Innovation in Behavioral Health (IBH) Model Frequently Asked Questions

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Model Impact

  1. What are the potential impacts for state Medicaid agencies participating in the IBH Model?
    The IBH Model empowers states to drive system-wide change that transforms behavioral health care delivery by aligning Medicaid and Medicare. States participating in the IBH Model receive up to $7.5 million in cooperative agreement funding, plus robust technical assistance from CMS to modernize health IT, implement interoperable data systems, and design value-based payment strategies tailored to their populations.
     
  2. What is the IBH Model’s priority population?
    The IBH Model prioritizes adults (18 years of age or older) with moderate to severe mental health conditions, a SUD, or both, who receive behavioral health care in a Medicaid and Medicare-eligible outpatient setting. While adults with moderate to severe behavioral health diagnoses are the IBH Model’s priority population, all adult Medicaid and Medicare beneficiaries receiving care from an eligible Practice Participant may access IBH Model care delivery framework services when necessary. Practices must serve, on average, at least 25 Medicaid beneficiaries per month who meet the threshold for moderate to severe behavioral health conditions to participate in the IBH Model.

State, Practice, and Beneficiary Participation

  1. What state entities are eligible to apply to the IBH Model?
    State Medicaid agencies from all U.S. states, territories, and the District of Columbia are eligible to apply to the IBH Model. Currently, three states—Michigan, New York, and South Carolina—are participating in the IBH Model. CMS may select up to five additional states to receive a cooperative agreement award to join the model via Cohort II. 
     
  2. Can a state implement the IBH Model if they utilize Medicaid managed care, Medicaid fee-for-service (FFS), or a combination?
    Yes, states can implement the IBH Model in Medicaid fee-for-service (FFS), Medicaid managed care, or a combination, even if they separate Medicaid behavioral health services out of managed care. Where applicable, Medicaid managed care organizations (MCOs) will support states to implement program components including, but not limited to, developing and implementing the model care delivery framework; recruiting Practice Participants; operationalizing the Medicaid Payment Approach; improving data sharing, collection, and analysis; and providing technical assistance.
     
  3. What are the requirements for specialty behavioral health practices to be eligible to participate in the IBH Model?
    In the IBH Model, a specialty behavioral health organization (or setting) refers to a health care provider, practice, or facility, or other community-based organization, that predominantly provides outpatient behavioral health treatment services. Specialty behavioral health practices within the state’s proposed geographic service area will be eligible to participate, at the time of recruitment, if they meet all the following criteria:
  • Have at least one behavioral health provider that is an employee, leased employee, or independent contractor of the practice licensed by the state to deliver behavioral health treatment services and meets any state-specific Medicaid provider enrollment requirements and is eligible for Medicaid reimbursement;
  •  Serve adult Medicaid beneficiaries (age 18 or older) with moderate to severe behavioral health conditions; and
  • Provide mental health and/or SUD treatment services at the outpatient level of care. This does not include the intensive outpatient (IOP) level of care.

    Practices that are NOT eligible to participate in the IBH Model include:
  • Practices that provide only case management or recovery services. 
  • Practices that do not provide direct delivery of diagnostic or treatment of behavioral health services. 
  • Medicare-only providers.
  • Inpatient and post-acute care settings. Post-acute care includes, but may not be limited to, home health agencies, skilled nursing facilities, inpatient rehabilitation facilities, and long-term care hospitals

    All IBH Model Practice Participants must serve Medicaid beneficiaries and participate in their state’s Medicaid program. Participating states will be responsible for recruiting and selecting eligible specialty behavioral health practices to participate in the IBH Model. IBH Model Practice Participants also have the option of serving Medicare beneficiaries and people with Medicare and Medicaid (i.e., dually eligible individuals) by applying in response to a CMS Request for Application (RFA), which will be available starting in 2026. Practices must serve, on average, at least 25 Medicaid beneficiaries per month who meet the threshold for moderate to severe behavioral health conditions to participate in the IBH Model. Behavioral health practices serving only Medicare beneficiaries are not eligible to participate in the IBH Model. Please refer to Section A4.2.1 of the Notice of Funding Opportunity (NOFO) for more information.
     

  1. What are examples of specialty behavioral health practices that are eligible to participate?
    To be eligible to participate in the IBH Model, specialty behavioral health practices must meet the criteria listed in the prior question response above. Examples of specialty behavioral health practices that are eligible to participate in the IBH Model (if they meet criteria above) include, but are not limited to:

    Certified Community Behavioral Health Clinics (CCBHCs), including those supported through the Section 223 CCBHC Medicaid Demonstration, through the Substance Abuse and Mental Health Services Administration (SAMHSA) administered CCBHC Expansion (CCBHC-E) Grants, or through independent state programs separate from the Section 223 CCBHC Medicaid Demonstration.

  • Certified Community Behavioral Health Clinics (CCBHCs);
  • Community Mental Health Centers; 
  • Critical Access Hospital outpatient behavioral health clinics;
  • Independent health care providers with and without clinic affiliation;
  • Local and territorial health departments and governments or other entities that are part of a local government behavioral health authority where a locality, county, region, or state maintains authority to oversee behavioral health services at the local level and uses the entity to provide those services;
  • Opioid Treatment Programs;
  • Private specialty clinics with and without medical center affiliations; 
  • Rural Health Clinics (RHCs) that provide specialty behavioral health care services;*
  • Specialty SUD provider organizations; and

  • Tribal health organizations and clinics.

    A complete list of eligible practices is found in Section A4.2.1 of the NOFO.

    *Additional information regarding RHC eligibility requirements will be provided in future guidance materials.
     

  1. What types of behavioral health practices or levels of care are not eligible to participate in the IBH Model? 
    The following behavioral health practice types are not eligible to participate in IBH Model:
  • Practices that provide only IOP or partial hospitalization program levels of care and do not provide longitudinal outpatient behavioral health treatment. 
  • Inpatient and post-acute care settings (e.g., home health agencies and skilled nursing facilities), as well as ambulance and transportation providers. 
  • Practices that only provide short-term or crisis-based services, such as those using an outpatient license for services at an urgent care center or for crisis stabilization, without ongoing longitudinal outpatient behavioral health care.
  • Behavioral health practices serving only Medicare beneficiaries are not eligible to participate in the IBH Model. At a minimum, all Practice Participants must serve Medicaid beneficiaries; and they may also serve Medicare beneficiaries to participate in both the Medicaid and Medicare components of the model.
     
  1. How can state-selected IBH Model practices participate in the IBH Model Medicare Payment Approach?
    To be eligible to participate in the Medicare Payment Approach, all IBH Model Practice Participants must serve Medicaid beneficiaries and participate in their state’s Medicaid program. These practices will have the option to apply to participate in the IBH Model Medicare Payment Approach and provide IBH Model care delivery framework services to Medicare beneficiaries and people with Medicare and Medicaid (i.e., dually eligible individuals) through a CMS RFA, which will be available in 2026.
     

  2. How does the IBH Model interact with crisis providers? 
    As states are increasingly using mobile crisis intervention services to provide rapid, critical services to people experiencing mental health or substance use crises, CMS designed the IBH Model to dovetail with those services. Practice Participants in the IBH Model provide whole-person, integrated care for beneficiaries with moderate to severe behavioral health conditions by leveraging engagement between the beneficiary and a behavioral health provider. The IBH Model’s care delivery framework and Payment Approach focus on care integration, care management or care coordination, and preventive care and health promotion. While states could implement the IBH Model in a way that would support longitudinal care for beneficiaries coming out of the crisis system, the model does not encompass payment for physical or behavioral health procedures, tests, or treatment, including crisis services. These services continue to be reimbursed under existing Medicaid and Medicare payment authorities, outside of the IBH Model Payment Approach. Additionally, IBH Model Infrastructure Funding will allow Practice Participants to enhance their health IT systems, which could allow for real-time tracking of beneficiary involvement with the crisis system.

    IBH Model care delivery framework services provide a seamless bridge for patients as their needs evolve. The IBH Model supports care coordination across outpatient behavioral health care, crisis services, and higher levels of care, and facilitates re-engagement in longitudinal outpatient care following hospitalization. 
     

  3. What are the IBH Model’s beneficiary eligibility requirements?
    The IBH Model will include Medicaid and Medicare beneficiaries, as well as beneficiaries enrolled in both Medicare and Medicaid (i.e., dually eligible individuals) who are 18 years of age and older, with moderate to severe behavioral health conditions, and receiving outpatient care from an eligible Practice Participant. All adults served by an eligible Practice Participant are eligible to receive IBH Model care delivery framework services if those services are deemed reasonable and necessary (i.e., the level of care required by the IBH Model's care delivery framework is needed), as defined under §1862(a) (1) (A) of the Social Security Act. Adults whose needs do not meet the level of care required by the IBH Model’s care delivery framework are not eligible to be enrolled in the IBH Model.
     
  4. Could beneficiaries enrolled in Medicare Advantage and other commercial health plans receive IBH Model care delivery framework services?
    The IBH Model is a Medicaid and Medicare FFS model. Beneficiaries enrolled in Medicare Advantage and other commercial health plans are not eligible to participate in the IBH Model.
     

  5. How should participating states recruit practices for participation in the IBH Model?
    CMS encourages participating states to leverage various partners to assist with recruitment of practices for the IBH Model including MCOs, risk-based prepaid inpatient health plans, or risk-based prepaid ambulatory health plans, as well as the State Mental Health Authority and/or the Single State Agency for SUD. The state’s IBH Model Convening Structure can help work with these plans and other partners to identify and recruit practices. Ideally, engagement with stakeholders, beneficiaries, and payers in the convenings will inform participating states’ overall recruitment strategy. The overall recruitment strategy must include a plan for outreach to rural, safety-net, under-resourced, and tribal providers and those serving vulnerable populations.

    The Practice Participant eligibility criteria (detailed in prior question responses above) is the basic framework that participating states must use to identify eligible Medicaid Practice Participants, including that the practice must serve, on average, at least 25 Medicaid beneficiaries with a moderate to severe behavioral health condition per month. Participating states (and, as applicable, their partners) may not apply further limiting eligibility criteria, except for limiting eligibility by sub-state region as allowable and identified in its application.

Application Timeline and Period of Performance

  1. When will the IBH Model begin?
    The IBH Model launched in January 2025 with the selection of the first states participating in Cohort I, including Michigan, New York, and South Carolina. The period of performance for Cohort I states is from January 1, 2025, through December 31, 2032, including a three-year Pre-Implementation Period (2025-2027) and a five-year Implementation Period beginning in 2028, when Cohort I practices may start receiving funding for IBH Model care delivery framework services. During the Pre-Implementation Period, practices may enroll and receive Infrastructure Funding for the Medicaid Payment Approach via cooperative agreement funding, at the state’s discretion.

    CohortPre-Implementation PeriodImplementation Period
    Cohort I01/01/2025 - 12/31/2027
    (Model Year 1 - Model Year 3)    		01/01/2028 - 12/31/2032
    (Model Year 4 - Model Year 8)
    Cohort II01/01/2027 - 12/31/2028
    (Model Year 1 - Model Year 2)    		01/01/2029 - 12/31/2033
    (Model Year 3 - Model Year 7)

    Up to five additional states may participate in the IBH Model via Cohort II, following the requirements outlined in the NOFO (released October 2025). CMS anticipates selecting Cohort II states in the fall of 2026, with participation beginning in January 2027 (dates are subject to change). The anticipated period of performance for Cohort II is January 1, 2027, through December 31, 2033, with a two-year Pre-Implementation Period (2027-2028) and a five-year Implementation Period beginning in 2029. For updates, please visit the IBH Model website or subscribe to the IBH Model listserv.
     

  2. How will CMS select states to participate in the IBH Model?
    Additional states interested in participating in the IBH Model must apply to the Cohort II NOFO by June 3, 2026, to be eligible to receive funding through a cooperative agreement. States may submit an optional letter of intent to apply by April 1, 2026. This will be a competitive application process that will include a review of all applications using a detailed rubric. States must submit an application through Grants.gov. See “How to Apply for Grants” at Grants.gov for electronic submission instructions. Refer also to How to Apply for CMS Grants on the CMS website. States must also complete five standard forms noted in the NOFO; Section D2.2 Standard Forms. These forms, along with instructions are available at https://grants.gov/forms. More information about the deadline for applications and the selection process is in the NOFO.
     
  3. Can states and/or practices currently participating in Section 223 CCBHC Medicaid Demonstration or CCBHC Planning, Development, and Implementation Grant participate in the IBH Model?
    Yes, states participating in the CCBHC Prospective Payment System (PPS) Demonstration or CCBHC planning grants programs administered by CMS and the Substance Abuse and Mental Health Services Administration (SAMHSA) can apply to participate in the IBH Model. CMS designed the IBH Model to complement the efforts of multiple, diverse states with different programs and initiatives focused on behavioral health, including pathways to build on and support the work of existing CCBHCs. CCBHCs can bolster their existing efforts to integrate behavioral health and physical health care under Medicaid while also receiving needed reimbursement for serving Medicare beneficiaries, including people with Medicare and Medicaid (i.e., dually eligible individuals). CMS will work with participating states and CCBHCs to ensure they meet all requirements of the IBH Model. Please refer to the Appendix V: Medicaid Payment Scenarios for health homes and CCBHCs in the NOFO for details.
     
  4. Can states participate in other CMS Innovation Center state-based models and participate in the IBH Model?
    Yes, states may participate in multiple CMS Innovation Center state-based models. States interested in participating in multiple Innovation Center models should email IBHModel@cms.hhs.gov with any questions on policies that impact providers and beneficiaries. Note that CMS’s model overlaps policies do not restrict beneficiary freedom to select the provider(s) of their choice.

Care Delivery Framework

  1. Does the IBH Model require Practice Participants to implement specific behavioral health services, or make changes to existing services, to integrate behavioral health and physical health?
    The IBH Model care delivery framework serves as a guide for model services and comprises required core elements, including care integration, care management, and preventive care and health promotion, as detailed in Section A4.3 of the NOFO. Care integration includes screening, assessing, and referring patients, as needed, for both behavioral and physical health conditions within the provider’s scope of practice. Care management involves an interprofessional care team addressing each beneficiary’s needs, such as providing ongoing care management across the beneficiary’s behavioral health and physical health needs.
    While the model does not require practices to add new behavioral health services beyond what they already provide, it does require new activities and workflows within existing behavioral health practice structures to integrate physical and behavioral health. For example, practices must:
  • Screen for diabetes, hypertension, and tobacco use and incorporate results into care planning.
  • Incorporate a physical health consultation into care integration activities. 

  • Establish workflows to address upstream drivers of health (e.g., food, housing, and transportation) including processes for screening, referral, and follow-up.

    IBH Model participating states and Practice Participants have the flexibility to determine how to operationalize integration within their state and model care delivery frameworks.
     

  1. What specific services will the IBH Model’s Payment Approach cover?
    Practice Participants in the IBH Model receive a monthly payment, known as the Integrated Support Payment (ISP), for services that fall under the three core elements of the care delivery framework: (1) Care Integration, (2) Care Management, and (3) Preventive Care and Health Promotion. The monthly payment supports all required activities of the care delivery framework including screening for diabetes, hypertension and tobacco use, care planning with physical health consultants, addressing upstream drivers of health needs, and ongoing care management. The IBH Model does not reimburse for separate physical or behavioral health procedures, tests, or other clinical services- providers will continue to bill Medicare or Medicaid for these services according to CMS or state Medicaid policies.

    Additionally, practices may receive Infrastructure Funding and performance-based payments. The performance-based payments are based on practice-based quality measures related to activities under the care delivery framework. 
     

  2. What provider types can be part of the IBH Model interprofessional care team?
    The interprofessional care team that provides model services must include a state licensed specialty behavioral health provider eligible to bill for Medicaid services and a Physical Health Consultant (e.g., physician, Nurse Practitioner, Physician Assistant) who may be in-house or contracted, and who advises on physical health screening, treatment initiation, monitoring, and interactions between behavioral health and physical health conditions. States have flexibility to determine what other provider types may participate in the interprofessional care team, such as non-physician providers of behavioral health or physical health services, peer workers, family advocates, case managers, community health workers, and counselors. This approach aims to ensure that each beneficiary receives comprehensive and personalized care from a team of professionals best suited to address their specific behavioral health and physical health needs.

     

  3. How will the IBH Model include the experiences of individual beneficiaries?
    The IBH Model’s care delivery framework is deliberate in its inclusion and engagement of beneficiaries and their caregivers as members of the care team. Beginning in the Pre-Implementation Period of the model, regional convenings will incorporate the voice of local communities, beneficiaries, beneficiary representatives, and advocacy groups. These groups will work alongside behavioral health and physical health care providers, payers, community-based organizations and regional associations and interests, to achieve a shared vision of behavioral health for the region. The IBH Model will also include a feedback loop to incorporate beneficiary perspectives over the model lifecycle by including a patient-reported outcome measure (PROM) that aims to assess outcomes that are most meaningful to beneficiaries.
     
  4. Are the Medicare behavioral health provider types included in the 2024 Medicare Physician Fee Schedule eligible to bill Medicare for IBH Model care delivery framework services?
    Yes. On January 1, 2024, CMS released the 2024 Medicare Physician Fee Schedule (PFS) including marriage and family therapists, mental health counselors (MHCs), and licensed alcohol and drug counselors who meet MHC requirements. If Practice Participants participate in the Medicare Payment Approach, these providers can serve as the billing practitioner for IBH Model care delivery framework services. Other provider types eligible to bill Medicare for IBH Model care delivery framework services include physicians, non-physician practitioners, and other eligible professionals whose primary area of practice involves the diagnosis, evaluation, and therapeutic management of mental health and SUD conditions. In addition to the provider types noted in the Calendar Year 2024 PFS, billing practitioners may include medical doctors or doctors of osteopathy, clinical psychologists, clinical social workers, clinical nurse specialists, nurse practitioners, physician assistants, and independently practicing psychologists. These providers must be in good standing with Medicare, comply with all applicable Medicare regulations, hold valid state licensure for their services, and be able to accept prospective payment. The provider must also implement the care delivery framework outlined in Section A4.3 of the NOFO. Note that providers may bill Medicare for IBH Model care delivery framework services only if they are part of a Practice Participant that participates in the state’s Medicaid Payment Approach and is accepted into the Medicare Payment Approach.

Measuring Quality of Care

  1. How will the IBH Model measure the quality of care provided through the care delivery framework?
    The IBH Model’s quality strategy seeks to evaluate the model’s ability to achieve IBH Model goals, including improved quality of care, increased access to care, improvements in priority health conditions, and reducing avoidable emergency department and inpatient utilization. CMS may adjust measures over time. Currently, the practice-level measures are:
  • Acute Hospital Utilization
  • Emergency Department Utilization
  • Controlling High Blood Pressure
  • Glycemic Status Assessment for Patients with Diabetes
  • Tobacco Use: Screening and Cessation Intervention
  • Upstream Drivers of Health

  • Patient-Reported Outcome (measure to be determined)

    CMS will monitor state-level performance with implementation and operation of the model, as well as patient care delivered by Practice Participants in a state. The state-level measures are:

  • Acute Hospital Utilization 
  • Emergency Department Utilization 
  • Follow-Up After Emergency Department Visit for Substance Use: Age 18 and Older 
  • Follow up after Hospitalization for Mental Illness: Age 18 or older 
  • Follow-Up After Emergency Department Visit for Mental Illness: Age 18 and Older 
  • Diabetes Screening for People with Schizophrenia or Bipolar Disorder Who Are Using Antipsychotic Medications
  • Medicaid Total Cost of Care 

  • Hemoglobin A1c Control for Patients with Diabetes*

    *The Diabetes Control measure is now known as Glycemic Status Assessment for Patients with Diabetes.
     

  1. How will CMS implement the standardized Total Cost of Care measure across different states?
    CMS is working with a measure developer to develop a Medicaid Total Cost of Care measure that will account for differences across states. CMS will provide more information about the measure specifications after the measure design process is complete.
     
  2. How will the IBH Model measure integrated care? Will the IBH Model measure behavioral health conditions, physical health conditions, or both?
    To measure outcomes and the integration of behavioral health and physical health, the IBH Model will track three priority health conditions: diabetes, hypertension, and tobacco use disorder. Practice Participants may treat these conditions in the behavioral health setting, or make appropriate referrals, provide care management services related to these conditions, and track and monitor these outcomes. States may add other behavioral health and/or physical health conditions to their state-specific requirements.
     

  3. Will the IBH Model qualify as a Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Model (APM)?
    A CMS Innovation Center model may be considered a Merit-based Incentive Payment System (MIPS) Advanced Alternative Payment (APM) if it meets two criteria: 1) Participants in the IBH Model (“APM Entities”) participate under an agreement with CMS or through a law or regulation; and 2) the APM bases payment on quality measures and cost/utilization. The IBH Model will satisfy both MIPS APM criteria and is expected to qualify as a MIPS APM.

    A model (or track within a model) must meet three specific criteria to be considered an Advanced APM: 1) require use of Certified Electronic Health Record Technology (CEHRT), 2) provide for payment based on performance on MIPS-comparable quality measures, and 3) require Participants to bear a more than nominal amount of financial risk. CMS does not expect the IBH Model to qualify as an Advanced APM.
     

  4. How much Infrastructure Funding will be available to Practice Participants?
    The level of Infrastructure Funding is based on a Health IT and Practice Transformation Needs Assessment, and whether the Practice Participant participates in the Medicaid Payment Approach only or both the Medicare and Medicaid Payment Approaches. At a minimum, all Practice Participants must participate in the Medicaid Payment Approach. Practice Participants that participate in only the Medicaid Payment Approach may receive Infrastructure Funding through the state’s cooperative agreement funding. Section A4.5 of the NOFO details that participating states (i.e., state Medicaid agencies) should reserve approximately $100,000 in cooperative agreement funding per Medicaid-only Practice Participant for budgeting purposes. Though the total amount of Infrastructure Funding distributed to each Medicaid-only Practice Participant is determined by the state through the Health IT and Practice Transformation Needs Assessment, Practice Participants that opt to participate in both the Medicaid and Medicare Payment Approaches and have signed an agreement with CMS to participate in the IBH Model’s Medicare Payment Approach will be eligible to receive up to an additional $200,000 in Infrastructure Funding directly from CMS, as determined by the Health IT and Practice Transformation Needs Assessment.

Model Funding and Other Participant Support

  1. How will the performance-based payments work?
    The IBH Model Medicare Payment Approach includes pay-for-reporting and pay-for-performance incentives that are a percentage of the ISP. The Medicare Payment Approach including the aligned performance-based payment, is described in the NOFO, Appendix VI Medicare Payment Approach Details.

    A participating state’s Medicaid Payment Approach must align with the Medicare Payment Approach, including the use of an upside bonus and a performance-based withhold. The Medicaid Payment Approach must have a performance-based payment component. The performance-based payment for Medicaid providers will come from existing state Medicaid funds. Participating states should engage members of their Convening Structure in designing this aspect of their Medicaid Payment Approach. 

    If participating states are unable to include a withhold in the performance-based payment for certain provider types, CMS will work with participating states on a case-by-case basis to determine other performance-based accountability features. These Practice Participants must also participate in the Medicare Payment Approach, where applicable. 

    CMS recognizes that many states have undergone comprehensive innovation in behavioral health benefit design and payment. In addition, many states have implemented, or are considering implementing, existing Medicaid state-based initiatives, such as behavioral health homes and CCBHCs. CMS will work with states to implement the IBH Model in a way that is compatible with those programs’ requirements.
     

  2. When will the performance-based withholds begin? 
    The Medicare performance-based payment will include incentives for measure reporting at a level that is equal to or above designated reporting thresholds. In Model Year 4 (MY4), CMS will transition from calculating the performance-based payment based on measure reporting to calculating based on performance, with one or two quality measures moving to performance‑based payment, while the remaining measures will continue as pay‑for‑reporting throughout the life of the model. For example, the patient‑reported outcome measure will remain pay‑for‑reporting for all Implementation Period years (MY3-MY7).

    CMS will evaluate performance progress using only the data from Practice Participants (CMS will not compare Practice Participants against non-participating practices). Practice Participants may earn a partial or full performance-based payment. The weight of each measure in the total performance-based payment calculation is in development. However, for MY4, CMS expects Acute Hospital Utilization and Emergency Department Utilization to be worth 10 percent of the performance-based payment and the remaining measures to be worth 20 percent of the performance-based payment.

    The performance-based payment will be upside only for MY6 through MY7. Practices can earn an additional 3 percent of the ISP for MY3, up to 4 percent of the ISP for MY4, and up to 5 percent of the ISP for MY5 to MY7. In MY6, CMS will introduce performance-based payment adjustments that include both upside and a withhold tied to quality. CMS will withhold 2 percent of the ISP with a 5 percent potential upside bonus. In MY7, there will be a 5 percent withhold with the same potential for a 5 percent upside bonus. Practice Participants may earn back withheld amounts based on improvements on the measures. CMS designed this approach to help familiarize specialty behavioral health practices with value-based payment, build capacity for data reporting, and ultimately reward improvements in care quality and outcomes.
     

  3. Can states develop more than one Medicaid Payment Approach?
    States may only develop one Medicaid Payment Approach for IBH Model care delivery framework services. However, if a state includes Practice Participants with different payment methodologies (e.g., per-beneficiary -per-month [PBPM] vs. PPS) , then the state may develop more than one Medicaid Payment Approach, pending CMS review and approval. Refer to Section A4.4 of the NOFO for additional information on the Medicaid Payment Approach.
     
  4. Can states use a Prospective Payment System for the Medicaid Payment Approach?
    Yes, states have the flexibility, pending CMS approval, to determine if their Medicaid Payment Approach should include the PBPM or a traditional FFS payment. Each payment must meet the IBH Model Medicaid Payment Approach criteria listed in Section A4.4 of the NOFO.
     

  5. How does the IBH Model avoid duplication of services? 
    States will be responsible for identifying a state-specific approach to avoid duplication for services. The participating state will implement and annually update a strategy to prevent duplication of services and payments across federal, state, and local programs, including Medicaid, Title V, and any relevant waivers or demonstrations. In addition, the IBH Model avoids duplication by establishing explicit eligibility exclusions—such as excluding inpatient and post-acute providers—prohibiting the use of cooperative agreement funds for Medicaid-covered clinical services and requiring the Medicaid Payment Approach to align with and not duplicate existing payment authorities. Additionally, CMS identified a list of codes that are prohibited for a provider to bill when a Medicare beneficiary is participating in the IBH Model. This list of codes is available in Appendix VI of the NOFO.

     

  6. How are states permitted to use cooperative agreement funding?
    Participating states in will receive up to $7.5 million in cooperative agreement funding over the IBH Model’s performance period. States will receive this funding to increase their capacity to implement the Medicaid Payment Approach and care delivery framework. States will also use these funds to support Practice Participants. Examples of allowable uses of funding include but not limited to:
  • Building and updating state and practice-level health IT infrastructure and capacity;
  • Convening a diverse range of partners to collaborate on model development and implementation, including development of the Medicaid Payment Approach;
  • Ensuring the flow and analysis of data needed for IBH Model monitoring, payment, and evaluation; 
  • Hiring new staff and training staff on care coordination, integration, and new clinical workflows; and

  • Identifying and recruiting Practice Participants.

    Note that cooperative agreement funding cannot be used to cover clinical services already covered under Medicare and Medicaid or the Children’s Health Insurance Plan (CHIP).
     

  1. How can Practice Participants bill Medicaid and Medicare for services covered under the model's care delivery framework?
    In the Medicaid Payment Approach, Practice Participants will follow the billing approach designed by the state to support care coordination and case management for attributed Medicaid beneficiaries. CMS will provide technical assistance to states in the Pre-Implementation Period to develop a Medicaid Payment Approach that reaches the IBH Model principles of directional alignment with the Medicare Payment Approach and is responsive to the state’s unique context (detailed in Sections A4.4.1 and A4.4.4 of the NOFO).

    Practice Participants that participate in the Medicare Payment Approach will bill a model-specific billing code to submit Medicare claims for services covered under the model’s care delivery framework. 
    CMS established the ISP to support the initial and ongoing assessment of behavioral health and physical health conditions and needs related to upstream drivers of health, along with care management, care integration, and health outcomes. The Medicare ISP is a prospective PBPM payment that will begin in 2028. CMS anticipates that the ISP will be approximately $200-220 per-beneficiary-per-month, and be risk adjusted.
     

  2. How will the IBH Model support the health IT capacity of Practice Participants?
    IBH Model Infrastructure Funding of up to $200,000 for approved practices serving Medicare and dually eligible beneficiaries will help practices invest in the necessary capacity and infrastructure tools, such as interoperability and telehealth capabilities, to enable care integration and care management as required by the model.* The amount of Infrastructure Funding for each Medicare Practice Participant is based on capacity and demonstrated need in the model Health IT and Practice Transformation Needs Assessment.

    Examples of activities supported by IBH Model Infrastructure Funding include but are not limited to the following:

  • Development or enhancement of electronic health record systems
  • IT tools for patient engagement 
  • Telehealth training, systems, and enhancements 
  • IT to support quality measurement/assessments
  • Interoperable systems and support for referrals, documentation, and follow up 
  • Connection to state Health Information Exchanges
  • Staff time to implement model requirements (e.g., for new policies and workflows) and support organizational change
  • Hiring and training staff in privacy and security regulations
  • Increased capacity for laboratory testing
  • Patient education and communications (e.g., educational resources and messages shared through an electronic patient portal).

  • Collaboration and agreements with physical health providers and social service organizations
    Practice Participants may also be eligible for funding for health IT and practice transformation from their participating state Medicaid agency, which may promote or support additional uses for Infrastructure Funding related to health IT and practice transformation.

    *The IBH Model care delivery framework includes screening, ongoing assessment, and care coordination for behavioral health and physical health needs and screening and closed loop referrals for upstream drivers of health (e.g., food, housing, and transportation). See the IBH Model website for more information.
     

  1. Will CMS provide technical assistance for practice participants in the IBH Model?
    Yes, CMS and its partners will provide ongoing, robust technical assistance and learning opportunities to IBH Model participating states and Practice Participants. The CMS Innovation Center designed the IBH Model with a two-or three-year Pre-Implementation Period (depending on whether the participating state is in Cohort I or Cohort II) to ensure adequate time for states and practices to receive technical assistance in crucial areas such as payment, care delivery, data, and quality.

IBH Model Design

  1. Are participating states implementing this model statewide or in a sub-state geographic service area?
    States may choose to implement the IBH Model across the entire state, or within a specific region of the state. 
     
  2. What type of external guidance did CMS solicit when developing this model?
    The CMS Innovation Center sought input for the model from a range of behavioral health experts, including advocacy groups, provider and beneficiary groups, SMAs, and other interested parties from across the country, as well as SAMHSA, the Center for Medicaid and CHIP Services (CMCS), the Indian Health Service, and Assistant Secretary for Technology Policy (formerly Office of the National Coordinator for Health IT). Topics discussed during these conversations included payment innovation, funding use, health IT, workforce, and care integration. CMS plans to continue to consult with states, providers, beneficiaries, and other experts and interested groups during the life of the model to support effective implementation and proactively address any emerging challenges. We appreciate their guidance on a successful model design.

Certified Community Behavioral Health Clinics and the IBH Model

  1. How will the IBH Model align with the Certified Community Behavioral Health Clinics?
    The CMS Innovation Center designed the IBH Model in partnership with CMCS and SAMHSA to complement CCBHC initiative efforts and investments by states and the federal government. The Department of Health & Human Services currently supports the CCBHC initiative through the Section 223 CCBHC Medicaid Demonstration and SAMHSA CCBHC Expansion Grants, which include CCBHC Improvement and Advancement (CCBHC-IA) and CCBHC Planning, Development, and Implementation (CCBHC-PDI). These programs have differing requirements and associated funding. 
     

  2. What is the value of participating in the IBH Model for states already integrating behavioral health through Certified Community Behavioral Health Clinics (CCBHCs) Does the IBH Model duplicate CCBHC services?
    The IBH Model aligns Medicare and Medicaid value-based payments, providing CCBHCs access to Medicare performance-based payments unavailable through the CCBHC Demonstration alone. By requiring implementation of these performance-based payments in the care delivery structure, the IBH Model creates a glidepath to a sustainable value-based payment system.

    The IBH Model does not replace or replicate CCBHC requirements. For the three targeted chronic conditions, the IBH Model complements CCBHC requirements by supporting deeper physical health integration and enhanced care management through required physical health screenings, care planning with a physical health consultant, and enhanced care management with closed loop referrals. The IBH Model allows CCBHCs to build on their existing work while providing funding to create more robust and consistent care management and integration.

    CCBHCs may participate in the IBH Model only if they meet IBH Model Practice Participant eligibility criteria. The state is responsible for ensuring there is no duplication of payment across CCBHC PPS and the IBH Model payments. At the participating state’s discretion and based on a standardized needs assessment, each CCBHC participating in the IBH Model may receive Infrastructure Funding as described in Appendix V and Appendix VI of the NOFO. The state may provide Infrastructure Funding to CCBHCs only when that funding is not duplicative of existing federal funds. Infrastructure Funding is based on a standardized Health IT and Practice Transformation Needs Assessment conducted by the state.

     

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Page Last Modified:
03/24/2026 12:17 PM
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