Below is a summary of how CMS addressed the policies raised in the grassroots campaign, as well as by APA Services and SPTAs.
For 2026, psychologists will receive an increase in Medicare reimbursement for most outpatient psychological services. Four codes (96132, 96112, 96170, and 96171) will receive a decrease in reimbursement due to Practice Expense (PE) methodology changes implemented for 2026. CMS did not accept APA’s PE methodology recommendations but indicated that they may address our recommendations in future rulemaking. APA will continue to advocate that CMS address the practice expense methodology changes.
Here are a few examples of the Medicare outpatient reimbursement changes for 2026.
CPT® Code2025 Non-Facility Payment Rate2026 Non-Facility Payment Rate2025 to 2026 Final Payment Change ($)2025 to 2026 Final Payment Change (%)90791$166.91$173.35$6.443.86%90837$154.29$167.00$12.718.24%90847$102.86$109.55$6.696.51%90853$28.14$30.39$2.258.01%96116$88.63$94.19$5.566.27%96130$117.42$123.92$6.505.54%96131$82.81$86.51$3.704.47%96132$125.18$122.25-2.93-2.34%96133$93.48$97.86$4.384.69%96156$98.98$107.55$8.578.66%96158$67.93$73.82$5.898.67%96159$23.29$25.38$2.109.00%
CMS did finalize modifications to the indirect practice expense methodology. Previously, indirect costs for practice expense relative value units in the facility or hospital setting were allocated at the same rate as the non-facility or office-based setting. But for 2026, indirect practice costs from facility-based services will be redistributed to non-facility-based services. CMS believes that this change, recognizing greater indirect costs for providers that practice in office-based settings, will better reflect current clinical practice. This will result in decreased reimbursement for facility-based services.
CMS finalized a policy supported by APA members to move all “provisional” telehealth services, including but not limited to developmental, psychological, and neuropsychological testing services, to the permanent Medicare Telehealth Services list.
CMS also approved the addition of two new codes to the Medicare Telehealth Services List, including multiple-family group psychotherapy (code 90849) and group behavioral counseling for obesity (code G0473), a common form of intensive behavioral therapy (IBT) for treatment of obesity.
CMS finalized its proposal to permanently adopt a definition of “direct supervision” that allows “immediate availability” of the supervising practitioner using audio/video real-time communications technology (excluding audio-only). However, the agency clarified that they are not making any changes to the requirements currently in place for the supervision policy for teaching physicians, who must still be present during the portion of the service that determines the level of service billed. Teaching physicians can maintain virtual presence in all teaching settings during key portions of telehealth services. CMS also clarified that no changes to long-standing supervision norms for Evaluation and Management (E/M) services—virtual presence is acceptable for the portion determining service level.
APA urged CMS to finalize and formalize the current flexibility, allowing providers to permanently use their affiliated practice addresses for billing when providing telehealth services from the providers home. CMS does not believe that additional “extensions” are required via rulemaking given that CMS issued an FAQ providing additional information on how to suppress street address details when providing telehealth services from their home.
While CMS adopted a new MIPS Value Pathway (MVP) for neuropsychology, several modifications were made to the original proposal, which resulted in the utility of the MVP to be limited to patients with a dementia diagnosis, which significantly understates the array of services performed by neuropsychologists. APA staff have already engaged with CMS staff to advocate the MVP be restored and include all the components APA initially proposed.
In response to CMS plan of sunsetting of MIPS to MIPS Value Pathways, APA encouraged CMS to retain traditional MIPS for those providers for whom no MVPs are relevant or are not feasibly able to be implemented and instead reduce the number of quality measures reported from 6 to 4 to better align with MVPs. CMS reiterated that while traditional MIPS continues to be a reporting option, they intend to end traditional MIPS in the future, at which point MVPs would become mandatory. That future date has not been determined and will be established through the official notice and comment rulemaking process.
APA recommended that CMS continue to retain the current minimum performance threshold of 75 points for MIPS reporting and maintain that threshold through the 2030 MIPS payment year. CMS finalized they will continue to use the mean final score from the CY 2017 performance period/2019 MIPS payment year for the CY 2026 performance period/2028 MIPS payment year through the CY 2028 performance period/2030 MIPS payment year. On this basis, CMS set the performance threshold at 75 points through the CY 2028 performance period/2030 MIPS payment year.
While CMS agreed not to delete HCPCS code G0136, they did not adopt APA’s recommendation to retain this code for general assessment of Social Determinants of Health (SDOH). Instead, CMS modified the code descriptor to limit applicability to “Administration of a standardized, evidence-based assessment of physical activity and nutrition, 5–15 minutes, not more often than every 6 months.” CMS did, however, finalize their proposal to allow psychiatric diagnostic evaluation (CPT code 90791) and Health Behavior Assessment and Intervention (HBAI) services (codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168) to serve as the initiating visit for this revised service.
CMS did not adopt APA members’ recommendation to establish a national price for the supply of Digital Mental Health Treatment (DMHT) and Remote Therapeutic Monitoring (RTM) tools but will continue to gather information and may revisit this issue in future rulemaking. APA will continue to advocate that CMS address this issue.
APA supported and CMS finalized their proposal to expand DMHT coverage to include digital therapy devices for Attention Deficit Hyperactivity Disorder (ADHD). Payment for DMHT devices cleared under section 510(k) of the FD&C Act or granted De Novo authorization by FDA and in each instance classified at 21 CFR section 882.5803, Digital therapy device for Attention Deficit Hyperactivity Disorder (ADHD).
APA also encouraged CMS to expand the DMHT codes to include device classifications for: computerized behavioral therapy devices for treating symptoms of gastrointestinal conditions under 21 CFR 876.5960; digital therapy devices to reduce sleep disturbance for psychiatric conditions under 21 CFR 882.5705; and computerized behavioral therapy device for the treatment of fibromyalgia symptoms to be codified at 21 CFR 882.5804, for CY 2026. CMS did not accept our recommendation but stated they may consider expanding payment policy to include them under future rulemaking.
Given the difficulties with carrier pricing and payment policy for DMHT at this time, APA recommended CMS not establish additional separate coding and payment for wellness digital tools used by practitioners intended for maintaining or encouraging a healthy lifestyle, as part of a mental health treatment plan of care for CY2026. CMS is not finalizing any new coding and payment for such digital tools at this time, but may in future rulemaking.
CMS requested information on the need for separate coding for motivational interviewing provided by health coaches. APA did not recommend that CMS establish separate coding and payment for motivational interviewing, as Health and Well-Being Coaching Category III codes (0591T, 0592T, 0593T), Community Health Integration (CHI) services (codes G0019, G0022) and Principal Illness Navigation (PIN) services (codes G0023, G0024) already offer a mechanism for reporting, and include the resources involved in furnishing, this service. CMS expressed appreciation for the feedback from commenters and will take the comments into consideration for possible future rulemaking.
CMS adopted a recommendation by APA members to allow psychiatric diagnostic evaluations (CPT code 90791) and Health Behavior Assessment and Intervention services (CPT codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168) to serve as initiating visits for Community Health Integration.
APA Services will continue to engage with CMS staff to address these issues and further advocate for psychologists and policies to improve access to behavioral health services.