Bob Seifert, a Friedman consultant supporting OCAH, reviewed the recommended approach for classifying non‑claims behavioral health payments. The approach applies the OCA expanded framework and uses rules and proportional allocations to limit recognition of general practice transformation and other infrastructure payments to the share attributable to behavioral health, based on claims and capitation proportions. Category‑specific rules were described for population health and practice infrastructure payments, performance payments, shared savings arrangements, capitation, and other non‑claims payments; formulas for proportional allocation appear in the presentation appendix.

Seifert said 100% of explicit behavioral health capitation (behavioral health‑specific capitation) would be counted as behavioral health spend. For other capitation types (professional, global, or integrated system payments), the behavioral health portion would be estimated by allocating payments using encounter data, analogous to the method used for primary care allocations.

OCAH also presented the behavioral health‑in‑primary‑care module, a separate measure designed to capture spending that counts as both behavioral health and primary care (for example, behavioral health screenings and brief interventions delivered in a primary care setting). To avoid double counting and to keep primary care and behavioral health buckets mutually consistent, OCAH proposed expanding the list of primary care provider taxonomies to include some behavioral health professions when they deliver services using primary‑care service codes and at primary care places of service. OCAH recommended excluding applied behavior analysis (ABA) taxonomies and certain psychoanalyst taxonomies from the primary care list at present, while considering school counselor taxonomy for inclusion because schools are an identified place of service.

Participants asked for more detail about how taxonomy expansion would work in practice, emphasized the need to tie provider taxonomy to place of service and eligible CPT/HCPCS codes, and suggested reconvening with a technical subgroup or bringing this back for a deeper review. OCAH agreed to follow up with more specifics and to consider a targeted future discussion on taxonomy choices and the capitation allocation formulas.