On June 16, 2025, APA Services submitted a response to a joint request for information (RFI) about the digital health technology ecosystemopens in new window from the Centers for Medicare and Medicaid Services (CMS) in partnership with the Assistant Secretary for Technology Policy’s Office of the National Coordinator for Health Information Technology (ASTP/ONC). The RFI requested feedback from providers, payers, patients, caregivers, technology developers, and other stakeholders about digital health products for Medicare beneficiaries and the broader health data infrastructure.
Given the broad scope of the RFI, the letter focused on several key areas: Improving infrastructure for using the new Digital Mental Health Technologies billing codes; reforming quality reporting measures and processes; increasing funding and other support for greater provider adoption of electronic health records; encouraging development of standardized data sets and technological tools that comply with heightened privacy protections for mental health care; and engaging in more robust provider education efforts on information blocking and interoperability.
In its response, APA Services noted that many of the questions raised in the RFI presume that providers have certified electronic health records (EHRs) and related technical capabilities, such as online patient check-in and secure online portals allowing patients to access their records and manage their information. We noted that because many psychologists and other mental/behavioral health and substance use treatment providers work in small and solo practices, they often lack the necessary IT staff and financial resources to implement new health information technologies. We encouraged the federal government to take steps to address this lack of resources to help psychologists advance in adopting health information technology.
The letter also encouraged CMS to consider expanding the pool of eligible digital mental health treatment (DMHT) tools that would qualify for reimbursement under the newly established billing codes (new G codes for DMHT devices); provide guidance to Medicare Administrative Contractors about the use of those codes; set a national reimbursement rate for those codes; and ensure that those codes can be used for telehealth services involving DMHT tools.
APA Services also asked CMS to carefully consider how artificial intelligence is integrated into health care technologies, and how AI use raises ethical issues related to transparency, bias, data security, and misinformation, as well as professional liability. The letter emphasized the need for more input from psychologists and other mental health providers in continuing to develop standardized data sets and technology tools that create, store, and share sensitive mental health data.
APA Services will continue to advocate for policies to promote the development of a health technology ecosystem that will improve population health and safeguard patients’ sensitive health data.
