Alert

The Centers for Medicare & Medicaid Services (CMS) made significant changes to Medicare reimbursement policies for behavioral health services, which are set to take effect in 2025.

These updates are part of a broader effort to improve access to high-quality mental health care and integrate behavioral and physical health services.

Key Updates to Medicare Reimbursement Policies

Major updates are as follows.

New Billing Codes for Safety Planning (Code G0560)

Safety planning interventions are services provided to individuals who are experiencing crises such as suicidal ideation or risk of overdose. These services can be provided via telehealth and is billed in 20-minute increments.

Coverage for Digital Mental Health Tools

Medicare will cover FDA-approved digital mental health devices. Similar in structure and documentation requirements to the remote patient monitoring codes, these services will require an order for the FDA device, documentation of training provided to the individual, and the time and work associated with monthly treatments. (Codes G0552–G0554)

Keep in mind that to bill for the supply of the digital mental health tool (Code G0552), the billing practitioner must have incurred the expense.

Expanded Billing for Interprofessional Consultations for Practitioners

This includes clinical psychologists, clinical social workers, and other practitioners that are limited to treatment of mental illness. Codes G0546–G0551 describing these services are available for reporting to CMS.

Network Adequacy Requirements for Medicare Advantage Plans

Medicare Advantage plans must maintain adequate networks of outpatient behavioral health providers. This ensures beneficiaries have access to in-network services, reducing out-of-pocket costs and wait times.

Provisional Coverage for Behavior Management and Modification Training Delivered to Caregivers of an Individual Patient

Codes G0539 and G0540 can be used to report caregiver training related to behavior management and modification for patients with dementia or Alzheimer’s.

Telehealth Services Update

Telehealth services will still be reported to CMS with the appropriate evaluation and management code even though there are 17 new codes for reporting telehealth services in 2025.

Code G2012 Update

Code G2012, which was used for reporting brief check-ins, was deleted. To report a virtual check in, use code 98016. Note that there is a five-minute time threshold that must be met. Services under five minutes are not reportable.

What This Means for Providers

For providers, these changes represent:

• New billing codes that providers will need to familiarize themselves with
• Reduction in overall payments under the Medicare Physician Fee Schedule
• Telehealth coding will vary for CMS and other insurance plans

What This Means for Patients

For patients, these changes represent:

• Updates aimed to enhance access to behavioral health services, particularly in underserved areas
• The integration of physical and mental health care under the innovation in behavioral health model is expected to improve overall health outcomes

What’s Next?

CMS is rolling out guidance and resources to help providers and Medicare Advantage plans adapt to these changes. Providers should review the new billing codes, update their practices to incorporate eligible tools, and explore ways to integrate behavioral and physical health services.

Stay informed about these updates to ensure your practice is prepared for the changes in 2025.

We’re Here to Help

For more information on these updates, contact your Moss Adams professional.

Additional Resources

• Health Care Consulting Services