CMS pitches 2025 physician fee schedule: 5 behavioral health updates

CMS is proposing adding Medicare reimbursement for creating safety plans and follow-up services for patients in crisis. 

The agency published its proposed physician fee schedule for 2025 on July 10. The agency proposed an overall 93 cent (2.8%) conversion factor decrease from 2024.  

The proposed rule includes several provisions designed to support access to behavioral health, CMS said in a fact sheet. 

Here are five proposed changes to know: 

1. CMS proposed adding billing codes for the creation of safety planning for patients in crisis, including those at risk of suicide or overdose. The code would allow providers to bill Medicare alongside an evaluation or management visit or psychotherapy visit for a patient when interventions are personally performed by the billing provider. 
   
   
2. In addition to reimbursement for safety planning, CMS also proposed adding a billing code for post-discharge follow-up for patients in crisis, providing a bundled payment for four calls in a month to a patient discharged from the emergency department or a crisis encounter. 
   
   
3. Under the proposed rule, Medicare would reimburse digital mental health treatment services used in conjunction with ongoing behavioral health treatment. 
   
   
4. CMS also proposed allowing providers limited to diagnosing and treating mental illness, including clinical psychologists and marriage and family therapists, to bill for interprofessional consultations. The expanded codes would allow for better integration of behavioral health treatment into primary care and other settings, the agency said. 
   
   
5. The agency is seeking comment on whether payment for intensive outpatient program services should be expanded to additional settings, including certified community behavioral health clinics. 

CMS also pitched several updates to reimbursement for opioid use disorder treatment, including expanding the number of opioid treatments covered by Medicare and relaxing requirements around the types of services provided through telehealth. 

The proposed fee schedule is open for comment until Sept. 9. Read more here.