As reported in the August Visions newsletter, the Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule on the 2025 Medicare Physician Fee Schedule.
The National Board for Certified Counselors (NBCC) has provided extensive comments on several provisions in the proposed rule related to advancing behavioral health services for Medicare beneficiaries.
For the September Visions newsletter theme on suicide prevention, we have summarized our comments to CMS on the proposed rule for the Medicare Physician Fee Schedule with an emphasis on safety planning intervention services and post-discharge follow-up that CMS is promoting in the rule.
Safety Planning Intervention (SPI) Services and Post-Discharge Follow-Up
In the proposed rule for the 2025 Proposed Medicare Physician Fee Schedule, CMS is proposing to implement separate coding and payment for “Safety Planning Intervention (SPI) Services” and/or telephonic post-discharge follow-up contacts after an emergency room visit or crisis encounter. These services are typically provided to patients with suicidality or displaying a risk of suicide and have a proposed length of 20 minutes. The add-on code for SPI services would be billed along with an evaluation/management visit or psychotherapy service.
For post-discharge telephonic follow-up contact interventions, the proposed rule calls for creating a monthly billing code describing specific protocols for post-discharge follow-up contacts that occur after a patient is discharged from the emergency department following a crisis encounter. This bundled service would include four follow-up calls in a month, with each call lasting between 10 and 20 minutes.
Because of the cost-sharing obligation of Medicare beneficiaries, practitioners would be required to obtain verbal or written consent from their patient in advance of furnishing these services.
NBCC expressed to CMS that with suicide rates continuing to escalate among all ages across the nation, we are appreciative of CMS emphasizing this critically important issue, especially among older adults, and for adding coding on safety planning interventions for patients at risk of suicide. This new code will enable mental health counselors and other mental health practitioners to provide evidence-based suicide safety planning. However, in our remarks to CMS, we highlighted that providers need a way to capture time spent performing safety planning interventions beyond the initial 20 minutes. NBCC suggested greater flexibility in reporting total time required to provide these critically important services.
We also highlighted that some studies (Miller et al., 2017) have shown that for patients identified with elevated suicide risk, interventions that include SPI and up to seven post-discharge follow-up calls with the patient focused on identifying suicide risk factors, clarifying goals, safety and future planning, facilitating treatment engagement, and problem-solving, can reduce future suicidal behavior.
In the proposed rule, the term “safety planning interventions” refers to just one of several brief interventions designed to reduce suicide risk. We pointed out in our response that the final rule should also include other approaches with strong scientific support and demonstrated efficacy, especially “crisis response planning (CRP),” also known as “crisis coping cards.” The crisis response planning approach has been validated via several randomized clinical trials (Bryan et al., 2017, 2024; Chen et al., 2013; Lohani et al., 2024; Wang et al., 2016). NBCC suggested that the wording of the proposed rule should be amended to ensure that the suicide prevention interventions with strong supporting evidence can be paid for as well beginning in 2025.
We are hopeful that when the final 2025 Medicare Physician Fee Schedule Rule is released, possibly in mid-November, it will reflect NBCC’s recommendations on suicide planning interventions.
Other Behavioral Health Provisions
NBCC also provided comments on several provisions in the proposed rule on behavioral health issues and CMS’s goal to improve mental health access to Medicare beneficiaries. NBCC supported several of these provisions—with technical recommendations to improve and clarify the initiatives. Those provisions included:
- Digital Mental Health Tools—creating three new payment codes for reimbursing digital mental health treatment services, such as “digital CBT,” used in conjunction with ongoing behavioral health treatment. The codes would only apply to technologies and products approved by the Food and Drug Administration (FDA).
- Interprofessional Consultations Via Communications Technology—allowing counselors and marriage and family therapists to bill for interprofessional consultations. The goal of the expanded codes is to allow for increased integration of mental health treatment into primary care and related settings. The Medicare client would need to consent.
- Telehealth—allowing audio-only telehealth services when a Medicare client is limited in technology for mental health services when they are at home.
- Opioid Use Disorder Treatment Services—proposing new codes for FDA-approved medications for the treatment of opioid use disorder (OUD) and known or suspected opioid overdose; increasing telecommunication flexibilities; and providing more comprehensive services for OUD treatment, including assessing unmet health-related social needs, harm reduction intervention needs, and recovery support services.
NBCC will provide an update to NCCs when the final Medicare Physician Fee Schedule Rule is released later this year with a summary of key changes based on comments from NBCC and other organizations.
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