NBCC Advocates for Counselors in 2026 Medicare Physician Fee Schedule Comments

Each year, the National Board for Certified Counselors (NBCC) submits comprehensive recommendations to the Centers for Medicare & Medicaid Services (CMS) addressing payment, technology, and quality measures for mental health counselors serving Medicare beneficiaries.

NBCC recently submitted detailed comments to CMS regarding the proposed 2026 Medicare Physician Fee Schedule, advocating for policies that recognize the unique needs and contributions of mental health counselors and marriage and family therapists serving Medicare beneficiaries. As mental health professionals will enter their third year in 2026 as Medicare Part B providers, NBCC's comments on the proposed rule address critical areas affecting practice sustainability and client access.

Expanding Telehealth Opportunities

NBCC strongly endorsed CMS’s proposed telehealth policy improvements, particularly praising the streamlined Medicare Telehealth Services List process and the addition of Multiple-Family Group Psychotherapy (90849) to covered services. The comments emphasized that mental health counselors have demonstrated exceptional success in providing telehealth services since 2024, achieving clinical outcomes comparable to in-person care while significantly improving access for underserved populations.

“The COVID-19 pandemic demonstrated that telehealth mental health services are not just an emergency measure, but a valuable permanent addition to the health care delivery system,” NBCC noted in its comments. NBCC particularly supports the permanent adoption of audio/video direct supervision, which will enhance training opportunities and support mental health service delivery in rural and underserved areas where experienced supervisors may not be physically present.

Advancing Behavioral Health Integration

The comments strongly support CMS’s efforts to expand access to behavioral health services through clarification of Community Health Integration (CHI) and Principal Illness Navigation (PIN) services. NBCC highlighted that mental health counselors are uniquely positioned to provide these services given their comprehensive training in psychosocial assessment, community resource coordination, and understanding of how social determinants impact mental health outcomes.

NBCC also endorsed the expansion of Digital Mental Health Therapy (DMHT) payment policies to include devices cleared for attention-deficit/hyperactivity disorder (ADHD) treatment, noting that mental health counselors frequently treat ADHD patients across the life span and that evidence-based digital interventions can significantly enhance traditional therapeutic approaches.

NBCC expressed strong support for CMS’s consideration of creating coding and payment for motivational interviewing, calling it “an evidence-based therapeutic approach widely used by mental health counselors” that is particularly effective for addressing ambivalence about behavior change in various clinical presentations.

Supporting Fair Payment Structures

NBCC voiced strong support for the proposed dual conversion factor structure for 2026, which provides a 1.2% increase for providers participating in qualifying Alternative Payment Models and a 0.7% increase for non-qualifying providers. The comments emphasized that this approach strikes an appropriate balance between innovation incentives and practice stability for the nearly 60,000 mental health counselors now serving Medicare beneficiaries.

“This policy will help ensure that mental health counselors can continue providing essential mental health services while transitioning toward value-based care models that improve outcomes for the Medicare population,” NBCC stated.

Addressing Practice Expense Challenges

A significant portion of NBCC’s comments focused on reforming Practice Expense (PE) Relative Value Unit (RVU) allocation methodologies. NBCC argued that current methodologies fail to capture the unique characteristics of mental health practice, including extended 45–60-minute session durations, specialized therapeutic environments, comprehensive technology infrastructure, and extensive documentation requirements.

NBCC recommended that CMS create specialized PE RVU categories for mental health services, conduct comprehensive practice expense surveys targeting mental health counselors, and develop activity-based costing methodologies that more accurately capture indirect costs specific to mental health practice.

Ensuring Accurate Service Valuation

The comments emphasized the importance of CMS’s potentially misvalued codes (PMVC) review process for mental health services. NBCC recommended proactive review of psychotherapy (90834, 90837), family psychotherapy (90847), group psychotherapy (90853), and psychiatric (90791, 90792) diagnostic evaluation codes to ensure RVU assignments reflect current practice patterns and resource requirements.

Quality Payment Program Adaptations

NBCC urged CMS to adopt the Quality Payment Program to recognize the unique characteristics of mental health counseling practice. Key recommendations included developing behavioral health–specific quality measures such as standardized mental health outcome tools (PHQ-9, GAD-7), incorporating mental health-relevant improvement activities, and addressing unique interoperability challenges in behavioral health settings.

The comments also called for creating Alternative Payment Model opportunities specifically designed for behavioral health services that recognize longer treatment episodes and recovery-oriented outcomes.

Supporting Rural and Underserved Communities

NBCC endorsed CMS’s proposals to enhance behavioral health integration services in Rural Health Clinics and Federally Qualified Health Centers, supporting the addition of Behavioral Health Integration and Psychiatric Collaborative Care Model add-on codes. However, the comments requested clarification on mental health counselor billing eligibility and expressed concerns about telehealth in-person visit requirements that could create barriers to care access.

Looking Forward

The comprehensive nature of NBCC’s comments reflects the organization’s commitment to ensuring that Medicare policies support sustainable mental health counseling practices while improving access and outcomes for beneficiaries. As mental health counselors continue to establish their role within the Medicare system, these policy recommendations aim to address both immediate practice needs and long-term integration goals.

Mental health counselors interested in the full details of NBCC’s comments can access them through our website, where you’ll find valuable insights into the evolving Medicare landscape and its impact on behavioral health service delivery.