APA Services has released an Action Alert on CMS’ CY 2026 Physician Fee Schedule (PFS) Proposed Rule, and we are asking for your help in sharing it broadly with your networks. Your engagement is critical to ensuring psychologists’ voices are heard in this important process.

Why This Matters

The PFS sets federal reimbursement policy and influences coverage decisions across the entire health care system. This year’s proposed rule includes several significant wins for psychology—made possible through years of advocacy and strong participation in prior federal regulatory comment campaigns. However, it also contains provisions where CMS needs the expertise and input of psychologists to make improvements.

Key Positive Provisions

• Preserves access to psychological services furnished via telehealth
• Permanently adopts a definition of direct supervision allowing “immediate availability” via two-way audio/video
• Creates a new pathway for neuropsychologists to participate in MIPS

Provisions Needing Improvement

• Removal of a reimbursement code for clinician assessment of Social Determinants of Health
• Inconsistent reimbursement for Digital Mental Health Treatment and Remote Therapeutic Monitoring tools
• Problematic changes to reimbursement codes for outpatient behavioral health services, including those vital to neuropsychological assessment and chronic illness management

Call to Action

Please disseminate APA’s action alert and encourage your members, colleagues, and networks to send comments to CMS. Broad engagement will help solidify these positive policies and shape improvements in the final rule. The comment period closes at 11:59pm EDT on September 12, 2025 

Click here to take action today!  

Thank you for your leadership and partnership. 

Best,
Alix