WA State BHOs: Combining Behavioral Health with Substance Use Disorder (SUD)

Washington State has released a draft data dictionary for “native” client data and transaction requirements that contain changes needed for the April 2016 Washington State transition from Regional Support Networks (RSNs)  providing mental health care to the new Behavioral Health Organizations (BHOs). BHOs will administer both mental health and substance use disorders (previously called substance abuse) funds to provide services to medically indigent individuals and those who have a BHO-eligible Medicaid benefit. Substance Use Disorder (SUD) providers will begin sending their data via the new data dictionary as the TARGET system is being removed. In addition, each local BHO may have additional changes in data and requirements.

It should also be noted that one region in Washington State, Southwest, will be an “Early Adopter” region, combining the administration of Medicaid benefits for Mental Health, Substance Use Disorder and Medical. There will be an Administrative Services Office for Southwest and many providers in that area may be contracting with the existing Apple Health Plans (such as Molina, CHPW, etc.) instead of directly with their designated region. Washington State hopes to integrate all health services in this manner beginning in 2020. 
 
The following is a brief summary of the Data Dictionary changes to being April 1, 2016:

All existing transactions will continue but will be renumbered due to changes in the new version. Some have been renamed and new transactions—identified by bold text—have been added:

• 020.06:   Client Demographics   (renamed from Consumer Demographics 020.05)
• 022.01:   Client Address   (new/MH, SUD & Pre-intake)
• 023.01:   Authorization   (new/MH & SUD)
• 030.01:   ASAM Placement   (new/SUD only)
• 035.08:   Client Profile   (renamed from Consumer Periodics 035.07)
• 036.01:   Substance Use   (new/SUD only)
• 060.03:   Program Identification   (was 060.02)
• 121.03:   Co-occurring Disorder   (was 121.02)
• 130.03:   Cascade Merge   (was 130.02)
• 160.03:   DMHP Investigation   (was 160.02)
• 161.03:   ITA Hearing   (was 161.02)
• 170.02:   Service Episode   (was 170.01)

There are a number of changes to existing transactions that include, but are not limited to:  Changing the transaction name; re-ordering the data within a transaction; the addition of new, changed or deleted data and/or data tables; and improved data definitions.

• RSN ID has been redefined as “BHO ID” and could possibly be the ProviderOne ID—further State clarification is needed.
• Transactions that include a hospital or facility ID will now require a facility National Provider Identifier (NPI). This will replace Reporting Unit (RU) and the State will provide a list of facility NPIs with an RU cross-walk.
• All references to Consumer have been updated to Client.
• There are no transaction header changes.

These data dictionary changes also come at the same time some RSNs are becoming BHOs, integrating the substance use disorder services with the mental health benefit administration. Both of these changes are fairly significant for clinical, as well as technical staff. These changes will require updates to internal clinical and business processes, changes to forms and/or data systems (EHRs), native transaction formats, collection point timelines, and of course, staff training—all by April 1, 2016. Although this sounds daunting, it is possible. The immediate first step is to review all changes, determine all points of impact, and have discussions with your local regions for additional guidelines and/or data changes to determine the next steps and resources required .

Please note that 837 changes, identified in the BHO Service Encounter Reporting Instructions (SERI) do not include structure changes but define the service (CPT and HCPCS) codes that will be allowable.