On Nov. 1, 2024, the Centers for Medicare & Medicaid Services (CMS) issued its Final Physician Fee Schedule (PFS) rule that will guide payment policies for all Medicare participating providers, including mental health counselors, for calendar year 2025.
NBCC and several mental health provider associations provided comments to CMS on the Proposed Physician Fee Schedule Rule in September on several issues pertaining to mental health counselors. Because of those comments, CMS modified key provisions in response to the mental health community’s concerns.
The annual Physician Fee Schedule (PFS) sets payment policies for all Medicare providers and should be used as a guide by counselors to identify changes that could impact their practice. Private health insurers and health plans (and Medicaid) use the fee schedule as part of their payment methodologies as well. The PFS is an important policy mechanism affecting health care and mental health policy.
Key Behavioral Health Provisions in the Final PFS Rule
Several behavioral health service areas that CMS addressed in its final rule include four critically important initiatives to address the needs of Medicare beneficiaries and allow for reimbursement for mental health counselors under Medicare:
- Safety Planning Interventions and Post-Discharge Telephone Follow-Up Contacts
After consideration of public comments by stakeholders including NBCC, CMS is finalizing its proposal to create separate coding and payment for safety planning interventions, with modifications. Specifically, CMS is now finalizing HCPCS code G0560 as a standalone code rather than an add-on code as originally proposed. CMS is also finalizing that G0560 can be billed by providers in units of 20 minutes. The HCPCS code G0560 will need to be personally performed by the billing practitioner for CY 2025.
CMS is finalizing payment for a monthly billing code that requires specific protocols in furnishing post-discharge follow-up contacts that are performed in conjunction with a discharge from the hospital or outpatient facility emergency department for a crisis encounter as a bundled service describing four calls in a month by the provider. The G-code for these services is HCPCS code G0544. CMS is finalizing a provision in the rule to allow client consent to be obtained prior to or during the initial phone call.
- Digital Mental Health Treatments
CMS, working with the Food and Drug Administration (FDA), is finalizing Medicare payments for digital mental health treatment devices used in conjunction with ongoing mental health care treatment under a plan of care to the client. CMS is finalizing three new HCPCS codes to describe these services and will monitor how digital mental health treatment devices are used as part of overall behavioral health care. CMS is finalizing HCPCS codes G0553 and G0554 for providers. - Interprofessional Consultation Billed by Practitioners to Treat Behavioral Health Conditions
CMS is finalizing payment for interprofessional consultations performed via communications technology such as telephone or internet (including videoconference). Currently, there is no payment mechanism to recognize the time and effort of performing these services by mental health counselors. CMS finalized payment policies for six new codes from G0546–G0551 for interprofessional telephone/internet/electronic health record assessment and management service provided by a practitioner for various time frames.
- Telehealth Services Under the PFS
Unless policymakers act between now and Dec. 31 during the congressional lame-duck legislative session, the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency (PHE) will retake effect for most telehealth services on Jan. 1. These include geographic and location restrictions on where the services are provided. The final rule permanently changes the definition of an interactive telecommunications system to include two-way, real-time, audio-only communication technology for any telehealth services furnished by practitioners to beneficiaries in their homes.
Looking Ahead
The Final Physician Fee Schedule will be officially published in the Federal Register on Dec. 9.
Please keep in mind that the new codes identified under safety planning, digital therapies, and interprofessional consultation provisions will go into effect on Jan. 1, 2025. If you provide any of these new services for a Medicare client before that date, you will not be reimbursed by Medicare.
For counselors who have not enrolled in Medicare, this is a great opportunity to complete the enrollment form provided by CMS so you can become a Medicare provider and take advantage of billing for the new 2025 codes—and current ones—for Medicare beneficiaries.
NBCC is supporting telehealth legislation passed by the House Energy and Commerce Committee, which will be considered by Congress in the upcoming lame-duck legislative session, that would extend the COVID-19–era telehealth policies through Dec. 31, 2026. Specifically, the Telehealth Modernization Act is bipartisan legislation that includes expanding originating sites to include the home, allowing for telemental health visits to occur without a 6-month in-person requirement, and permitting Community Health Centers and Rural Health Clinics to bill Medicare for telehealth services.
Other bipartisan legislative efforts include a focus on changing the expected 2.8% payment cut embodied in the PFS Conversion Factor to a 1.9% payment increase (or similar changes) for 2025. Read the full text of H.R. 10073, the Medicare Patient Access and Practice Stabilization Act of 2024.
NBCC supports this congressional bill, which is likely to be considered during the lame-duck session, and is advocating for appropriate changes that could modify the Conversion Factor to increase payments to all Medicare providers in 2025.
For more information about the Medicare Physician Fee Schedule process and provider enrollment, and NBCC initiatives focused on these areas, please visit our Government Affairs Newsroom.
