposed definition and measurement methodology and in supplemental HPD analyses planned for the fall and winter. The work group will revisit the module design in upcoming meetings and may revise the taxonomy approach based on empirical analyses and public input.

The discussion preserved a clear distinction among three categories of activity: (1) discussion of methodological options and risks; (2) staff directions to perform supplemental analyses and present alternative views (for example, showing results with and without the expanded taxonomy); and (3) no formal action or vote to change the definition at this meeting.

What remains unresolved is how to reliably distinguish integrated behavioral health visits from standalone outpatient visits using existing claims fields. OCA staff said coding limitations — especially the non‑granular “office” place-of-service code — are the main constraint, and recommended further empirical testing with HPD (the Healthcare Payments Data Program) to estimate how much misclassification would occur under different taxonomy choices.

Work group members asked that OCA present comparative outputs (with/without expanded taxonomy) and share empirical audits or spot-checks before any permanent change to the primary care definition is adopted.