Psychologists and other mental health providers will see increases in the work values of codes for psychotherapy and health behavior assessment and intervention (HBAI) services. CMS is finalizing its proposal to raise the work values for these services by 19.1% over a 4-year period. The initial proposal was to increase payments for only psychotherapy, but thanks to advocacy by APA Services and others, CMS agreed to include HBAI services. The increase in work values will apply to psychotherapy codes 90832, 90834, 90837, 90839, 90840, 90845, 90846, 90847, 90849, and 90853, and HBAI codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168.

CMS did not adopt APA Services’ recommendation to increase the work values for the psychological and neuropsychological testing codes, but said it welcomes feedback on the valuation of psychological and neuropsychological testing services and may consider updates in future rulemaking. APA Services will continue to engage CMS and advocate for work value increases for the psychological and neuropsychological testing codes.

CMS did acknowledge the important role caregivers have in a patient’s overall care and are adopting an active payment status for CPT code 96202 and 96203: Multiple-family group behavior management/modification training for guardians/caregivers of patients with a mental or physical health diagnosis.

APA Services also asked for increased reimbursement for psychotherapy services in the Substance Use Disorder (SUD) services bundle. CMS is finalizing its proposal to provide an increase for HCPCS codes G2086 and G2087 to reflect two individual psychotherapy sessions per month, with a cross walk to the work RVUs for CPT code 90834, replacing the current cross walk to code 90832.

CMS has acknowledged that the current rate-setting methodology for practice expense (PE) negatively impacts certain services, including behavioral health services, and has requested information on potential changes to improve the methodology and practice expense reimbursement. APA Services made three PE methodology recommendations to improve PE valuation and reimbursement for behavioral health services. CMS indicated that they may consider changes to the PE methodology in future rulemaking. APA Services will continue to engage CMS and advocate for changes to improve PE valuation and reimbursement for behavioral health services.

CMS also discussed the American Medical Association’s Physician Practice Information (PPI) and Clinician Practice Information (CPI) surveys, which will be administered to more than 10,000 physician and non-MD/DO practices, with the intent to collect updated and accurate data on practice costs, which are a key element of clinician payment. These surveys are currently underway and will be in the field through April 2024. Data will be shared with CMS in early 2025 for the 2026 Medicare Physician Payment Schedule rulemaking process. Psychologists will be included in the CPI surveys.

The CMS final rule includes a 3.4% decrease to the conversion factor (CF) for 2024 ($32.74 compared to the 2023 CF of $33.89). APA is advocating alongside other physician and provider groups to forestall cuts in Medicare reimbursement for 2024, and to establish more sustainable annual updates to the conversion factor going forward. Congress provided a 1.25% increase to Medicare PFS payment rates for 2024 under legislation already enacted, and the Senate Finance Committee recently approved broad legislation that would double this to a 2.5% increase. We expect the issue of annual reimbursement rate updates to gain even more attention from Congress next year, and we’ll continue to push for more appropriate, effective Medicare payments.

APA Services has long advocated that CMS must continue to reimburse for telehealth at the in-person rate to ensure access to behavioral health services. In 2024, CMS will implement paying claims for telehealth services using POS 10 (services provided in the patient’s home) at the nonfacility rate. Claims for telehealth services using POS 02 (location other than the patient’s home) will be paid at the facility rate.

CMS is finalizing its proposal to classify additions to the Telehealth List as either permanent or provisional. Provisional status would be used when additional study is needed to show the clinical benefit of furnishing a service via telehealth. The codes for Psychological and Neuropsychological Test Administration and Evaluation Services (96130–96139) will have provisional status on the 2024 Medicare Telehealth List.

CMS is finalizing its proposal to permit virtual presence for direct supervision to be furnished via two-way, audio-visual communications technology through December 31, 2024. CMS is requesting comments on whether it should extend this allowance further, safety and quality concerns, and program integrity concerns (e.g., overutilization, fraud, and abuse).

CMS will continue to allow practitioners to use their currently enrolled practice location instead of their home address when providing telehealth services from their home. CMS is requesting comments on the issue of including a practitioner’s home address as a practice location.

As the result of federal legislation passed in 2022, marriage and family therapists (MFTs) and mental health counselors (MHCs) will be able to directly bill Medicare for their services in 2024. MFTs and MHCs will be paid 75% of the amount under the PFS; whereas, psychologists are paid 100% of the PFS rate.

In light of this legislation, in its comment letter on the proposed rule, APA Services asked CMS to also recognize master’s-trained clinicians in health service psychology (M-HSP clinicians) as MHCs. In the final rule, CMS clarified that individuals who are licensed or certified by their state under a different title to furnish mental health counseling are eligible to enroll in Medicare under the “mental health counselor” category as long as they meet all applicable qualifications for education and clinical supervised experience, and practice independently.

Consistent with requirements stated in Section 4123(a)(1) of the Consolidated Appropriations Act, 2023, Improving Mobile Crisis Care in Medicare, CMS finalized coding and payment for two new G codes, now assigned as HCPCS code G0017; Psychotherapy for crisis furnished in an applicable site of service; first 60 minutes, and G0018; Psychotherapy for crisis furnished in an applicable site of service; each additional 30 minutes. These codes were established to describe psychotherapy for crisis services that are furnished in any nonfacility place of service other than the physician’s office setting.

CMS also proposed new coding to describe and separately value three types of services that may be provided by auxiliary personnel incident to the billing physician or practitioner’s professional services, and under the billing practitioner’s supervision, when reasonable and necessary to diagnose and treat the patient: community health integration services, social determinants of health risk assessment, and principal illness navigation.

Social Determinants of Health Risk (SDOH) Assessment

CMS finalized coding and payment for a new stand-alone G code, now assigned as HCPCS code G0136, Administration of a standardized, evidence-based SDOH risk assessment, 5–15 minutes, not more often than every 6 months. SDOH risk assessment refers to the review of the individual’s SDOH or identified social risk factors that influence the diagnosis and treatment of medical conditions and recognizes the time and resources spent by practitioners when assessing SDOH. Further, for the operational ease of practitioners, CMS did not finalize the proposed requirement that the SDOH risk assessment must be performed on the same date as the initiating evaluation/management (E/M) services. In response to recommendations made by APA Services and our members, CMS agreed that, in addition to E/M services, the SDOH risk assessment can be performed by a licensed psychologist and billed with behavioral health visits (such as CPT codes 90791 or 96156). APA Services will continue to advocate for the SDOH assessment also to be allowed to be billed with neuropsychological codes such as CPT codes 96116.

Community Health Integration (CHI) Services

CMS finalized their proposal to create two new G codes (G0019 and G0022) describing CHI services performed by certified or trained auxiliary personnel, which may include a community health worker, incident to the professional services, and under the general supervision of the billing practitioner. The agency indicated that they did consider adding services provided by clinical psychologists (i.e., CPT codes 90791 and 96156), to the list of services that could serve as an initiating visit for CHI services, but determined that these services would be better captured under the principal illness navigation services (discussed below) and would better serve the needs being addressed with the principal illness navigation service elements. They did, however, note that they will continue to analyze the uptake of CHI services and will consider comments regarding adding services provided by clinical psychologists for future rulemaking.

Principal Illness Navigation (PIN) Services

CMS finalized their proposal to establish two new G codes to describe PIN services to better recognize through coding and payment policies when certified or trained auxiliary personnel, under the direction of a billing practitioner, are involved in the patient’s health care navigation as part of the treatment plan for a serious, high risk disease that places the patient at significant risk of hospitalization or nursing home placement, acute exacerbation/decompensation, functional decline, or death. The newly established G-codes are: G0023; Principal Illness Navigation services by certified or trained auxiliary personnel under the direction of a physician or other practitioner, including a patient navigator or certified peer specialist; 60 minutes per calendar month, and G0024; Principal Illness Navigation services, additional 30 minutes per calendar month (list separately in addition to G0023).

In response to recommendations made by APA Services and our members, CMS agreed that, in addition to E/M services, CPT code 90791; Psychiatric diagnostic evaluation and the Health Behavior Assessment and Intervention (HBAI) services described by CPT codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168 furnished by a psychologist can serve as the initiating service for PIN services.

As part of the proposed rule, CMS included request for information (RFI) on remote therapeutic monitoring (RTM) services, including digital cognitive behavioral therapy (dCBT). APA Services provided extensive comments. CMS acknowledged they received extensive feedback on this topic and indicated that they may consider updates in future rulemaking. APA Services will continue to engage with CMS in this area. 

CMS solicited comments on whether there is a need for potential separate coding and payment for interventions initiated or furnished in the emergency department or other crisis setting for patients with suicidality or at risk of suicide, such as safety planning interventions and/or telephonic postdischarge follow-up contacts after an emergency department visit or crisis encounter. APA Services endorsed the need for additional coding and payment for these services and has offered to work with CMS to develop future policies in this area. CMS expressed thanks for the many detailed comments received and noted that they may consider this input for potential policy proposals through future rulemaking. APA Services will continue to engage with CMS in this area. 

APA Services will continue to provide additional information and details regarding the over 2,000-page CMS Final Rule soon. 

A huge thanks to everyone who submitted comments to CMS and advocated to improve access to behavioral health services. Your participation is making a difference.

APA Practice News
https://www.apaservices.org/practice/reimbursement/government/2024-physician-fee-schedule-final-rule