Our work shaping and reporting on national mental health policy is made possible through a capacity grant from the Perigee Fund.
On October 31, the Centers for Medicare and Medicaid Services (CMS) issued its Final Rule on the Medicare 2026 Physician Fee Schedule.
The Medicare Fee Schedule indirectly impacts private insurer and Medicaid protocol and pricing, as this schedule is often used as a benchmark for their own coverage and payment rates, which in turn impact OB and mental health care practices and reimbursement for providers, also often influencing patient access to care and costs.
The Policy Center for Maternal Mental Health (“Policy Center”) provided comments on the July 2025 Notice of Proposed Rule Making.
Following is a summary of the actions CMS took that align with our interests for the field of maternal mental health:
What CMS adopted from our recommendations:
- Reduction in Pay Not Enacted: CMS removed recommendations in the proposed rule that would have applied a -2.5% reduction to time-based evaluation and management (E/M), behavioral health integration, and maternity codes, securing payment stability for the perinatal period.
Why this matters: Payments are not reduced for maternity care, behavioral health integration, and time-based evaluation and management (E/M) codes (which can be used by Ob/Gyns for management and follow-up of patients with positive maternal mental health screens). This is important as obstetric providers are facing unprecedented pressures and need additional financial capacity, not less, to support the maternal mental health of their patients.
- FQHCs Can Now Bill Collaborative Care: CMS finalized the policy to transition Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to standard CoCM CPT codes.
Why this matters: This allows community health clinics (FQHCs/RHCs), which often serve as the sole source of care for low-income pregnant and postpartum women, to bill for integrated mental health care, thereby improving access to care and the financial sustainability of these integrated services.
- Permanent Telehealth Expansion: CMS finalized the following telehealth policies that impact perinatal providers:
- Permanently adopting a definition of “direct supervision” that allows the supervising physician/practitioner of a treating practitioner to provide supervision through real-time audio and visual interactive telecommunications rather than in-person.
- Simplifying the process for adding new services to the “Telehealth List.”
Why this matters: This new rule eliminates the impractical requirement that the supervising physician/practitioner must be in the same physical office, allowing the supervising provider to work from any location and serve multiple sites. This change in policy is particularly vital for rural clinics where supervising clinicians, like OB/Gyns, psychiatrists and psychologists could support on the ground teams of nurse practitioners, certified peer support specialists and community health workers (CHWs) for example. This will allow more women to access timely screening, counseling, and follow-up care, ultimately reducing the risks of untreated mental health conditions.
Where Work Continues
While we celebrate these administrative and payment successes, CMS did not accept feedback regarding:
Protecting Peer Support Integrity
Our recommendation: 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.
Principal Illness Navigation (PIN) services are a type of care management service that auxiliary personnel, including care navigators or peer support specialists, may perform incidental to the professional services of a physician or other billing practitioner, under general supervision, to help patients understand their medical condition or diagnosis and guide them through the health care system. These services are designed for individuals with serious conditions that are expected to last at least 3 months, including severe mental illness or substance use disorder (SUD).
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.
The CMS Response & Our Next Step: The proposed and final rules now permit behavioral health providers: MFTs, MHCs, and CSWs to bill under PIN-PS codes G0140 and G0146.
We support CMS’s clarification that MFTs, MHCs, and CSWs may bill for Community Health Integration (CHI) codes G0019, G0022 and PIN codes G0023, G0024. We will continue to recommend PIN-PS codes G0140, G0146 be limited in use by certified peer support specialists and other trained non-clinical auxiliary personnel such as CHWs, 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.
Although we disagree with behavioral clinicians’ use of codes designed for peer CHI codes, this final rule represents real progress in integrating maternal mental health into obstetric care and improving access to and payment for behavioral health treatment.
