On November 1, the Centers for Medicare & Medicaid Services (CMS) released their 2025 Medicare Physician Fee Schedule through a comprehensive fact sheet that breaks down all the planned changes across the health care system.
Here’s a look at how these changes will affect the behavioral health and telehealth landscape as we turn the corner into 2025 along with some insights from our Chief Medical Officer, Dr. Thomas Milam, on how we can interpret these changes.
Average payment rates under the PFS will be reduced by 2.93% in CY 2025
While the new ruling contains several positive updates, the PFS reduction in payment rates by 2.93% may have cascading impacts across your organization that you may have to prepare for.
While a decrease wasn’t unexpected, it still may present challenges for those affected as this reduction will put less money in the hands of healthcare workers and their organizations.
Dr. Thomas Milam, Chief Medical Officer, Iris Telehealth
Everything we do in medicine has a relative value unit (RVU) assigned to it – every procedure and every patient encounter – so even an incremental decrease is less money going to doctors, hospitals, and facilities during a time where there’s a lot more patients and higher acuity.
CMS will preserve and expand the scope of and access to telehealth services
Without congressional action, the pre-COVID-19 statutory limitations in place for Medicare telehealth services will resume, including geographic restrictions and service limitations in which practitioners can provide telehealth services.
CMS has expressed intentions to preserve important flexibilities in their authority and expand the scope of, and access to, telehealth services. However, we’re still waiting on the supportive data and legislative updates that will be critical to such efforts.
Dr. Thomas Milam, Chief Medical Officer, Iris Telehealth
The CMS Behavioral Health Strategy has a lot of important initiatives where telehealth could play a major role in keeping patients well and out of hospitals and emergency departments. We have every reason to believe CMS, patients, and providers want to continue leveraging telehealth in patient care–we’ve been doing it, and we should keep doing it.
CMS is leaning into greater suicide prevention and flexibilities for OUD treatment
To expand access to behavioral health care, CMS is taking action towards safety planning. When properly executed, this planning can go a long way towards preventing suicide.
CMS is currently finalizing separate coding and payment under the PFS describing safety planning interventions for patients in crisis, including those with suicidal ideation and those at risk of suicide or overdose.
Dr. Thomas Milam, Chief Medical Officer, Iris Telehealth
CMS is leaning in more to support efforts to identify people at risk for suicide, and they plan to have additional reimbursement modeling for services to move towards a zero-suicide policy. Suicide rates remain high in all age groups, and among veterans as well, so we should all be doing everything we can to screen, intervene, and prevent such loss of life — telehealth will continue to play a big role in such efforts.
There will be additional G-codes in the system that will cover some additional services for suicide screening, assessment, and management in keeping with the success of the 988-suicide hotline.
CMS is also finalizing telecommunication technology flexibilities for Opioid Use Disorders treatment services – allowing people to receive care without an in-person visit.
Dr. Thomas Milam, Chief Medical Officer, Iris Telehealth
I was pleased to see there are still a lot of flexibilities around opiate treatment programs in the 2025 PFS. The high risk of intentional and accidental deaths associated with opiates and the fentanyl crisis warrant continued efforts in early screening, management and prevention strategies.
The opiate epidemic is still a major concern for CMS and among health care providers, so allowing flexibilities to use telehealth and other technologies to keep patients engaged in ongoing treatment is imperative.
Prior to the COVID-19 PHE, if someone needed buprenorphine to stay well and avoid withdrawal and relapse, they had to go to a clinic in person, attend to their appointments for med management and therapy, and get drug screens – everything had to be done in person.
Now, a lot of this process takes place over the phone and helps lower the risk that someone might relapse or overdose. As policies around this patient population evolve, it’s critical that CMS and SAMSHA continue working together to recognize the vulnerability and importance of people struggling with opiate use disorder.
New G-codes can help promote provider collaboration
CMS is finalizing six G-codes that will be billed by people who have limitations in their statute to services for diagnosis and treatment, mental illness, psychologists, social workers and management. These codes will mirror current interprofessional consultation and CBT codes.
There’s also more recognition in healthcare that provider communication around patient care is of high importance.
For example, eConsults weren’t previously paid for, but now there’s recognition that collaboration is real work and adds value for patients and providers. Reimbursing healthcare providers for their interprofessional communication and identifying the work that different care teams are engaged in together to keep patients well is an important step in the right direction.
CMS also shared they are finalizing a policy to continue allowing direct supervision via interactive, real-time audio-visual platforms to extend various types of supervision for providers who may require it such as like nurse practitioners, therapists, physician’s assistants.
While there seems to be hesitancy around using audio-only modalities for supervision and care delivery, they will hopefully still be viable options given the rural locations of so many patients and providers in the US.
Where Iris fits in
At Iris, we believe in a future that helps more people get the high-quality behavioral health they need and deserve – regardless of where they live. Virtual care is an important part of the future of healthcare and will continue to increase access to care for those who need it most.
Want to learn more about what the final rule means for your organization? Reach out to talk to someone today – you can contact us here!
You can also get more information and read more about the new CMS rule here.
