U.S. Department of Health and Human Services 
Office of Inspector General 
 
Provider Shortages 
and Limited 
Availability of  
Behavioral Health 
Services in New 
Mexicos Medicaid 
Managed Care 
 
 
OEI-02-17-00490 
September 2019 
Joanne M. Chiedi 
 
Acting Inspector General 
oig.hhs.gov  Rep ort in Brief  U.S. Department of Health and Human Services 
September 2019 
Office of Inspector General 
 
OEI-02-17-00490 
 
 
Why OIG Did This 
Provider Shortages and Limited Availability of 
Review 
Behavioral Health Services in New Mexicos Medicaid  The need for behavioral 
health services is 
Managed Care 
particularly pronounced 
in New Mexicoa State 
What OIG Found 
that has among the 
Despite the need for behavioral health serviceswhich 
Key Takeaway  highest rates for suicide 
includes treatments and services for mental health and 
  and deaths from 
substance use disordersmany counties in New Mexico have  The challenges faced by New 
overdose in the Nation.  
few licensed behavioral health providers serving Medicaid  Mexicoincluding provider 
The Office of Inspector 
managed care enrollees.  These behavioral health providers  shortages and limited 
General (OIG) received a 
are unevenly distributed across the State, with rural and  availability of behavioral 
congressional request to 
frontier counties having fewer providers and prescribers per  health servicesare likely 
look into concerns 
1,000 Medicaid managed care enrollees.  Further, a significant  shared by other States and 
about behavioral health 
number of New Mexicos licensed behavioral health providers  will require both State and 
provider shortages and 
do not provide services to Medicaid managed care enrollees.    national attention. 
the availability of care 
In addition, most of the States licensed behavioral health  for Medicaid managed 
providers serving Medicaid managed care enrollees work in behavioral health organizations  care enrollees; these 
(BHOs), which include federally qualified health centers and community mental health centers;  enrollees account for 
however, BHOs report challenges with finding and retaining staff, as well as ensuring  most of New Mexicos 
transportation for enrollees.  As a result, these organizations cannot always ensure timely access  Medicaid population.   
for enrollees seeking behavioral health services. These organizations also report difficulty 
How OIG Did This 
arranging or making referrals for services that they do not provide largely because of the lack of 
Review 
providers.  In addition, they report challenges with continuity of care for enrollees, citing limited 
care coordination and lack of integration of primary and behavioral healthcare, provider  We analyzed State 
shortages, and barriers to sharing health information, such as a lack of access to broadband.   Medicaid managed care 
Nonetheless, BHOs highlight promising initiatives to increase the availability of behavioral health  data on the number of 
services, including open-access scheduling, treatment first, care integration, and telehealth.   behavioral health 
providers and the 
What OIG Recommends  
number of managed 
Although this report focuses on New Mexico, it provides insights into challenges that are likely 
care enrollees by 
shared by other States providing behavioral health services to Medicaid enrollees, especially in rural 
county.  We also 
and frontier counties.  In addition, because of the breadth and depth of these issues, additional 
conducted a survey of 
support at the national level is needed.  Therefore, we recommend that the Centers for Medicare & 
selected BHOs that play 
Medicaid Services (CMS) identify States that have limited availability of behavioral health services 
a critical role in 
and develop strategies and share information with them to ensure that Medicaid managed care 
providing services to the 
enrollees have timely access to these services.  We also recommend that the New Mexico Human 
States Medicaid 
Services Department expand New Mexicos behavioral health workforce that serves Medicaid 
enrollees as well as to 
managed care enrollees.  It should also improve access to services by reviewing its access to care 
uninsured residents.  In 
standards and by increasing access to transportation, access to broadband, and the use of 
addition, we interviewed 
telehealth.  Lastly, it should improve the effectiveness of services by increasing adoption of 
selected providers, State 
electronic health records, identifying and sharing information about strategies to improve care 
Medicaid agency 
coordination, expanding initiatives to integrate behavioral and primary healthcare, and sharing 
officials, and key 
information about open-access scheduling and the Treat First Clinical Model.  Both CMS and the 
stakeholders.   
New Mexico Human Services Department concurred with our recommendations.
 
 
The full report can be found at oig.hhs.gov/oei/reports/oei-02-17-00490.asp   
 
TABLE OF CONTENTS 
BACKGROUND  1 
Methodology  5 
FINDINGS   
Many counties have few behavioral health providers serving Medicaid managed care enrollees  6 
Most behavioral health providers work in behavioral health organizations; however, these  9 
organizations report challenges with finding and retaining staff 
Behavioral health organizations cannot always ensure timely access for enrollees seeking  10 
behavioral health services 
Behavioral health organizations report difficulty arranging or making referrals for services that  12 
they do not provide  
Behavioral health organizations report challenges with continuity of care, citing limited care  15 
coordination, provider shortages, and barriers to sharing health information  
Behavioral health organizations highlight promising initiatives to increase the availability of  18 
services, including open-access scheduling, treatment first, care integration, and telehealth  
CONCLUSION AND RECOMMENDATIONS   
Recommendation to the Centers for Medicare & Medicaid Services:    
Identify States that have limited availability of behavioral health services and develop  24 
strategies and share information to ensure that Medicaid managed care enrollees have 
timely access to these services   
Recommendations to the New Mexico Human Services Department:    
Take steps to expand New Mexicos overall behavioral health workforce  24 
Increase behavioral health providers participation in Medicaid managed care   25 
Review its standards governing access to care and determine whether additional standards  25 
are needed for behavioral health providers 
Improve access to transportation for Medicaid managed care enrollees needing behavioral  25 
health services 
Work with State partners to strengthen access to broadband in rural and frontier counties  26 
Expand the use of telehealth to increase the availability of behavioral health services  26 
Take steps to increase adoption of electronic health records and participation in the State  27 
Health Information Exchange by behavioral health providers  
Identify and share information about strategies to improve care coordination  27 
Expand initiatives to integrate behavioral and primary healthcare  28 
 
   
 
Share information about open-access scheduling and the Treat First Clinical Model and  28 
promote expansion 
AGENCY AND STATE COMMENTS AND OIG RESPONSE  29 
APPENDICES 
 
A:  Detailed Methodology  31 
B:  Number of Licensed Behavioral Health Providers That Serve Medicaid Managed Care Enrollees  34 
in New Mexico 
C:  Number of Selected Behavioral Health Organizations That Report Having Difficulty Providing  37 
 
Timely Appointments
D:  Number of Selected Behavioral Health Organizations That Report Having Difficulty Arranging  38 
Each Service 
E:  Centers for Medicare & Medicaid Services Comments   40 
F:  New Mexico Human Services Department Comments  43 
ACKNOWLEDGMENTS  47 
 
 
 
 
 
 
     
 
   
 
BACKGROUND 
 
Objectives  
   
1.  To determine the number of behavioral health providers that 
  serve New Mexicos Medicaid managed care enrollees in 
each county.  
 
2.  To determine the extent to which behavioral health 
 
organizations are able to meet the needs of the States 
  Medicaid managed care enrollees.   
3.  To identify challenges and promising initiatives for improving 
 
the availability of behavioral health services for the States 
  Medicaid managed care enrollees. 
Research has shown that Medicaid enrollees experience a higher rate of 
behavioral health disorderswhich include both mental health disorders 
and substance use disordersthan the general population.1  In spite of the 
importance of treating such disorders, many Medicaid enrollees encounter 
significant barriers when accessing behavioral health treatment.  These 
barriers include an overall shortage of behavioral health providers in the 
United States, combined with a relatively small number of behavioral health 
providers who accept Medicaid.2  Such barriers can impede access to 
necessary services, resulting in untreated addiction and mental health 
conditions, worsening health, and increased medical costs.3 
              ___________________________________________________________ 
1 Government Accountability Office (GAO), Medicaid Expansion: Behavioral Health Treatment 
Use in Selected States in 2014, (GAO-17-529), June 2017.  Accessed at  
https://www.gao.gov/assets/690/685415.pdf on April 4, 2019. 
2 Substance Abuse and Mental Health Services Administration (SAMHSA), Report to Congress 
on the Nations Substance Abuse and Mental Health Workforce Issues, January 24, 2013.  
Accessed at https://www.cibhs.org/sites/main/files/file-attachments/samhsa_bhwork_0.pdf on 
April 5, 2019.  See also Medicaid and CHIP Payment and Access Commission (MACPAC), 
Physician Acceptance of New Medicaid Patients, January 24, 2019.  Accessed at 
https://www.macpac.gov/wp-content/uploads/2019/01/Physician-Acceptance-of-New-
Medicaid-Patients.pdf on April 5, 2019. 
3 GAO, Medicaid Expansion: Behavioral Health Treatment Use in Selected States in 2014, June 
2017.  Accessed at  https://www.gao.gov/assets/690/685415.pdf on April 4, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  1 
OEI-02-17-00490   
 
Improving access to behavioral healthcare is essential in New Mexico, where 
56 percent of adults with mental illness do not receive treatment.4  Further, 
the State has among the highest rates for suicide and deaths from overdose 
in the Nation.5  New Mexico also ranks as one of the poorest States in the 
Nation, with more than half of 
Behavioral health includes: 
the population either covered 
by public health insurance or 
  promotion of emotional health, 
uninsured.6       
  prevention of mental illnesses and 
In 2013, New Mexico 
substance use disorders, and  
experienced major disruptions   
  treatment and services for mental 
in services, with the closure 
and substance use disorders.   
and replacement of many of its 
largest behavioral health   
organizations (see text box below).  The Office of Inspector General (OIG) 
received a congressional request to look into concerns about behavioral 
health provider shortages in Medicaid managed care.  In response, OIG 
agreed to conduct a review to determine the number of behavioral health 
providers that serve the States Medicaid managed care enrollees and the 
availability of care to meet the needs of this population.  OIG also agreed to 
look at the extent to which providers have waiting lists, the extent to which 
providers have difficulty making referrals, and any challenges with continuity 
of care.    
Historical perspective of behavioral health in New Mexico 
The behavioral health system in New Mexico experienced major disruptions in the provision of care 
that affected Medicaid managed care enrollees.  In 2013, the New Mexico Human Services 
Department suspended Medicaid payments to 15 behavioral health organizations due to an 
accusation of fraud; these 15 organizations provided about 85 percent of all behavioral health 
services to enrollees.  Although all of these organizations were eventually cleared of wrongdoing in 
subsequent years, 13 of them went out of business.  These organizations were initially replaced by 
Arizona-based organizations; however, all but two of these replacement organizations are no 
longer practicing in the State.  
              ___________________________________________________________ 
4 SAMHSA, Behavioral Health Barometer: New Mexico, Volume 4: Indicators as Measure 
Through the 2015 National Survey on Drug Use and Health, the National Survey of Substance 
Abuse Treatment Services, and the Uniform Reporting System, 2017.  Accessed at 
https://www.samhsa.gov/data/sites/default/files/NewMexico_BHBarometer_Volume_4.pdf on 
June 10, 2019. 
5 New Mexico Health Care Workforce Committee, 2017 Annual Report, October 1, 2017.  
Accessed at http://www.hsd.state.nm.us/uploads/PressRelease/2f473c14ee 
654f868b5a25b3cfd15a6d/NMHCWF_2017Report_eDist_LoRes.pdf on April 3, 2019. 
6 U.S. Census Bureau, 20132017 American Community Survey 5-Year Estimates, Selected 
Economic Characteristics.  Accessed at https://factfinder.census.gov/faces/ 
tableservices/jsf/pages/productview.xhtml?src=bkmk on June 10, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  2 
OEI-02-17-00490   
 
Medicaid managed care in New Mexico 
Medicaid plays a critical role in providing behavioral healthcare.  Nationally, 
Medicaid is the single largest payor for behavioral healthcare, accounting 
for approximately 11 percent of all Medicaid spending.7   
Most States, including New Mexico, provide a portionif not allof their 
behavioral health services through Medicaid managed care plans.  These 
plans typically provide behavioral health services through a network of 
participating providers in exchange for a fixed monthly fee per enrollee 
(often referred to as capitation).   
New Mexicos Medicaid managed care program, Centennial Care, was 
implemented in 2014 and requires managed care plans to cover services for 
physical health, behavioral health, and long-term care.8  Most (80 percent) 
of New Mexicos Medicaid population is enrolled in one of New Mexicos 
three managed care plans.9  These plans provide services to enrollees 
throughout the State, and most of the behavioral health providers that 
participate in Medicaid managed care participate in all of the States 
managed care plans. 
Federal regulations require States to develop standards for access to care 
that all managed care plans must meet.10  These standards are intended to 
ensure that each plan maintains an adequate network to provide access to 
covered Medicaid services.11  New Mexicos standards for behavioral health 
require that appointments for non-urgent behavioral healthcare be 
              ___________________________________________________________ 
7 This analysis is based on 2009 Medicaid data.  Mark et al., Insurance Financing Increased for 
Mental Health Conditions But Not for Substance Use Disorders 1986-2014, June 2016.  
Accessed at https://www.healthaffairs.org/doi/pdf/10.1377/hlthaff.2016.0002 on June 10, 2019.  
8 The New Mexico Human Services Department oversees the Medical Assistance Division and 
the Behavioral Health Services Division.  The Medical Assistance Division is responsible for 
contracting with Medicaid managed care organizations and the Behavioral Health Services 
Division oversees SAMHSA-funded behavioral health block grants. 
9 These data were provided by the New Mexico Human Services Department.  Note that the 
Native American population is typically exempt from the requirement to enroll in a managed 
care plan.  See New Mexico Administrative Code (NMAC) 8.308.7.9(A).  Also note that for 
most of the study period, there were four Medicaid managed care plans in the State.   
10 42 CFR  438.206(a). 
11 42 CFR  438.206(b)(1). 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  3 
OEI-02-17-00490   
 
available within 14 days and behavioral health outpatient appointments for 
urgent conditions be available within 24 hours.12  
Licensed behavioral health providers 
Licensed behavioral health providers have a range of education and training 
in specialties that address substance use and mental health needs.  These 
behavioral health providers are able to engage in a broad range of 
interventions, including assessment, psychotherapy, and crisis intervention 
services.   
Independently licensed providers may be directly reimbursed by Medicaid 
for their services.  Such providers include psychiatrists, psychologists, and 
licensed clinical social workers.13  Certain independently licensed behavioral 
health professionals are also authorized to diagnose mental illness and 
substance use disorders, and in some cases, can prescribe medication as 
part of an enrollees treatment plan.14 
The next level of licensure consists of non-independently licensed providers.  
These providers typically work under the supervision of an independently 
licensed provider and generally cannot be directly reimbursed for their 
services.  These providers include licensed masters level social workers, 
licensed mental health counselors, and licensed associate marriage and 
family therapists.15 
Behavioral health organizations 
Although outpatient behavioral health services can be provided by 
individuals (and by individuals who form group practices), behavioral health 
organizations (BHOs) are core providers that play a critical role in providing 
              ___________________________________________________________ 
12 NMAC 8.308.2.12 (E), (F).  The standard governing request-to-appointment time, for non-
urgent behavioral healthcare, can be waived if the enrollee requests a later time.  New 
Mexico also requires that appointments for behavioral health crisis services be available 
within two hours.  See NMAC 8.308.2.12 (R).  In addition, New Mexico requires its managed 
care organizations to comply with standards that address distance and travel time between 
enrollees and contracted providers.  See NMAC 8.308.2.9 (A)(11)(c). 
13 NMAC, 8.321.2.9 (H). 
14 New Mexico Health Care Workforce Committee, 2017 Annual Report, October 1, 2017.  
Accessed at http://www.hsd.state.nm.us/uploads/PressRelease/2f473c14ee654 
f868b5a25b3cfd15a6d/NMHCWF_2017Report_eDist_LoRes.pdf on April 25, 2019. 
15 NMAC 8.321.2.9 (J).  Some behavioral health services may be provided by non-licensed 
providers who are not able to prescribe medication and are not able to practice without 
supervision.  These include masters level behavioral health interns, certified peer support 
workers, and pre-licensure psychology post-doctorate students.  New Mexico Network of 
Care, Behavioral Health in New Mexico: Challenges, Medicaid Contributions, New 
Opportunities.  Accessed at 
http://newmexico.networkofcare.org/content/client/1446/3Centennial%20Care%20Update-
Final.pdf on June 10, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  4 
OEI-02-17-00490   
 
services to the States Medicaid enrollees as well as to uninsured residents.  
BHOs include federally qualified health centers, community mental health 
centers, behavioral health agencies, rural health clinics, and core service 
agencies.16 
In addition to outpatient services, a number of behavioral health services 
are delivered in inpatient or residential settings.  These include psychiatric 
hospitals, residential treatment centers, as well as facilities that provide 
inpatient treatment for substance use disorders. 
Methodology  We used several data sources to address the studys objectives.  We first 
analyzed State Medicaid managed care data to determine the number of 
behavioral health providers serving New Mexicos managed care enrollees 
by county.  We focused this part of the study on licensed behavioral health 
providers who render outpatient services to Medicaid managed care 
enrollees.  Licensed behavioral health providers have the specific education 
and training needed to address a broad range of mental health and 
substance use disorders.  We did not include non-licensed behavioral health 
workers and other physical health workers who may provide only limited 
behavioral health services such as diagnostic screening.17 
Next, we conducted a survey of 53 selected BHOs to determine the extent 
to which these organizations are able to meet the needs of the States 
Medicaid managed care enrollees.  In addition, we interviewed selected 
behavioral health providers, State Medicaid agency officials, and key 
stakeholders.  We analyzed these data to identify challenges and promising 
initiatives for improving the availability of behavioral health services for 
Medicaid managed care enrollees.   
See Appendix A for the detailed methodology.    
Standards  We conducted this study in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General on 
Integrity and Efficiency. 
 
 
   
              ___________________________________________________________ 
16 New Mexico may designate a BHO as a core service agency if it provides and coordinates 
certain core services, such as psychiatric services, medication management, crisis services, 
and treatments that support an enrollees recovery goals. 
17 This study also does not include out-of-State behavioral health providers licensed by New 
Mexico who provide services remotely. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  5 
OEI-02-17-00490   
 
FINDINGS 
Many counties  New Mexico has about 2,700 licensed behavioral health providers that serve 
its Medicaid managed care enrollees.  These behavioral health providers are 
have few 
distributed unevenly across the State.  As a result, many counties have few 
behavioral health 
providers that serve Medicaid managed care enrollees. 
providers serving 
New Mexico has 2,665 licensed behavioral health providers that 
Medicaid managed 
serve nearly 670,000 Medicaid managed care enrollees 
care enrollees  Licensed providers are essential to meeting the behavioral health needs of 
enrollees.  Enrollees with serious mental illnesses or substance use disorders 
 
often require a team of providers that consist of several different types of 
licensed providers.  These providers include prescribing providers such as 
psychiatrists and advance practice nurses.  They also include other 
independently licensed providers, such as professional clinical counselors, 
clinical social workers, and marriage and family therapists.  Additionally, 
there are non-independently licensed providers that include social workers, 
registered nurses, and substance use counselors.  These providers generally 
cannot be directly reimbursed for their services and typically work under the 
supervision of an independently licensed provider.   
In total, New Mexico has 2,665 licensed behavioral health providers that 
serve its Medicaid managed care enrollees in 2017.  See Exhibit 1 for more 
detailed information about the number of licensed providers in New 
Mexico.    
Exhibit 1: Licensed behavioral health providers in New Mexico. 
  
Source: OIG analysis of State Medicaid data, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  6 
OEI-02-17-00490   
 
Many of the States licensed behavioral health providers do not 
serve Medicaid managed care enrollees  
Shortages of behavioral health providers are a problem that affects 
behavioral healthcare for all populations, not just for its managed care 
enrollees.18  A study of the New Mexico healthcare workforce found that 
9,528 behavioral health providers had active licenses in the State in 2016.19  
The smaller number of providers that we identifiedjust 2,665 providers or 
30 percentindicates that many behavioral health providers in New Mexico 
do not provide services to Medicaid managed care enrollees.  If only a small 
proportion of that workforce serves Medicaid enrollees, enrollees access to 
critical services can be impeded. 
More than half of New Mexicos counties have fewer than 2 licensed 
providers per 1,000 enrollees; all of these counties are rural or 
frontier 
The 2,665 licensed behavioral health providers are distributed unevenly 
across the State.  Notably, 19 of the States 33 counties have fewer than 
2 licensed behavioral health providers for every 1,000 Medicaid managed 
care enrollees.  All 19 of these counties are rural or frontier.20  This includes 
13 counties that have between 1 and 2 providers per 1,000 enrollees; 
3 counties that have fewer than 1 provider per 1,000 enrollees; and 
3 counties that have no providers at all.  In contrast, four countiesmost of 
them urbanhave much larger numbers of licensed providers per 1,000 
enrollees.  These 4 counties ranged from 6 to 19 providers per 1,000 
enrollees.  See Exhibit 2 and Appendix B for the number of licensed 
behavioral health providers by county. 
 
 
 
              ___________________________________________________________ 
18 Almost all of New Mexicos counties have a health professional shortage area for mental 
health.  For more information see Health Resources and Services Administration, Health 
Professional Shortage Areas Find.  Accessed at https://data.hrsa.gov/tools/shortage-
area/hpsa-find on May 24, 2019. 
19 Note that this analysis was mandated by the State of New Mexicos Legislature.  The 9,528 
providers identified in the study are the same types of providers that are included in our 
report.  See New Mexico Health Care Workforce Committee, 2017 Annual Report, October 1, 
2017.  Accessed at http://www.hsd.state.nm.us/uploads/PressRelease/2f473c 
14ee654f868b5a25b3cfd15a6d/NMHCWF_2017Report_eDist_LoRes.pdf on April 25, 2019. 
20 New Mexico designates counties as urban, rural, or frontier.  Note that frontier counties 
have an average of 2.8 people per square mile, and rural counties have an average of 13.7 
people per square mile.        
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  7 
OEI-02-17-00490   
 
Exhibit 2: Distribution of licensed behavioral health providers in New Mexico.   
 
Source: OIG analysis of State Medicaid data, 2019. 
 
Rural and frontier counties have disproportionately fewer licensed providers 
than urban counties.  Only 29 percent of licensed providers are located in 
rural and frontier counties, even though nearly half of the States Medicaid 
managed care enrollees reside in these counties.  Further, rural and frontier 
counties have a median of 1.8 providers and 1.5 providers per 
1,000 Medicaid managed care enrollees, respectively.  In contrast, urban 
counties have a median of 6.4 providers.  See Exhibit 3. 
Similarly, rural and frontier counties have disproportionately fewer 
behavioral health prescribers.  Ten frontier countieswith a total of 27,000 
Medicaid managed care enrolleeshave no prescribers.  Further, rural and 
frontier counties have a median of 0.2 prescribers and 0.0 prescribers per 
1,000 Medicaid managed care enrollees, while urban counties have a 
median of 0.7 prescribers.  
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  8 
OEI-02-17-00490   
 
Exhibit 3:  Rural and frontier counties have a lower median number of 
providers and prescribers. 
Median Number of  Median Number of Prescribing 
Behavioral Health Providers  Behavioral Health  Providers 
County Type  per 1,000 Enrollees  per 1,000 Enrollees 
   Urban   6.4  0.7 
   Rural   1.8  0.2 
   Frontier   1.5  0.0 
Source:  OIG analysis of State Medicaid data, 2019. 
 
Most behavioral  Sixty-two percent of the States licensed behavioral health providers serving 
Medicaid enrollees work in BHOs.21  These organizations play a unique role  
health providers 
in the States behavioral health system 
work in behavioral 
because they are responsible for 
health  coordinating care and providing essential 
organizations;  services to managed care enrollees who 
have serious mental illnesses, severe 
however, these 
emotional disturbances, or dependence on 
organizations report 
alcohol or drugs.  BHOs are core providers 
challenges with  typically offering behavioral health services 
to the States Medicaid enrollees as well as 
finding and 
uninsured residents.22   
retaining staff 
Notably, 38 of the 53 selected BHOs report that they need additional staff 
  to meet the needs of Medicaid managed care enrollees in their area.  They 
report particularly needing prescribing providers and providers that 
specialize in treating substance use disorders.  Of these BHOs, one in three 
did not have a prescriber on staff.  Additionally, two in three BHOs did not 
have a provider specializing in substance use disorders on staff.  Most of the 
BHOs in need of additional staff are located in rural and frontier areas. 
BHOs further note that staffing challenges affect enrollees with all types of 
diagnoses.  As one BHO states, there are far more requests for services 
beyond staff capacity.   
BHOs also highlight challenges with finding and retaining qualified staff to 
meet the needs of enrollees.  Several cite an overall lack of licensed 
providers in the State or their area to meet the demands of the population, 
              ___________________________________________________________ 
21 The remaining providers work in group or independent practices, other outpatient settings, 
or inpatient facilities. 
22 As noted earlier, BHOs include federally qualified health centers, core service agencies, 
community mental health centers, behavioral health agencies, and rural health clinics. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  9 
OEI-02-17-00490   
 
as well as challenges maintaining a highly trained workforce.  According to 
several BHOs, there is an extremely limited pool of qualified candidates, and 
when they do find qualified candidates, it can be difficult to retain them.  
This challenge particularly affects rural and frontier BHOs.  As one BHO 
explains, It is difficult to find and hire therapists in [rural] New Mexico...it is 
really difficult work with a high burnout rate.  Therapists from other areas, 
[who are not familiar with the specific needs of the community], do not last.  
 
Behavioral health  BHOs provide essential behavioral health services to Medicaid managed 
care enrollees.  Yet, many BHOs report that Medicaid managed care 
organizations 
enrollees have difficulty accessing the full range of behavioral health 
cannot always 
services at the frequency they need.  BHOs further report difficulty providing 
ensure timely access  timely appointments for 
enrollees, and some BHOs 
for enrollees 
maintain wait lists for certain 
seeking behavioral 
services.  Providing timely 
health services 
access to behavioral health 
services is important to 
ensuring positive health 
outcomes and to ensuring 
that patients behavioral 
health conditions do not go untreated.  
More than half of BHOs are not able to offer timely appointments 
for enrollees  
Most BHOs (29 of 53) report that they do not have urgent appointments 
available within 24 hours or routine appointments available within 14 days 
with providers in their BHO for Medicaid managed care enrollees.    
According to New Mexicos standards, appointments for urgent conditions 
must be available within 24 hours and appointments for routine behavioral 
healthcare must be available within 14 days.23  See Appendix C for more 
detailed information about the number of BHOs that are not able to offer 
timely urgent or timely routine appointments.   
 
              ___________________________________________________________ 
23 NMAC 8.308.2.12 (E), (F).    
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  10 
OEI-02-17-00490   
 
 
 
Notably, 23 of 53 BHOs are unable to provide urgent appointments with 
prescribers in their BHOs within 24 hours.  Twenty of these BHOs do not 
have prescribers on staff.24  The other three have wait times for urgent 
appointments with prescribers that range from 2 days to 21 days.  At the 
same time, four BHOs are unable to provide urgent appointments with non-
prescribers in their BHO within 24 hours.  For these BHOs, wait times with 
non-prescribers range from 2 days to 7 days. 
In addition, 25 of 53 BHOs are unable to provide routine appointments with 
prescribers in their BHOs within the 14 days as established by New Mexicos 
standards.  For the BHOs with prescribers on staff, wait times for routine 
appointments range from 20 days to 90 days.  Four BHOs are unable to 
provide routine appointments with non-prescribers in their BHO within 14 
days.  For these BHOs, wait times for non-prescribers range from 30 days to 
75 days. 
Some BHOs maintain wait lists for certain behavioral health services 
If the BHO is at capacity, it may have to maintain a wait list until services 
become available.  Fourteen BHOs report having maintained a wait list in 
the past year for at least one of 
the services they provide.  Most  We are not supposed to have 
commonly, they had wait lists for  a wait list, but the reality is 
certain outpatient services such as  that at different times 
substance abuse treatment or  providers have had to use a 
counseling and therapy.  Four BHOs  wait list because of workforce 
had a wait list for up to one month; an  issues. 
additional six BHOs had a wait list for  -BHO Administrator 
longer.  BHOs report that wait lists 
particularly affect services for beneficiaries with autism spectrum disorder, 
depression, and substance use disorder.    
 
              ___________________________________________________________ 
24 BHOs may provide appointments by arranging services with others providers who are not 
on their staff.  
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  11 
OEI-02-17-00490   
 
BHOs report that transportation is a challenge to ensuring access to 
timely services 
A number of BHOs (9 of 53) highlight challenges with accessing 
nonemergency medical transportation, despite New Mexicos requirement 
that its Medicaid managed care organizations provide such transportation 
to enrollees who need it.25  For example, one stakeholder notes that there 
are no nonemergency medical transportation providers in the area that 
offer service in the evening, making it particularly difficult for enrollees to 
access intensive outpatient substance abuse counseling services, which are 
often held in the evening.  A few BHOs also note that difficulty accessing 
nonemergency medical transportation causes delays in care.  For example, 
one BHOs notes, [non-emergency medical transportation] has to be 
scheduled, and sometimes that takes a few days for approval.  The patient is 
then seen a week after their initial scheduled appointment. 
 
Behavioral health  BHOs arrange services or make referrals for services that enrollees need but 
that BHOs do notor currently cannotprovide.  Enrollees with mental 
organizations report 
health and substance use issues need a range of services that include:   
difficulty arranging 
recovery and support services; non-intensive outpatient services; intensive 
or making referrals  outpatient services; and inpatient and residential services.  BHOs report 
difficulty arranging behavioral health services in each category to meet the 
for services that 
needs of Medicaid managed care enrollees.  See Exhibit 4 for a description 
they do not provide 
of the different service categories and Appendix D for the number of BHOs 
 
that report having difficulty arranging each service.    
 
 
 
 
 
 
 
              ___________________________________________________________ 
25 New Mexico requires that Medicaid managed care organizations provide nonemergency 
medical transportation for enrollees who have no other means of transportation and need to 
get to and from medical services, including behavioral health services.  NMAC 8.308.2.12 (P). 
New Mexicos managed care organizations contract with providers to offer nonemergency 
medical transportation services to enrollees.  New Mexico Human Services Department, 
Centennial Care Waiver Demonstration: Section 1115 Quarterly Report, March 2, 2018.  
Accessed at http://www.hsd.state.nm.us/uploads/files/Public%20Information 
/Centennial%20Care/Quarterly%20Reports/2017%20Quarterly%20Progress%20Reports/Final
%20Report(2).pdf on February 15, 2019.    
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  12 
OEI-02-17-00490   
 
Exhibit 4:  Behavioral health services includes a variety of services that 
are generally organized into four categories.  
 
 S  ource: OIG analysis of State documentation on behavioral health services, 2019. 
 
BHOs most commonly (43 of 53) report having difficulty arranging recovery 
and support services for Medicaid managed care enrollees.  BHOs explain 
that provider shortages make it difficult to make referrals and can result in 
enrollees not receiving the support and services that they need.  Notably, 
BHOs report difficulty arranging psychosocial rehabilitation services that 
help enrollees develop coping strategies, as well as respite care that 
provides short-term relief for primary caregivers.  As one BHO notes, these 
services are already provided by an extremely limited number of providers, 
which is continually shrinking.   
Most BHOs (42 of 53) also report having difficulty arranging intensive 
outpatient services.  This includes arranging applied behavior analysisa 
type of therapy that focuses on improving social skills and adaptive learning 
skills for enrollees with autism spectrum disorder.  As one rural BHO 
explains, there are no providers that offer this type of therapy in the five 
neighboring counties, making it extremely difficult to arrange these services 
for enrollees.  As a result, enrollees may need to travel long distances to the 
nearest provider.  Another rural BHO adds that its nearest autism care 
provider is 4 hours away.    
Similarly, most BHOs (39 of 53) report difficulty arranging inpatient and 
residential services.  In particular, some BHOs note that there are a lack of 
inpatient psychiatric facilities and detox facilities.  One stakeholder notes 
that, as a result, it is a long, long wait to get enrollees into inpatient 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  13 
OEI-02-17-00490   
 
psychiatric treatment, and it is even more difficult to secure inpatient 
psychiatric treatment for a child.  Further, these facilities may be far away.  
According to this stakeholder, the nearest child inpatient psychiatric 
treatment facility is 200 miles away.  Another stakeholder notes that many 
of the inpatient facilities for substance use disorders will not accept 
enrollees on any medication, often only accept men, and [will] not accept 
anyone with mental health diagnoses.  This clearly leaves many enrollees 
without care. 
Further, many BHOs (33 of 53) report having difficulty arranging non-
intensive outpatient services.  Nearly half have difficulty arranging 
medication assisted treatment to treat opioid addiction, such as 
buprenorphine.  BHOs also attribute this difficulty to the lack of providers.  
As one provider notes, the number of medication assisted treatment 
providers in one of the larger urban areas needs to double in size in order 
to meet current enrollee needs.  BHOs also highlight difficulty arranging day 
treatmentservices that focus on improving functional and behavioral 
deficitsand note a lack of providers offering these services.   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  14 
OEI-02-17-00490   
 
Behavioral health  Continuity of care is particularly important for patients with behavioral 
health diagnoses because they may require treatment from a number of 
organizations report 
providers for extended periods of time.26  Continuity of care includes 
challenges with 
maintaining care when transferring from one setting to another, seeing the 
continuity of care,  same provider each visit at the BHO, and exchanging health information 
throughout the continuum of care.  BHOs report a number of concerns 
citing limited care 
about continuity of care for Medicaid managed care enrollees. 
coordination, 
provider shortages,  Enrollees care is not always maintained during transitions, due in 
and barriers to  part to limited coordination among providers 
More than half of BHOs (29 of 53) 
sharing health 
report that enrollees care is not always  A few BHOs use warm handoffs to   
information  
maintained when they are transferred  promote continuity of care 
from one level of care to another.  
 
Warm handoffs occur between two 
Breakdowns during transitions of care 
healthcare providers when a 
  can cause confusion regarding 
patient is being transferred from 
treatment plans, duplicative testing, 
  one setting to another.  In addition 
discrepancies in medications, and 
to in-person communication 
missed appointments.27    
between providers, the patient is 
A number of BHOs report difficulties  also included in the discussion 
with coordinating enrollees care during  about his or her plan of care.  This 
transitions.  One BHO notes that  helps to build relationships 
constant provider turnover results in  between care coordinators, 
enrollees not effectively transitioning to  providers, patients, and their 
other care providers, causing a  families and provide opportunities 
significant proportion of these enrollees  to clarify or correct information.   
to leave care altogether.  Another 
 
stakeholder notes that there is a lack of coordinated care for enrollees who 
need both mental health services and service s for substance use disorders.  
Many of these enrollees must see multiple behavioral health providers to 
meet their needs, and those providers do not always coordinate patients 
care.  
              ___________________________________________________________ 
26 Institute of Medicine Committee on Crossing the Quality Chasm, Coordinating Care for 
Better Mental, Substance-Use, and General Health, 2006.  Accessed at 
https://www.ncbi.nlm.nih.gov/books/NBK19833/ on March 27, 2019.  See also Biringer et al., 
Continuity of Care as Experienced by Mental Health Service Users: A Qualitative Study, 
November 21, 2017.  Accessed at https://bmchealthservres.biomedcentral.com 
/articles/10.1186/s12913-017-2719-9 on March 27, 2019. 
27 Although BHOs strive to provide coordinated care, some types of BHOs are required to do 
so.  See CareLink NM, CareLink NM Health Homes: Provider Policy Manual, 2018.  Accessed at 
https://www.hsd.state.nm.us/uploads/files/Providers/Manuals%20and%20Guides/Managed%
20Care%20Policy%20Manual/CLNM%20Pol%20Manual%2012_28_18.pdf on June 11, 2019.  
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  15 
OEI-02-17-00490   
 
A few BHOs also note that the lack of integration between primary and 
behavioral healthcare acts as a barrier to coordination efforts.  Integrating 
primary and behavioral healthcarewhich typically involves close 
collaboration of both physical and behavioral health providers in the same 
locationcan be critical, since certain behavioral health disorders carry 
higher incidences of physical issues, including obesity, diabetes, asthma, 
migraines, heart disease and cancers.28   
Enrollees are not always able to see the same providers,  
often because of a lack of providers or high turnover 
One-third of BHOs (17 of 53) report that enrollees cannot always see the 
same provider as the previous visit for the same service.  Ongoing 
relationships with the same provider create stable conditions for enrollees; 
changes in providers can often create setbacks in treatment, and can 
sometimes give rise to anxiety, frustration, and a sense of being rejected.29  
A few BHOs highlight the importance of engaging in and maintaining such 
relationships to improve health 
  Part of [ensuring continuity of 
outcomes.  As one provider 
care] is you have to keep people 
notes, enrollees are scheduled 
in the workforce.  You can see a 
with the same provider...which 
provider more than oncethat 
ensures sustained recovery. 
is really criticalit can be done.   
BHOs find that a lack of providers 
-  Key Stakeholder           
limits their ability to keep 
enrollees with the same provider.  For example, according to one BHO, 
more patients are being seen in psychiatric emergency services because of 
the lack of community providers, resulting in continuity of care issues.  
Some BHOs also state that staff turnover results in some enrollees being 
unable to continue with the same provider, which affects enrollees health 
outcomes.  For example, a rural provider, who focuses on treatment for 
autism spectrum disorder, notes that turnover impacts a childs long-term 
outcomes since each new provider has to build a rapport with the child and 
learn the childs complex treatment plan.   
Enrollee health information is not always communicated because of 
barriers to sharing enrollee health information across providers  
Half of BHOs (26 of 53) report that enrollees health information is not 
always communicated in an effective and timely manner throughout their 
              ___________________________________________________________ 
28 The Colorado Health Foundation, The Colorado Blueprint for Promoting Integrated Care 
Sustainability, March 2012.  Accessed at https://www.integration.samhsa.gov/ 
TCHF_IntegratedCareReport.pdf on January 8, 2019.  
29 Biringer et al., Continuity of Care as Experienced by Mental Health Service Users: A 
Qualitative Study, November 21, 2017.  Accessed at https://bmchealthservres 
.biomedcentral.com/articles/10.1186/s12913-017-2719-9 on March 27, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  16 
OEI-02-17-00490   
 
continuum of care.  Sharing health information helps coordinate care 
among different providers and across different settings.  It also helps 
providers reduce unnecessary testing, avoid medication errors, and 
decrease administrative costs.30  Electronic health record (EHR) systems can 
be a critical tool for supporting seamless and instantaneous health 
information exchanges across providers when those providers EHR systems 
are interoperable (able to exchange information). 
Many BHOs (26 of 53) use EHRs, and find that using EHRs helps them to 
improve services for enrollees.  According to one BHO, its EHRs provide 
quicker access to health 
  [EHRs] improve continuity of 
information and improves its 
care for patients with multiple 
ability to share records with 
providers, maintain updated 
providers and ensure continuity 
information, document patients 
of care.  Some BHOs further note 
past records, and track patients 
that their EHRs enable providers 
recovery goals and 
to collaborate across behavioral 
interventions.   
health disciplines and with 
-  BHO Administrator           
primary healthcare providers.   
Despite the advantages of EHRs, some BHOs (13 of 52) have not adopted 
EHRs.31  Nearly all of these BHOs are rural.  Rural providers face a unique set 
of barriers to implementing EHRs, such as difficulty connecting to 
broadband service.  Broadband is high-speed internet access, and is needed 
to support EHRs and other health information technology services such as 
telehealth.32  In New Mexico, only 47 percent of people in rural areas have 
access to advanced broadband, compared to 95 percent of people in urban 
areas.33  Other barriers to implementing EHRs include a lack of expertise on 
how to use such technology and what some BHOs perceive to be 
prohibitive startup costs.  One stakeholder further explains, it is difficult for 
provider organizations, unless they are very large and have sufficient scale, 
to afford the cost of an EHR.     
              ___________________________________________________________ 
30 Office of National Coordinator for Health Information Technology (ONC), Why is health 
information exchange important?, March 21, 2018.  Accessed at 
https://www.healthit.gov/faq/why-health-information-exchange-important on March 18, 
2019. 
31 For information on nationwide BHO adoption of health information technology, see 
National Council for Community Behavioral Healthcare, HIT Adoption and Readiness for 
Meaningful Use in Community Behavioral Health, June 2012.  Accessed at 
https://www.thenationalcouncil.org/wp-content/uploads/2012/10/HIT-Survey-Full-Report.pdf 
on May 3, 2019.     
32 ONC, Federal Health IT Strategic Plan: 2015-2020.  Accessed at https://www.healthit 
.gov/sites/default/files/9-5-federalhealthitstratplanfinal_0.pdf on May 3, 2019.  
33 Federal Communications Commission, 2018 Communications Marketplace Report: 
Broadband Deployment Appendices, December 31, 2017.  Accessed at 
https://docs.fcc.gov/public/attachments/FCC-18-181A9.pdf on March 21, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  17 
OEI-02-17-00490   
 
Other BHOs note that the lack of interoperability between their EHR systems 
and other providers systems presents problems.  Interoperability allows 
unrelated records systems to exchange electronic health information.  As 
one BHO explains, not enough providers in the area can accept and share 
information with other providers EHR systems.  Such barriers to 
interoperability can constrain BHOs ability to share health information and 
coordinate care among different providers and across different settings.   
Several BHOs also note difficulty with getting enrollee health information 
from certain types of providers.  New Mexico operates a health information 
exchange (HIE)a platform through which participating providers can share 
health information.  The HIE has the potential to enable providers to share 
information about enrollees demographics, diagnoses, medications, 
encounter history, procedures, and even clinical notes.  However, there are 
only a small number of behavioral health providers that participate in the 
States HIE.  While the HIE is available to all providers, as one stakeholder 
notes, providers without EHRs are unable to participate in the HIE.  
 
Behavioral health  Although BHOs report a number of challenges with the availability of 
behavioral health services, they also cite a number of promising initiatives.  
organizations 
BHOs have adopted these initiatives to varying degrees.  These initiatives 
highlight promising 
increase the availability of services by improving access to providers, better 
initiatives to  coordinating enrollee care, and expanding the use of technology to deliver 
increase the  services. 
availability of 
Exhibit 5:  Initiatives to increase the availability of behavioral health 
services, including  services.  
open-access 
scheduling, 
treatment first, care 
integration, and 
telehealth  
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  18 
OEI-02-17-00490   
 
Many BHOs find that open-access scheduling improves the 
availability of services 
Many BHOs (34 of 53) have implemented open-access scheduling or walk-
in availability.  Open-accessalso known as advanced access and same-day 
schedulingis a method of scheduling in which patients can receive an 
appointment on the day they call.  Rather than booking each providers full 
block of time weeks or even months in advance, this 
We can see 90  model leaves part of the day open for unscheduled 
percent of our  visits.  Another part of the schedule is booked only 
clients within 24  with clinically necessary follow-up visits and 
hours of placing a  appointments for patients who chose not to come on 
call.  the day they called.  BHOs implement open-access 
scheduling in a variety of ways.  For example, one BHO 
-  BHO Administrator 
reserves a few same-day appointments throughout the week, whereas 
another reserves one day per week for same-day appointments. 
All 34 BHOs that have implemented this type of scheduling report that it 
has improved the availability of services for managed care enrollees.  These 
BHOs commonly note that such initiatives immediately address crisis 
situations, with one BHO noting that anything urgent or emergency can be 
seen immediately, or on the same day.  Several BHOs further note that 
these initiatives can potentially decrease the need for higher levels of care 
or hospitalization, as well as improve enrollee health outcomes.  Another 
BHO notes that open-access not only increases access to services, it also 
decreases the number of no-show appointments.  
The Treat First Clinical Model allows faster access to services 
About half of the BHOs (25 of 53) have adopted the clinical model referred 
to as Treat First.  Developed for New Mexico in March 2016, Treat First is 
designed to improve access to care by prioritizing treatment and reducing 
State assessment requirements.34  Previously, the State required that the 
results of a comprehensive assessment and treatment plan for each new 
patient be submitted within 30 days of the first visit, emphasizing the 
assessment over treatment.  Treat First allows for up to four encounters with 
a provisional diagnosis without a comprehensive assessment and treatment 
plan.   
Almost all BHOs that have adopted this model of care (21 of 25 BHOs) 
report that it has improved the availability of services for managed care 
enrollees.  According to one BHO, Treat First enrollees have easier and more 
immediate access to services, leading to increased patient satisfaction and 
              ___________________________________________________________ 
34 Medical Assistance Division, Letter of Direction #57: Treat First Model Extension, August 
25, 2016.  Accessed at https://www.hsd.state.nm.us/uploads/FileLinks/c06b4701fbc8 
4ea3938e646301d8c950/LOD_%2357___Treat_First_Model_Extension___08.25.2016.pdf on 
June 10, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  19 
OEI-02-17-00490   
 
better rapport with the clinicians as well as reduced paperwork and less staff 
burnout among providers.  In addition, stakeholders report that Treat First 
has resulted in a decrease in the number of enrollees that are no-shows for 
the next scheduled appointment, which they attribute to being able to 
begin treatment during the enrollees first visit. 
CareLink Health Homes Program helps to integrate physical and 
behavioral healthcare 
In total, eight BHOs participate in New Mexicos CareLink Health Homes 
Program, which is an integrated healthcare service program.35  The program 
provides a monthly capitated payment per eligible enrollee to each 
participating BHO.  Each BHO agrees to serve as a health home and is 
responsible for providing and coordinating the physical and behavioral 
healthcare for the enrollee.  The health home is also required to provide 
additional services, including comprehensive care management and 
referrals to community and social support services.  Each health home must 
also measure and report on specific quality indicators.   
According to one BHO that currently participates in CareLink, it is better 
able to connect enrollees with services outside their agency and address 
conditions causing hospitalization.  Other BHOs add that coordination of 
care between behavioral health and primary care is improved by more 
frequent contact between enrollees and providers.  This coordination 
increases access to services and improves medication compliance, which 
can improve overall health outcomes.   
Many BHOs find that telehealth improves availability of services  
Telehealth uses internet and communications technologies such as 
videoconferencing, chat, and text messaging, to provide health information 
and treatments in real time.  
Thirty BHOs report having 
We would not be able to 
implemented telehealth in 
serve 90% of the families 
some way.  Several BHOs 
we currently serve without 
report using telehealth for 
telehealth. 
assessments, and many BHOs 
- BHO Administrator 
report also providing 
. 
medication management and 
psychiatric services through telehealth.  All 30 BHOs note that implementing 
telehealth has improved the availability of services for Medicaid managed 
care enrollees.  According to one BHO that implemented telepsychiatry, this 
              ___________________________________________________________ 
35 Four additional BHOs that are not in our sample also participate in CareLink.  CareLink is 
for Medicaid behavioral health beneficiaries with a primary condition of Serious Mental Illness 
and/or Severe Emotional Disturbance.  See New Mexico Human Services Department, 
CareLink NM Health Homes.  Accessed at http://www.hsd.state.nm.us/health-homes.aspx on 
April 5, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  20 
OEI-02-17-00490   
 
initiative increases its ability to 
Project ECHO: Extension for 
offer more stable outpatient 
Community Healthcare Outcomes 
medication management because 
of an increased pool of qualified  In addition to providing services to 
staff.36  Another BHO highlights  enrollees, telehealth can also be 
the value of using telehealth for  used to train and supervise 
assessments, noting that it has  providers.  New Mexicos Project 
opened up time for our therapists  ECHO uses teleconferencing to 
to provide more time for  increase the availability of specialty 
individual therapy and group  care in behavioral health.  The 
therapy, reducing wait times and  model links specialist teams with 
increasing access to services.    behavioral health providers in the 
community.  Behavioral health 
Telehealth can offer particular 
providers become part of a learning 
benefits for enrollees located in 
community, where they receive 
remote locations.  According to 
mentoring and feedback from 
one BHO, its telehealth initiative 
specialists.  This model is now used 
has allowed it to spend less time 
in both urban and rural areas, and 
and resources recruiting local 
includes training on how to treat 
providers in rural and frontier 
both mental and substance use 
clinic sites, allowing for better 
disorders.   
continuity of care and increased 
access to psychiatric and   
counseling services.  One provider adds that telehealth has been critical in 
 
establishing care for families in rural and underserved areas. 
At the same time, several BHOs note the limitations of telehealth.  First, 
enrollees sometimes have limited receptiveness to telehealth.  As one 
stakeholder points out, some enrollees do not feel comfortable with sharing 
their problems openly through technology.    
Second, many rural and frontier areas have limited broadband connectivity.  
As one BHO explains, the internet service for enrollees that live in remote 
areas is sometimes not capable of sustaining a good connection for 
telehealth.  Another provider further comments: Telehealth has improved 
access tremendously.  However, many communities in need of services 
either do not have internet access in their rural area or cannot afford to pay 
for the service.  Research indicates that internet access remains a challenge 
to rural telehealth; as mentioned earlier, rural areas in New Mexico have less 
              ___________________________________________________________ 
36 New Mexico is one of nine States as of 2017 where medical boards issue telehealth-specific 
licenses or certificates that allow out-of-State providers to furnish telehealth services in a 
State that they are not located.  See University of Michigan: Behavioral Health Workforce 
Research Center, The Use of Telehealth Within Behavioral Health Settings: Utilization, 
Opportunities, and Challenges, March 2018.  Accessed at http://www.behavioralhealth 
workforce.org/wp-content/uploads/2018/05/Telehealth-Full-Paper_5.17.18-clean.pdf on April 
3, 2018. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  21 
OEI-02-17-00490   
 
access to broadbanda factor that limits the types of telehealth services 
available to them via a home internet connection.  
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  22 
OEI-02-17-00490   
 
CONCLUSION AND RECOMMENDATIONS 
Concerns exist about the availability of behavioral health serviceswhich 
includes treatments and services for mental health and substance use 
disordersfor enrollees in Medicaid managed care.  The need for such 
services is particularly pronounced in New Mexicoa State that has among 
the highest rates for suicide and deaths from overdose in the Nation.   
Many counties in New Mexico have few licensed behavioral health providers 
serving Medicaid managed care enrollees.  These behavioral health 
providers are unevenly distributed across the State, with rural and frontier 
counties having disproportionately fewer providers and prescribers.  
Notably, only 29 percent of the States licensed providers are in rural and 
frontier counties, despite nearly half of the States Medicaid managed care 
enrollees residing in these counties.  Further, a significant number of New 
Mexicos licensed behavioral health providers do not provide services to 
Medicaid managed care enrollees.  
Additionally, most of the States licensed behavioral health providers work in 
BHOswhich include federally qualified health centers and community 
mental health centers; however, BHOs report challenges with finding and 
retaining staff, as well as ensuring transportation for enrollees.  As a result, 
these organizations cannot always ensure timely access for enrollees 
seeking behavioral health services.  These organizations also report difficulty 
arranging or making referrals for services that they do notor currently 
cannotprovide.  In addition, they report challenges with continuity of care 
for enrollees, citing limited care coordination, provider shortages, and 
barriers to sharing health information. 
Nonetheless, BHOs highlight promising initiatives that increase the 
availability of behavioral health services for Medicaid managed care 
enrollees, including open-access scheduling, treatment first, care 
integration, and telehealth.  These initiatives increase the availability of 
behavioral health services by improving access to providers, coordinating 
enrollee care, and expanding the use of technology.  In addition, New 
Mexico recently announced its intention to raise certain provider payment 
rates.37 
Although this report focuses on New Mexico, it provides insights into  
challenges that are likely shared by other States providing behavioral health 
services to Medicaid enrollees, especially in rural and frontier counties. 
These challengesincluding provider shortages and limited availability of 
behavioral healthrequire attention not only at the State level, but at the 
              ___________________________________________________________ 
37 New Mexico Human Services Department.  Accessed at https://www.hsd.state.nm.us/ 
uploads/PressRelease/2f473c14ee654f868b5a25b3cfd15a6d/FY20_RateIncrease_PubNotice_FI
NAL.pdf on July 3, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  23 
OEI-02-17-00490   
 
national level as well.  These challenges are particularly heightened as 
Medicaid agencies continue to be on the front lines of fighting opioid abuse 
and in ensuring that appropriate behavioral health services are available. 
On the basis of the findings of this report, we recommend that the Centers 
for Medicare & Medicaid Services (CMS):   
Identify States that have limited availability of behavioral health 
services and develop strategies and share information to ensure 
that Medicaid managed care enrollees have timely access to these 
services   
CMS should identify Statesin addition to New Mexicothat have limited 
availability of behavioral health services for Medicaid managed care 
enrollees.  CMS should work with these States to develop strategies to 
ensure that enrollees have timely access to behavioral health services.  CMS 
should particularly focus on these challenges in rural and frontier areas.  
CMS should build on its existing efforts to provide technical assistance and 
share best practices and lessons learned from States experiences.  As a part 
of its efforts, CMS should work to ensure that States are monitoring the 
numbers and locations of behavioral health providers and that States are 
identifying any barriers that impede access to behavioral healthcare.  For 
example, CMS could encourage States to monitor whether there are 
shortages of specific types of behavioral health providers, such as substance 
use counselors or psychiatrists.  To encourage information sharing, CMS 
could identify any promising practices that other States have developed.  
CMS could then share this information with Statessuch as through case 
studies, tool kits, and other methods.   
We also recommend that the New Mexico Human Services Department:   
Expand New Mexicos behavioral health workforce that serves 
Medicaid managed care enrollees 
Having a sufficient number of behavioral health providers that serve 
Medicaid managed care enrollees in New Mexico is essential to improving 
the availability of services to this population.  To achieve this, the New 
Mexico Human Services Department should: 
  Take steps to expand New Mexicos overall behavioral 
health workforce.  To address workforce shortages of 
behavioral health providers, New Mexico should implement 
initiatives to recruit and retain additional behavioral health 
providers.  For example, New Mexico could look to other States 
initiatives, including internship opportunities in behavioral health 
fields and market to both in-State and out-of-State candidates.  
New Mexico could also encourage non-licensed providers to 
pursue licensure.  New Mexico should particularly target these 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  24 
OEI-02-17-00490   
 
efforts towards developing its behavioral health workforce in 
rural and frontier counties. 
  Increase behavioral health providers participation in 
Medicaid managed care.  A significant number of New 
Mexicos licensed behavioral health providers do not provide 
services to Medicaid managed care enrollees.  New Mexico 
should develop initiatives to encourage more of its existing 
behavioral health workforce to serve Medicaid managed care 
enrollees.  Such initiatives could include initiatives implemented 
by other States, such as periodic reviews of licensure 
requirements and reimbursement rates, direct outreach to 
providers, and simplification of administrative requirements.   
Improve access to behavioral health services 
Improving access to services is another essential element for bolstering 
services for Medicaid managed care enrollees.  To achieve this, the New 
Mexico Human Services Department should: 
  Review its standards governing access to care and 
determine whether additional standards are needed for 
behavioral health providers.  New Mexico should determine 
whether its managed care organizations are meeting the existing 
State standards that apply to behavioral health providers.  It 
should also evaluate whether any changes to its existing 
standards are needed in order to better meet the behavioral 
health needs of their Medicaid managed care enrollees. 
  Improve access to transportation for Medicaid 
managed care enrollees needing behavioral health 
services.  Transportation to medical care is essential for 
Medicaid managed care enrollees who have limited means of 
transport to and from needed behavioral health services.  New 
Mexico should first take steps to determine if managed care 
organizations are meeting their contractual obligations and to 
identify any challenges with nonemergency medical 
transportation.  It should then work with its managed care 
organizations to develop initiatives to provide improved 
nonemergency medical transportation to enrollees.  It should 
identify these initiatives and effective practices by reviewing the 
approaches taken by other States to improve the availability of 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  25 
OEI-02-17-00490   
 
transportation services.38  These initiatives should include 
working with the managed care organizations to review their 
networks of nonemergency medical transportation providers 
and looking for ways to expand the number of providers, such 
as coordinating with local organizations.   
  Work with State partners to strengthen access to high-
speed, reliable, and secure communications 
technologies in rural and frontier counties.  High-speed, 
reliable, and secure communications technology is needed for 
healthcare providers and enrollees to benefit from EHRs and 
other health information technology services such as telehealth.  
A lack of access to connectivity with sufficient bandwidth 
speedssuch as broadband connectivityremains a significant 
barrier faced by rural providers.  New Mexico should strengthen 
broadband access, particularly in rural and frontier counties.  
New Mexico should work with other State partners to look for 
opportunities to attract additional broadband service providers 
to communities that are currently without access to broadband.  
New Mexico should also pursue additional funding opportunities 
for broadband-related projects, including Federal programs that 
can fund projects related to broadband planning, public access, 
digital literacy, and deployment.39     
  Expand the use of telehealth to increase the availability 
of behavioral health services.  BHOs note that telehealth has 
improved the availability of services for Medicaid managed care 
enrollees, particularly those in rural and frontier areas.  New 
Mexico should expand the use of telehealth, as appropriate, to 
further increase the availability of services, particularly in rural 
and frontier areas.  To do this, the State should encourage 
adoption of telehealth, expand participation in Project Echo, and 
              ___________________________________________________________ 
38 CMS and the National Academies of Sciences, Engineering, and Medicine provide effective 
practices used by other States to address transportation issues.  See National Academies of 
Sciences, Engineering, and Medicine, Handbook for Examining the Effects of Non-Emergency 
Medical Transportation Brokerages on Transportation Coordination, October 22, 2018.  
Accessed at https://www.nap.edu/download/25184 on February 25, 2019; CMS, Medicaid 
State Plan Amendments.  Accessed at https://www.medicaid.gov/state-resource-
center/medicaid-state-plan-amendments/index.html on February 26, 2019; and, GAO, 
Nonemergency Medical Transportation: Updated Medicaid Guidance Could Help States, GAO-
16-238, February 2, 2016.  Accessed at https://www.gao.gov/assets/680/674934.pdf on 
February 7, 2019. 
39 For a list of Federal funding sources, including grants funded by the United States 
Department of Health and Human Services, see the Federal Communications Commission, 
Funding Broadband-Enabled Health Care.  Accessed at https://www.fcc.gov/general/funding-
broadband-enabled-health-care on May 6, 2019. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  26 
OEI-02-17-00490   
 
strengthen access to broadband to expand telehealth 
accessibility. 
Improve the effectiveness of behavioral health services 
Another key element of strengthening services for Medicaid managed care 
enrollees is to improve their effectiveness.  To achieve this, the New Mexico 
Human Services Department should: 
  Take steps to increase adoption of electronic health 
records (EHRs) and participation in the State Health 
Information Exchange (HIE) by behavioral health 
providers.  BHOs report that EHRs improve care for enrollees 
and enable providers to collaborate across behavioral health 
settings and with primary healthcare providers.  EHRs also allow 
providers to easily access patient information and in some cases 
to share that information with other providers.  EHRs are also 
needed to participate in the States HIE, which can provide 
information about enrollees diagnoses, medications, 
procedures, andin some casesclinical notes.  Some 
providers face challenges in adopting EHRs and participating in 
the State HIE including the prohibitive cost of many EHR systems 
and limited expertise on how to use such technology.  To 
address these challenges, New Mexico should work with 
providers in accessing assistance and resources that support 
behavioral health providers adoption and use of EHRs and 
encourage participation in the States HIE.40   
  Identify and share information about strategies to 
improve care coordination.  Coordination among behavioral 
health and other providers is especially important since certain 
behavioral disorders carry higher incidences of chronic physical 
illnesses.  BHOs report some challenges with finding providers 
and coordinating among providers, particularly when enrollees 
are transferred from one level of care to another.  New Mexico 
should identify and share information on strategies for improved 
care coordination among behavioral health and other 
providers.  For example, New Mexico should review other States 
strategies to promote coordinated care across various 
              ___________________________________________________________ 
40 An example of a resource that may be helpful is the Regional Extension Centers, which 
provide on-the-ground technical assistance for individual and small provider practices that 
lack resources to adopt and maintain EHRs.  Services include health information technology 
education and training, vendor selection consultation, and partnering with the State health 
information exchange.  For more information, see ONC, Regional Extension Centers (RECs), 
November 7, 2018.  Accessed at https://www.healthit.gov/topic/regional-extension-centers-
recs on March 7, 2019.  
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  27 
OEI-02-17-00490   
 
settings.  New Mexico should facilitate information sharing 
among its providersthrough the development of case studies, 
tool kits, and other methodsto encourage providers to use 
these strategies. 
  Expand initiatives to integrate behavioral and primary 
healthcare.  BHOs report that the increased integration 
between behavioral and primary healthcare can improve patient 
outcomes.  For example, CareLink health homes is New Mexicos 
integrated care model.  The goal of this model is to enhance the 
integration of behavioral and primary healthcare as well as other 
services.  New Mexico should assess the implementation of 
CareLink health homes and the value of integrating care.  On the 
basis of the results, it should refine and expand this model or 
consider other models of integrated care, if appropriate. 
  Share information about open-access scheduling and 
the Treat First Clinical Model and promote expansion.  
BHOs report that open-access scheduling and the Treat First 
Clinical Model help increase the availability of behavioral health 
services for Medicaid managed care enrollees.  New Mexico 
should share information with the BHOs that do not use these 
tools about the benefits identified by the BHOs that do use 
them.  New Mexico could also convene forums for BHOs to 
share strategies and technical assistance for successful 
implementation of these tools.     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  28 
OEI-02-17-00490   
 
AGENCY AND STATE COMMENTS AND OIG 
RESPONSE 
Both CMS and the New Mexico Human Services Department (the State) 
concurred with our recommendations.  We made one recommendation to 
CMS and 10 recommendations to the State.  
CMS concurred with our recommendation to identify States that have 
limited availability of behavioral health services and develop strategies and 
share information.  CMS stated that it will work with States that identify 
themselves as having behavioral health shortages and States that have 
managed care plans that do not meet the State defined standards of 
network adequacy.  CMS stated that it will provide technical assistance to 
those States by developing strategies and sharing information to ensure 
that Medicaid managed care enrollees have timely access to behavioral 
health services.  
The State concurred with our 10 recommendations that seek to expand the 
States behavioral health workforce, improve access to behavioral health 
services, and improve the effectiveness of behavioral health services.  
In response to the two recommendations that seek to expand the States 
behavioral health workforce, the State noted that it plans to, among other 
things, use Federal grants to increase behavioral health services provided in 
rural and frontier counties, while also implementing a Graduate Medical 
Education program for providers.  The State also implemented an increase 
of Medicaid rates for behavioral health providers and will continue to meet 
with the Regulation and Licensing Department to discuss the streamlining of 
licensing requirements and implementation of reciprocity for out-of-state 
providers who move to New Mexico.   
In response to the four recommendations that seek to improve access to 
behavioral health services, the State noted that it is in the process of 
promulgating a new rule for behavioral health.  It also stated that it plans to 
provide additional non-emergency medical transportation for the justice-
involved population upon their release.  To strengthen access to 
communication technologies, it stated that it plans to pursue additional 
funding for broadband coverage and work with other State agencies to 
endorse increased funding for broadband efforts.  It also stated that it will 
continue working with the State telehealth network to expand telehealth 
coverage.  
In response to the four recommendations that seek to improve the 
effectiveness of behavioral health services, the State plans to explore 
funding for connectivity and data transmission to increase behavioral health 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  29 
OEI-02-17-00490   
 
provider data sharing.  It also noted that it is currently in discussions with 
the States HIE to include behavioral health providers on the HIE.  The State 
also noted that it recently expanded the number of health homes to better 
integrate behavioral and primary healthcare.  Finally, the State added that it 
plans to collaborate with the New Mexico Behavioral Health Provider 
Association to increase the number of providers who are trained in the Treat 
First model.   
We appreciate CMSs and the States steps to address these important 
issues.  OIG urges both CMS and the State to continue their work in this 
area to ensure timely access to behavioral health services for Medicaid 
managed care enrollees. 
For the full text of CMSs comments, see Appendix E.  For the full text of the 
New Mexico Human Services Departments comments, see Appendix F. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  30 
OEI-02-17-00490   
 
APPENDIX A:  Detailed Methodology 
We based this study on analyses of Medicaid managed care data from the 
State and on survey data from selected BHOs.  We also conducted 
interviews with selected behavioral health providers, State Medicaid agency 
officials, and key stakeholders. 
State Medicaid managed care data 
We requested data from the State Medicaid Agency to determine the 
number and type of licensed behavioral health providers that serve the 
States managed care enrollees.  Using these data, we developed a list of all 
unique providers listed on at least one behavioral health claim during the 
period of January 1, 2017, through December 31, 2017. 
For each of these providers, we requested information about their 
behavioral health specialty, their current enrollment status (i.e., active), and 
the primary county in which they provide servicesand whether that county 
was urban, rural, or frontier.41  We also requested information about the 
organizations where each of the providers work.   We then identified all 
unique active licensed behavioral health providers in the State, by county.42  
We included providers in the following three categories: 43  
  Independently licensed, prescribing behavioral health providers 
consist of psychiatrists (MD or DO with a psychiatric specialty), 
advanced practice nurses (i.e., clinical nurse specialists or clinical 
nurse practitioners with a psychiatric specialty), and licensed clinical 
psychologists (Ph.D., Psy.D. or Ed.D.) certified for prescribing. 
 
  Independently licensed, non-prescribing behavioral health providers 
consist of licensed clinical psychologists (Ph.D., Psy.D. or Ed.D.) not 
certified for prescribing, licensed independent or clinical social 
workers (LISW or LCSW), licensed professional clinical mental health 
counselors (LPCC), licensed professional mental health counselors 
              ___________________________________________________________ 
41 Note that providers may practice at multiple locations, including locations outside of their 
primary service county.  Further, we based our analysis on New Mexicos designation of 
urban, rural, and frontier counties.  Note that frontier counties have an average of 2.8 people 
per square mile, and rural counties have an average of 13.7 people per square mile.        
42 This analysis does not include out-of-State providers.  
43 In addition to the types of providers listed above, the State licenses other behavioral health 
providers, such as certified alcohol and drug abuse counselors (CADAC) and licensed 
physician assistants (PA) with a psychiatric specialty.  Note that if types of behavioral health 
providers are not included in the bullets above, there were no providers of these types in the 
2017 data. 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  31 
OEI-02-17-00490   
 
(LPC), licensed marriage and family therapists (LMFT), licensed 
professional art therapists (LPAT), and licensed alcohol and drug 
abuse counselors (LADAC).  
 
  Non-independently licensed behavioral health providers consist of 
licensed masters of social work (LMSW), licensed baccalaureates of 
social work (LBSW), licensed mental health counselors (LMHC), 
licensed associate marriage and family therapists (LAMFT), licensed 
substance abuse associates (LSAA), and registered nurses (RN) with 
a with a psychiatric specialty.  
We also requested the total number of Medicaid managed care enrollees by 
county in 2017.  Using these data, we determined the ratio of providers per 
1,000 Medicaid managed care enrollees for each county.  We also calculated 
the median ratio of providers and prescribers per 1,000 Medicaid managed 
care enrollees for urban, rural, and frontier counties.   
Finally, we identified the number of licensed behavioral health providers 
that work in BHOs.  Using the State data, we identified 351 BHOs that 
provide services to Medicaid managed care enrollees.  These included all 
BHOs that provided outpatient behavioral health services to Medicaid 
managed care enrollees from January 1, 2017, through December 31, 2017. 
Survey of behavioral health organizations   
We selected a purposive sample of BHOs to survey.  We included all BHOs 
designated as core service agencies because they are primary sources for 
comprehensive medical and support services for many Medicaid managed 
care enrollees in New Mexico.  We then selected up to two additional BHOs 
with the largest behavioral health expenditures in each county to ensure 
geographic representation.44  Finally, we included any additional BHOs that 
billed for more than $1 million in 2017.  In total, we selected 78 BHOs 
throughout the State. 
Next, we conducted a survey of each of the selected BHOs.  Our questions 
focused on the availability of behavioral health services for Medicaid 
managed care enrollees.  We asked about the availability of both urgent 
and routine appointments for enrollees seeking services at the BHO from 
both prescribing and non-prescribing providers.  We also asked about the 
extent to which BHOs maintain wait lists.  Additionally, we asked about the 
extent to which they have difficulty arranging services that they do not or 
currently cannot provide.  We also asked about any challenges with 
ensuring continuity of care, including maintaining care when transferring 
from one setting to another, seeing the same provider each visit, and 
exchanging health information throughout the continuum of care.  Lastly, 
we asked about challenges and promising initiatives for improving the 
              ___________________________________________________________ 
44 Five counties only had one BHO, and one county did not have a BHO. 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  32 
OEI-02-17-00490   
 
availability of behavioral health services.  We conducted the survey from 
August through November 2018.  We received responses from a total of 53 
BHOs in 27 of the 32 counties in New Mexico with a BHO.  Of these BHOs, 
16 were in urban counties, 20 were in rural counties, and 17 were in frontier 
counties.45   
Interviews with selected providers, State Medicaid officials and key 
stakeholders   
We conducted interviews with selected providers from the BHOs, officials 
from the States Medicaid managed care program, and key 
stakeholders.46  We asked the behavioral health providers about their 
experience working with Medicaid managed care enrollees and the 
availability of behavioral health services.  We conducted structured 
interviews with State Medicaid officials responsible for behavioral health 
services in the State and specific initiatives such as the Treat First Clinical 
Model.  Lastly, we conducted structured interviews with key stakeholders, 
including representatives from the Local Collaborative Alliance New Mexico, 
a group of organizations that support community participation in behavioral 
health services.  We focused our questions on the availability of behavioral 
health services for Medicaid managed care enrollees and on challenges and 
opportunities for improving the availability of behavioral health services in 
the State.   
              ___________________________________________________________ 
45 The 53 BHOs received more than $61 million in Medicaid managed care behavioral health 
expenditures in 2017.  This amounts to 50 percent of the expenditures received by all BHOs 
in that year. 
46 We asked each BHO to identify at least one provider who had the most experience 
working with Medicaid managed care enrollees.   
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  33 
OEI-02-17-00490   
 
APPENDIX B:  Number of Licensed Behavioral 
Health Providers That Serve Medicaid 
Managed Care Enrollees in New Mexico  
Exhibit B-1: Number of licensed behavioral health providers, by provider type, 2017  
  Total  Urban  Rural  Frontier 
Independently Licensed 
Prescribing Behavioral Health  328  227  69%  83  25%  18  6% 
Providers 
   Psychiatrists  202  151  75%  40  20%  11  5% 
   Advanced Practice Nurses*  94  52  55%  38  40%  4  4% 
   Prescribing Psychologists  32  24  75%  5  16%  3  9% 
Independently Licensed Non-
Prescribing Behavioral Health  1,872  1,346  72%  449  24%  77  4% 
Providers 
   Counselors and Therapists  976  682  70%  255  26%  39  4% 
   Social Workers  584  426  73%  131  22%  27  5% 
   Psychologists, Non-Prescribing  274  220  80%  45  16%  9  3% 
   Substance Use Counselors  38  18  47%  18  47%  2  5% 
Non-Independently Licensed 
465  325  70%  115  25%  25  5% 
Behavioral Health Providers 
   Counselors and Therapists  250  184  74%  58  23%  8  3% 
   Social Workers  198  131  66%  51  26%  16  8% 
   Registered Nurses  13  9  69%  4  31%  0  0% 
   Substance Use Counselors  4  1  25%  2  50%  1  25% 
Total  2,665  1,898  71%  647  24%  120  5% 
* Includes certified nurse practitioners with a psychiatric specialty and certified nurse specialists with a psychiatric specialty. 
Rows may not total 100 percent due to rounding. 
Source: OIG analysis of State Medicaid data, 2019. 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  34 
OEI-02-17-00490   
 
Exhibit B-2:  Number of licensed behavioral health providers, by county, 2017  
Total 
Independently  Independently  Non- Licensed 
Medicaid  Total 
Licensed,  Licensed, Non- Independently  Providers 
County  Type   Managed  Licensed 
Prescribing  Prescribing  Licensed  per 1,000 
Care  Providers 
Providers  Providers  Providers  Enrollees 
Enrollees* 
Bernalillo  Urban  187,932  149  911  230  1,290  6.9 
Catron  Frontier  654  -  1  -  1  1.5 
Chaves  Rural  25,574  3  22  8  33  1.3 
Cibola  Frontier  7,353  2  7  2  11  1.5 
Colfax  Frontier  4,448  -  4  2  6  1.3 
Curry  Rural  16,123  2  37  14  53  3.3 
De Baca  Frontier  902  -  -  -  -  - 
Dona Ana  Urban  92,905  48  157  46  251  2.7 
Eddy  Rural  18,215  7  14  5  26  1.4 
Grant  Rural  9,472  3  33  5  41  4.3 
Guadalupe  Frontier  1,910  -  3  -  3  1.6 
Harding  Frontier  67  -  -  -  -  - 
Hidalgo  Frontier  1,677  1  1  2  4  2.4 
Lea  Rural  24,730  4  14  7  25  1.0 
Lincoln  Frontier  6,117  -  8  -  8  1.3 
Los 
Urban  775  1  11  3  15  19.4 
Alamos 
Luna  Rural  13,544  2  6  3  11  0.8 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  35 
OEI-02-17-00490   
 
Exhibit B-2:  Number of licensed behavioral health providers, by county, 2017 (continued) 
Total 
Independently  Independently  Non- Licensed 
Medicaid  Total 
Licensed,  Licensed, Non- Independently  Providers 
County  Type   Managed  Licensed 
Prescribing  Prescribing  Licensed  per 1,000 
Care  Providers 
Providers  Providers  Providers  Enrollees 
Enrollees* 
McKinley  Rural  17,377  10  17  3  30  1.7 
Mora  Frontier  1,295  -  4  -  4  3.1 
Otero  Rural  16,798  13  32  4  49  2.9 
Quay  Frontier  3,513  -  4  2  6  1.7 
Rio Arriba  Rural  17,449  2  21  9  32  1.8 
Roosevelt  Rural  6,444  1  6  -  7  1.1 
San Juan  Rural  32,683  16  45  9  70  2.1 
San 
Frontier  11,315  12  25  16  53  4.7 
Miguel 
Sandoval  Rural  33,006  15  111  33  159  4.8 
Santa Fe  Urban  56,777  29  267  46  342  6.0 
Sierra  Frontier  6,435  2  10  1  13  2.0 
Socorro  Frontier  6,414  1  3  -  4  0.6 
Taos  Rural  12,064  4  64  12  80  6.6 
Torrance  Frontier  7,986  -  7  -  7  0.9 
Union  Frontier  576  -  -  -  -  - 
Valencia  Rural  26,852  1  27  3  31  1.2 
Total    669,705*  328  1,872  465  2,665  4.0 
* This includes an additional 323 enrollees in which the county was unknown.  
Source: OIG analysis of State Medicaid data, 2019. 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  36 
OEI-02-17-00490   
 
APPENDIX C:  Number of Selected Behavioral 
Health Organizations That Report Having 
Difficulty Providing Timely Appointments  
Urgent Appointments 
  Number of BHOs      Percentage of BHOs 
With a prescriber in their BHO 
   Within 24 Hours  30  56.6% 
   After 24 Hours  23  43.4% 
With a non-prescriber in their BHO 
   Within 24 Hours  49  92.5% 
   After 24 Hours*  4  7.5% 
 
 
 
Routine Appointments 
  Number of BHOs      Percentage of BHOs 
With a prescriber in their BHO 
   Within 14 Days  28  52.8% 
   After 14 Days  25  47.2% 
With a non-prescriber in their BHO 
   Within 14 Days  49  92.5% 
   After 14 Days**  4  7.5% 
* Three of the four BHOs are unable to provide urgent appointments with prescribers and non-prescribers in their BHOs within 24 hours. 
** All four BHOs are unable to provide routine appointments with prescribers and non-prescribers in their BHOs within 14 days. 
Source:  OIG analysis of BHO survey data, 2019. 
   
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  37 
OEI-02-17-00490   
 
Appendix D:  Number of Selected Behavioral 
Health Organizations That Report Having 
Difficulty Arranging Each Service 
  Number of BHOs  Percentage of BHOs 
Recovery and Support Services 
   Behavioral Health Respite Care  27  50.9% 
   Family Support Services  22  41.5% 
   Psychosocial Rehabilitation Services  22  41.5% 
   Supportive Housing Pre-Tenancy and Tenancy Services  22  41.5% 
   Behavior Management Skills Development Services  17  32.1% 
   Comprehensive Community Support Services (CCSS)  15  28.3% 
Non-Intensive Outpatient Services 
   Day Treatment  24  45.3% 
   Medication Assisted Treatment (MAT): Buprenorphine  
24  45.3% 
   Treatment for Opioid Use Disorder 
   Screening, Brief Intervention & Referral to Treatment (SBIRT)  16  30.2% 
   Crisis Intervention Services  12  22.6% 
   Behavioral Health Professional Services for Screenings,    
4  7.5% 
   Evaluations, Assessments and Therapy 
Intensive Outpatient Services 
   Opioid Treatment Program (OTP)  22  41.5% 
   Applied Behavior Analysis (ABA)  28  52.8% 
   Intensive Outpatient Program for Substance Use Disorders or  
21  39.6% 
   Mental Health Conditions  (IOP) 
   Cognitive Enhancement Therapy (CET)  20  37.7% 
   Assertive Community Treatment Services  19  35.8% 
   Multi-Systemic Therapy (MST)  17  32.1% 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  38 
OEI-02-17-00490   
 
 
  Number of BHOs  Percentage of BHOs 
Inpatient and Residential Services 
   Accredited/ Non-accredited Residential Treatment Center  
30  56.6% 
   (ARTC, RTC) or Group Home 
   Institution for Mental Diseases (IMD)  30  56.6% 
   Treatment Foster Care I and II  18  34.0% 
Source: OIG analysis of BHO survey data, 2019. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  39 
OEI-02-17-00490   
 
APPENDIX E:  Centers for Medicare & Medicaid 
Services Comments 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  40 
OEI-02-17-00490   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  41 
OEI-02-17-00490   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  42 
OEI-02-17-00490   
 
APPENDIX F:  New Mexico Human Services 
Department Comments 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  43 
OEI-02-17-00490   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  44 
OEI-02-17-00490   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  45 
OEI-02-17-00490   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  46 
OEI-02-17-00490   
 
ACKNOWLEDGMENTS 
Vincent Greiber served as the team leader for this study.  Others in the 
Office of Evaluation and Inspections who conducted the study include 
Grant Conway.  Office of Evaluation and Inspections staff who provided 
support include Clarence Arnold and Kevin Manley.  
We would also like to acknowledge the contributions of other Office of 
Inspector General staff, including Marissa Baron and Jessica Swanstrom.   
This report was prepared under the direction of Jodi Nudelman, Regional 
Inspector General for Evaluation and Inspections in the New York regional 
office, and Nancy Harrison and Meridith Seife, Deputy Regional Inspectors 
General.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To obtain additional information concerning this report or to obtain copies, 
contact the Office of Public Affairs at Public.Affairs@oig.hhs.gov.  
Provider Shortages and Limited Availability of Behavioral Health Services in New Mexicos Medicaid Managed Care  47 
OEI-02-17-00490   
 
ABOUT THE OFFICE OF INSPECTOR GENERAL 
The mission of the Office of Inspector General (OIG), as mandated by Public 
Law 95-452, as amended, is to protect the integrity of the Department of 
Health and Human Services (HHS) programs, as well as the health and 
welfare of beneficiaries served by those programs.  This statutory mission is 
carried out through a nationwide network of audits, investigations, and 
inspections conducted by the following operating components: 
Office of Audit  The Office of Audit Services (OAS) provides auditing services for HHS, either 
by conducting audits with its own audit resources or by overseeing audit 
Services 
work done by others.  Audits examine the performance of HHS programs 
and/or its grantees and contractors in carrying out their respective 
responsibilities and are intended to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, 
abuse, and mismanagement and promote economy and efficiency 
throughout HHS. 
Office of Evaluation  The Office of Evaluation and Inspections (OEI) conducts national evaluations 
to provide HHS, Congress, and the public with timely, useful, and reliable 
and Inspections 
information on significant issues.  These evaluations focus on preventing 
fraud, waste, or abuse and promoting economy, efficiency, and 
effectiveness of departmental programs.  To promote impact, OEI reports 
also present practical recommendations for improving program operations.   
Office of  The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of fraud and misconduct related to HHS programs, 
Investigations 
operations, and beneficiaries.  With investigators working in all 50 States 
and the District of Columbia, OI utilizes its resources by actively 
coordinating with the Department of Justice and other Federal, State, and 
local law enforcement authorities.  The investigative efforts of OI often lead 
to criminal convictions, administrative sanctions, and/or civil monetary 
penalties. 
Office of Counsel to  The Office of Counsel to the Inspector General (OCIG) provides general 
legal services to OIG, rendering advice and opinions on HHS programs and 
the Inspector 
operations and providing all legal support for OIGs internal operations.  
General 
OCIG represents OIG in all civil and administrative fraud and abuse cases 
involving HHS programs, including False Claims Act, program exclusion, and 
civil monetary penalty cases.  In connection with these cases, OCIG also 
negotiates and monitors corporate integrity agreements.  OCIG renders 
advisory opinions, issues compliance program guidance, publishes fraud 
alerts, and provides other guidance to the healthcare industry concerning 
the anti-kickback statute and other OIG enforcement authorities.