Advocacy to Revise Comprehensive Treatment Plan Requirements

The National Council for Mental Wellbeing Medical Director Institute has released a position statement on documentation requirements for comprehensive treatment plans, joining the American Association for Community Psychiatry (AACP) and the American College of Physicians (ACP) in calling for a review and revision of the treatment plan documentation requirements across the nation – to promote better access to care, improved patient care experience, better quality care, and compliance with mental health parity requirements.

Regulators and payers for behavioral health treatment services, particularly for serious mental illness and substance use disorders in Medicaid, commonly require treatment plans that are substantially more detailed and lengthier than those used in other areas of health care delivery as a precondition of receiving treatment services. These overly detailed and complicated requirements have remained relatively unchanged from when they were written over 50 years ago and have been driven by the Centers for Medicare and Medicaid Services’ (CMS) Conditions of Participation (CoP) for psychiatric hospitals and community mental health centers.

Advocates point out six (6) key issues with the Current Treatment Plan Documentation Requirements that negatively impact care, which include:

1. Parity violation for access & payment – Advocates argue that comprehensive treatment plans for behavioral health treatment that are substantially more detailed and lengthier than those used in other areas of health care delivery as a precondition of receiving treatment services constitutes a parity violation; and that rules should be updated so there is parity in the treatment plan documentation requirements compared to other parts of the healthcare sector.
2. Lack of Evidence – There is no evidence showing that comprehensive and overly burdensome treatment plans lead to better patient outcomes.
3. Negative impact on access and workforce – The overly burdensome and complex treatment requirements add unnecessary administrative burden that amplifies workforce challenges. Rules should be updated to incorporate briefer problem-focused treatment plans, as is common in the rest of healthcare delivery.
4. Communication failure – Overly detailed treatment plan documentation usually results in a document so lengthy that most people involved in ongoing care delivery do not have the time to read and refer to them during subsequent treatment visits. The current overly complicated requirements are a barrier to effective integration of care and contribute to BH being siloed from the rest of healthcare delivery.
5. Negative engagement effect – The requirements are not person-centered; and rather than engaging in problem-focused and person-centered care for a client’s chief concerns, persons seeking treatment must first talk in detail about issues that have no direct relationship to their current distress which damages client-clinician rapport.
6. Delayed treatment – The time it takes to meet the current documentation requirements results in substantial delays in treatment to relieve the person’s distress.

The National Council calls for ongoing support from stakeholders to advocate to CMS and the Department of Labor for the revision of documentation requirements in behavioral health care service delivery.  Learn more here.