CMS Releases Proposed Rule for Community Mental Health Centers with a Big Role for OT
Occupational Therapy a Required Service for Community Mental Health Centers According to Proposed Rule
The Centers for Medicare & Medicaid Services (CMS) released proposed Conditions of Participation (COPs) for community mental health centers that include a prominent role for occupational therapists. According to the first ever proposed COPs for community mental health centers, CMS would require the development of physician-led evaluation and treatment teams that would direct patient care. As part of that requirement, the interdisciplinary team would be composed of a doctor of medicine, osteopathy or psychiatry, a psychiatric registered nurse, clinical psychologist, a clinical social worker, an occupational therapist, and other licensed mental health counselors, as necessary.
This recognition of the importance of occupational therapy to patient function and overall outcomes is an important step towards increasing opportunities for occupational therapy practitioners in the practice area of mental health.
CMS's proposed COPs build upon the inclusion of occupational therapy as part of the Medicare Partial Hospitalization benefit and extend that inclusion to a required role in both evaluation and treatment in community mental health centers for Medicare beneficiaries. The proposed rule also expresses the intent of CMS that these COPs would be adopted for all payers, greatly expanding the reach and scope of the rule.
Here is a link to the proposed rule published in the Federal Register on June 17, 2011. Comments are due on August 16, 2011, by 5 p.m. EST. AOTA has sent a copy of the proposed rule to the members and leadership of the Mental Health Special Interest Section and is working to draft comments supporting the inclusion of occupational therapy in the final rule expected to be released this fall.
AOTA members with expertise in mental health are encouraged to send their own comments supporting the explicit inclusion of occupational therapy in the treatment and evaluation teams in community mental health centers. AOTA’s official comments on the proposed COPs will be available on AOTA’s Web site under Federal Advocacy/Testimony & Statements after submission to CMS.