The National Board for Certified Counselors (NBCC) has provided extensive comments to the Centers for Medicare & Medicaid Services (CMS) on several provisions affecting mental health counselors contained in the 2025 Medicare Physician Fee Schedule Proposed Rule.
Each year, CMS updates the overall Physician Fee Schedule through a proposed rule. In NBCC’s statement to CMS, we provided comments on key behavioral health issues and CMS’s overall goal to improve mental health access to Medicare beneficiaries. NBCC supported the following provisions proposed by CMS in the fee schedule with technical recommendations to improve and clarify specific initiatives:
- Safety Planning Interventions: Proposing to implement separate coding and payment by counselors 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.
- Digital Mental Health Tools: Creating three new payment codes for reimbursing digital mental health treatment services provided by counselors, 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.
- 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 is using this comment period to reinforce other concerns of counselors related to enrollment processes on documentation of clinically supervised experience, similar to our views provided in the 2024 Fee Schedule Rule. In addition, we provided comments on clarifying payment provisions under several mental health settings, including home health and outpatient rehabilitation services.
NBCC will provide an update to NCCs when the final 2025 Medicare Physician Fee Schedule Rule is released later this year with a summary of key changes based on our comments.
