Board delays benchmark but finalizes measurement approach for behavioral health spending

The Office of Health Care Affordability presented a detailed methodology to the board for measuring behavioral health spending that combines claims‑based identification with rules for non‑claims payments and allocated capitation amounts. The office said it will not set a behavioral health spending benchmark this year; the board agreed to postpone adoption until 2026 to allow a full year of data collection and additional analysis. In the meantime, payers will report behavioral health data for 2024–2025 in 2026, and staff will publish a full data submission guide incorporating the definitions this fall. Why this matters: the statute requires the office to both measure behavioral health spending and later set a benchmark to encourage sustained capacity and improved access. Board members and public commenters emphasized the need for definitions that capture integrated care delivered in primary care settings and for methods that avoid incentives to carve out behavioral health services. Staff described a rules‑based claims approach that: counts claims with a primary behavioral‑health diagnosis as behavioral health spending; includes screening and assessment codes even when the diagnosis is not primary; classifies services by place of service, revenue and procedure codes for reporting subcategories; and uses a national drug code (NDC) list to identify pharmacy claims for mental‑health or substance‑use disorder spending. For non‑claims payments, staff proposed classifying population‑health and practice‑infrastructure payments as behavioral health only when paid to behavioral‑health providers and allocating portions of practice transformation, IT and other broad payments to behavioral health using the ratio of behavioral health claims and capitation to total claims and capitation. Staff proposed simplifying reporting subcategories — folding low‑volume categories such as “mobile clinic services” and “long‑term care” into broader outpatient categories — to reduce reporting burden and relying on the state’s Health Care Payments Data program for more granular monitoring. Several board members raised concerns that a diagnosis‑based rule can undercount behavioral health delivered in primary care and urged robust behavioral‑health‑in‑primary‑care modules and incentives for plans to recognize integrated services. Board member Elizabeth Mitchell and other commenters emphasized that measurement rules should not discourage primary care providers from treating behavioral health needs. Public commenters from county behavioral‑health leaders and advocacy groups warned staff not to allow the measurement approach to be used to divest specialty public behavioral‑health capacity. The county directors’ association urged clarification that shifting investment toward primary care should not reduce funding for the public safety‑net behavioral‑health system. Next steps: staff said it will publish the proposed definition and methodology for a 30‑day public comment period beginning August 1, present advisory committee feedback in September and adopt the final submission guide this fall so payers can report in 2026 for 2024–25 years.