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The Policy Center for Maternal Mental Health submitted the following letter in response to the Centers for Medicare and Medicaid Services Proposed Physician Fee Schedule regarding gleaning insights from our partners at the Health Care Transformation Task Force, Mental Health Leadership Group, and others.

September 12, 2025

The Honorable Dr. Mehmet Oz, Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services (HHS)
Attention: CMS-1832-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850

Submitted electronically via http://www.regulations.gov. 

RE: CMS-1832-P: Medicare and Medicaid Programs; CY 2026 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program

Dear Administrator Dr. Mehmet Oz:  

On behalf of the Policy Center for Maternal Mental Health, we are writing in response to the Proposed Rule [CMS-1832-P]. 

The Policy Center for Maternal Mental Health is a non-profit, non-partisan policy and research think tank. We commend CMS for advancing policies that strengthen behavioral health integration, expand access to preventive services, and modernize payment structures. 

As HHS and CMS are aware, maternal mortality is a pressing health crisis, and maternal mental health conditions, including maternal suicide and overdose, are leading pregnancy-related causes of maternal mortality. Pregnant and postpartum women do not yet universally receive mental health and substance use disorder screening, diagnosis, treatment, and follow-up. These services must be provided starting in pregnancy and through 12 months postpartum.  Incentivizing this care through available billing codes and adequate reimbursement is critical to reducing risks and improving mother and infant outcomes.

We also wish to thank CMS for advancing maternal health and maternal mental health work through the Centers for Medicaid and Medicare Innovation, Transforming Maternal Health (TMaH) program. 

Following is our feedback relative to the Proposed Rule. 

CMS: “We are proposing to apply the [efficiency] adjustment to all codes except time-based codes, including but not limited to, E/M visits, care management services, behavioral health services, services on the CMS telehealth list, and maternity codes with a global period of MMM.”

Our Comment: We strongly support CMS’s decision not to reduce payment for any of the services mentioned above, which apply to care provided to women during the perinatal period. 

CMS: CMS proposes to revise the definition of primary care services used for beneficiary assignment to incorporate behavioral health services. Starting in January 2026, to include the following HCPCS and CPT codes: 

  • Enhanced Care Model Management Services: Behavioral health integration (BHI) or Collaborative Care Model (CoCM) services that are furnished with alternative primary care management services. 
  • HCPCS code GPCMI: Initial psychiatric collaborative care management in the first calendar month of behavioral health care manager activities, in consultation with a psychiatric consultant and directed by the treating physician.
  • HCPCS code GPCM2: Subsequent psychiatric collaborative care management, in a subsequent month of behavioral health care manager activities in consultation with a psychiatric consultant and directed by the treating physician. 
  • HCPCS code GPCM3: Care management services for behavioral health conditions, directed by a physician or other qualified health care professional, per calendar month. 

Our Comments: We appreciate CMS’s proposed change to expand the definition of primary care services by including Enhanced Care Model Management Services and related behavioral health codes.  Integrating behavioral health is essential for whole-person care and has the potential to prevent avoidable high-cost care delivered in emergency departments and inpatient settings. Though this might not be the intent, we wish to note that these codes should be available to all providers delivering primary care services, not just those in Accountable Care Organizations (ACOs). 

Further, we urge CMS to clarify in the Final Rule that behavioral health integration (BHI) and Collaborative Care (CoCM) apply to obstetric and midwifery settings. These providers have clinical guidelines from their respective clinical bodies and Federal government-sanctioned guidelines through HRSA’s Alliance for Innovation in Maternal Health (AIM) program to conduct screening, diagnose, and provide treatments within their scope of licensure. 

CMS: CMS proposes to create optional add-on codes for Advanced Primary Care Management (APCM) services to facilitate BHI. CMS would propose three new codes (G0556, G0557, G0558) to eliminate the time-based requirements for existing BHI and CoCM codes. These codes would supplement the existing APCM services, as established in the CY25 PFS final rule, which bundled together a set of care management and technology-based communication services. CMS believes the addition of these behavioral health codes will reduce the administrative burden for delivering BHI services, resulting in increased uptake. 

Our Comments: We strongly support CMS’s proposal to create new add-on codes for behavioral health integration (BHI) and psychiatric collaborative care management (CoCM) services within Advanced Primary Care Management (APCM). These new codes represent an important step toward reducing administrative burden, supporting integrated behavioral health, and advancing the long-term transition away from fee-for-service toward hybrid and population-based payments that promote value and sustainability in primary care.

The development of APCM codes was designed to streamline care delivery by eliminating restrictive, time-based billing requirements and patient eligibility determinations, while granting primary care providers the flexibility to deliver advanced, team-based care. The addition of behavioral health codes builds on this framework by recognizing the vital role of behavioral health integration and enabling practices to better meet the full spectrum of patients’ needs. Importantly, as noted in our comments above, this has significant implications for maternal mental health, where integration of behavioral health into obstetric care settings is critical for identifying and treating conditions such as perinatal depression, anxiety, and substance use disorders.

While we support CMS’s direction, we recommend several refinements to ensure adoption and effectiveness:

  1. Reduce Administrative Burden
    CMS should eliminate duplicative reporting requirements tied to APCM codes, such as those aligned with CPC+ Track 2 or overlapping QPP measures. Burdening practices with additional reporting undermines the very intent of APCM, which is to reduce complexity and allow providers to spend more time with patients rather than navigating billing and compliance. For maternal mental health specifically, streamlined billing is essential so OB/GYNs, midwives, pediatricians, and primary care providers can focus on timely screening, referral, and follow-up.
  2. Address Patient Cost-Sharing
    Because APCM codes include preventive services, applying patient cost-sharing poses a significant barrier to access and reduces providers’ willingness to adopt these codes. We urge CMS to establish waivers or flexibilities around patient cost-sharing for APCM services to prevent unexpected out-of-pocket costs for patients and expand uptake among primary care practices. This is particularly important for pregnant and postpartum women, who may already be facing financial stressors and for whom even modest out-of-pocket costs can deter care-seeking for behavioral health needs.
  3. Introduce Complexity Modifiers
    We recommend CMS adopt a two-tiered complexity structure, modeled on Chronic Care Management, to better reflect patient needs. This would allow fair reimbursement for practices caring for patients with higher behavioral health complexity, such as comorbid conditions, substance use disorders, or suicide risk, while preserving the administrative simplicity of APCM. This refinement is particularly relevant for maternal mental health, where conditions may be compounded by co-occurring risk factors such as intimate partner violence, chronic health conditions, or substance use, all of which increase risk for poor maternal and infant outcomes.
  4. Ensure Payment Parity for Advanced Practice Clinicians (APCs)
    Current policies apply a 15–20% payment reduction when services are billed “incident to” under general supervision, creating a disincentive for nurse practitioners and physician assistants to deliver Collaborative Care. This disproportionately harms rural, women’s health, and underserved clinics where APCs often serve as the primary or sole providers of maternal and behavioral health care. We urge CMS to establish payment parity for APCs furnishing Collaborative Care services to ensure sustainability and equity.
  5. Support Sustainability in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs)
    We support CMS’s proposal to retire G0512 and transition Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to standard Collaborative Care CPT codes (99492–99494, G2214). This change allows for more accurate reimbursement that accounts for patient complexity and strengthens the financial foundation for safety net clinics to expand access to integrated behavioral health services. FQHCs and RHCs often serve as the primary source of care for low-income women during pregnancy and postpartum, making this refinement essential for expanding access to maternal mental health services.

CMS: “Remote therapeutic monitoring (RTM) represents the monitoring of adherence to at-home therapeutic interventions…RTM can be provided for a variety of conditions, and there are distinct device supply codes that have been created for three types of therapeutic monitoring: respiratory system, cognitive behavioral therapy, and musculoskeletal system monitoring…. All of the codes in the RTM family are considered new technology and will be placed on the New Technology list to be reviewed after 3 years of data are available (April 2030). [See codes on Table 17]

Our Comment: We support these new technology RTM billing codes for monitoring whether cognitive behavioral therapy interventions delivered from digital therapeutic mental health services work.

CMS:  CMS has created a RFI on how to better support chronic disease prevention and management. In particular, the agency is seeking feedback on whether to create separate coding and payment for services related to social isolation and loneliness, intensive lifestyle interventions, medically tailored meals, digital therapeutics, and motivational interviewing. 

Our Comments: We strongly support CMS’s efforts to expand access to services that address non-medical drivers of health.  

The 2025 Physician Fee Schedule final rule took an important step by establishing separate payment for select digital mental health therapeutic (DMHT) devices, effective January 1, 2025. However, CMS has not established a national billing framework for mental health-focused digital therapeutics. This is critical to advancing access to care, particularly in rural communities and mental health shortage areas, and incentivising primary care and obstetric providers in prescribing DMHTs.  In the case of maternal mental health, obstetric providers are eager to have immediate treatment options for their patients, and Digital Therapeutics have the potential to solve what is often a void. There is currently at least one Digital Therapeutic that is FDA-approved for the treatment of maternal mental health disorders. 

CMS: CMS issued an RFI on the inclusion of preventive care within the APCM bundled rate. CMS believes that some of the current services included in the APCM may be considered preventive care and is seeking feedback on whether to include additional preventive services within the bundle. In particular, CMS is seeking feedback on how CMS should apply cost-sharing to APCM services. 

Our Comments: Currently, the APCM codes trigger cost-sharing for patients, which is a significant barrier to care for many patients. All primary care services and obstetric care, including preventive services such as depression screening, should be at no cost to patients. 

CMS: CMS proposes to increase access to telehealth services by granting providers additional flexibilities and streamlining administrative processes. In particular, CMS proposes to:

  • Permanently lift the frequency limits on subsequent inpatient, nursing facility, and critical care consultations.
  • Permanently allow virtual direct supervision.
  • Add five services to the 2026 Medicare Telehealth List using the appropriate audio-only or audio-video modifier on the E/M code.
  • Simplify the process for adding services to the Medicare Telehealth List by streamlining the current five-step process to a three-step process.

However, CMS proposes to limit virtual teaching physician supervision of residents to non-metropolitan areas. 

Our Comments: We strongly support CMS’s proposals to expand and streamline access to telehealth. These changes will reduce providers’ administrative burden while improving access to high-quality care, particularly for patients in rural and underserved communities.

We specifically support:

  • Simplifying the review process for adding services to the Medicare Telehealth Services List and eliminating the “provisional” status will provide predictability and stability for providers.
  • Permanently removing frequency limitations on Medicare telehealth services for subsequent inpatient visits, subsequent nursing facility visits, and critical care consultations, which will allow clinicians greater flexibility to meet patients’ needs.
  • Expanding access and reimbursement for telehealth services through the Physician Fee Schedule will ensure that investments in telehealth infrastructure remain sustainable over time.

For maternal mental health, these policies are especially important. Telehealth has proven to be a critical lifeline for pregnant and postpartum individuals who face barriers such as childcare responsibilities, transportation challenges, and workforce shortages in behavioral health and obstetric care. Ensuring permanent, stable reimbursement for telehealth services will allow more women to access timely screening, counseling, and follow-up care, ultimately reducing risks of untreated mental health conditions. 

CMS: 

In the 2024 PFS final rule CMS finalized G-codes to reflect new coding and payment for services describing Community Health Integration (CHI) provided by community health workers, peer support workers. Marriage and family therapists (MFTs) and mental health counselors (MHCs) have a similar statutory benefit category as clinical social workers, (CSWs) and may also connect individuals with community-based resources to address unmet social needs that affect the diagnosis and treatment of medical problems. Like CSWs, MFTs and MHCs can bill Medicare directly for services they personally perform for the diagnosis or treatment of mental illness and substance use disorders, but are not authorized by statute to bill under the provider fee schedule (PFS) for services that are provided by auxiliary personnel incident to their professional services. CHI and PIN services are typically provided by auxiliary personnel supervised by the billing practitioner, and MFTs and MHCs could serve as auxiliary personnel, as the codes do not limit the types of auxiliary personnel that can perform CHI and PIN services. We are further clarifying that if CSWs, MFTs, and MHCs perform the services as auxiliary personnel under the general supervision of a billing practitioner, in the absence of state-level requirements, they meet the certification or training requirements to perform all CHI and PIN service elements.

Our Comments: Principal Illness Navigation – Peer Support (PIN-PS, HCPCS codes G0140 and G0146) were created as a distinct subcategory of PIN with specific language recognizing the unique role of certified peer support specialists. The explicit policy rationale in the CY 2024 PFS final rule (88 FR 78818) was to ensure that certified peer support specialists could provide peer support within the scope of their certification and be reimbursed accordingly.

Allowing MFTs, MHCs, and CSWs to bill under PIN-PS, G0140 and G0146 creates no additional value for Medicare beneficiaries, the Medicare program, or clinicians. Extending these codes to clinicians dilutes their intent, undermines the distinct practice of peer support, and risks eroding the policy boundaries that CMS established when it created the PIN-PS category.

In summary, we support CMS’s clarification that MFTs, MHCs, and CSWs may bill for CHI (G0019, G0022) and PIN (G0023, G0024). We strongly recommend, however, that CMS maintain the integrity of PIN-PS codes (G0140, G0146) by limiting their use to certified peer support specialists and other trained non-clinical auxiliary personnel under the direction of a physician or other practitioner, consistent with the original design and policy rationale articulated in the CY 2024 PFS final rule.

Thank you for the opportunity to provide comments on the CY2026 Physician Fee Schedule proposed rules. Please contact me if you have questions regarding any of the recommendations or suggestions listed. 

Sincerely,

Joy Burkhard, MBA

Executive Director