Medicare changes in 2025

The Centers for Medicare and Medicaid Services (CMS) adopted several recommendations from APA Services, SPTAs, and psychologists who submitted comments on the proposed rule. Psychologists will see changes and opportunities in key areas such as telehealth and new codes.

Safety planning interventions and postdischarge telephonic follow-up contact intervention services

For CY2025, CMS implemented separate coding and payment for safety planning interventions which involve patients in crisis working with a clinician to develop a personalized list of coping and response strategies and sources of support that the person can use in the event of experiencing thoughts of harm to themselves or others. This is not a suicide risk assessment, but rather, an intervention provided to people determined to have elevated risk of suicide or overdose.

Healthcare Common Procedure Coding System (HCPCS) code G0560 is a standalone, time-based service that can be billed in  20-minute increments when safety planning interventions are personally performed by the billing practitioner, either in-person or via telehealth. Billing practitioners can be any practitioner who is authorized to furnish services for the diagnosis and treatment of mental illness, including Psychologists, Clinical Social Workers, Mental Health Counselors, Marriage and Family Therapists, as well as physicians and NPPs. Furnishing and billing for safety planning interventions performed on the same day as a psychotherapy or an evaluation and management (E/M) visit is allowable but is not required.

G0560: Safety planning interventions, each 20 minutes personally performed by the billing practitioner, including assisting the patient in the identification of the following personalized elements of a safety plan: recognizing warning signs of an impending suicidal or substance use-related crisis; employing internal coping strategies; utilizing social contacts and social settings as a means of distraction from suicidal thoughts or risky substance use; utilizing family members, significant others, caregivers, and/or friends to help resolve the crisis; contacting mental health or substance use disorder professionals or agencies; and making the environment safe.

• Work RVU = 1.09
• Total nonfacility RVU = 1.27
• Medicare nonfacility payment = $42.42

For telephonic follow-up contact intervention (FCI) services, CMS implemented HCPCS code G0544 as a monthly bundle. FCI is a specific protocol of services for individuals with suicide risk involving a series of telephone contacts between a provider and patient following discharge from the emergency department and other relevant care settings and is designed to reduce the risk for subsequent adverse outcomes.

To report code G0544, the practitioner must have at least one real-time telephone interaction with the patient, lasting between 10–20 minutes. This does not include unsuccessful attempts to reach the patient. FCI calls aim to encourage use of the Safety Plan and updating it to optimize effectiveness, expressing psychosocial support, and helping to facilitate engagement in any indicated follow-up care and services. Obtaining verbal or written beneficiary consent is required either prior to, or during the initial phone call, and must be documented in the patient record.

Telephonic FCI can be performed and billed regardless of whether safety planning intervention (code G0560) was also furnished and billed for the same patient. Further, in contrast to code G0560, telephonic FCI can be provided by auxiliary personnel incident to the services of the billing practitioner.

G0544: Post discharge telephonic follow-up contacts performed in conjunction with a discharge from the emergency department for behavioral health or other crisis encounter, 4 calls per calendar month

• Work RVU = 0.98
• Total nonfacility RVU = 2.00
• Medicare nonfacility payment = $66.80

Interprofessional consultation billed by practitioners authorized by statute to treat behavioral health conditions

CMS is implementing HCPCS codes G0546–G0551 to facilitate interprofessional consultations between treating/requesting practitioners and consultant practitioners, when one or both of the practitioners is in a specialty whose covered services are limited by statute to the diagnosis and treatment of mental illness, and cannot independently bill Medicare for E/M services. These new G-codes are identical to the current CPT^® codes for Interprofessional Consultation services (codes 99446–99449 and 99451–99452). Although APA believes it is appropriate for payers to reimburse psychologists for the current CPT codes, Medicare and some payers limit billing of these codes to the types of providers who can independently bill Medicare for E/M visits; therefore, the new HCPCS codes aim to address this coding issue by appropriately recognizing and reimbursing for the time and effort of performing consultations.

G0546: Interprofessional telephone/internet/electronic health record assessment and management service provided by a practitioner in a specialty whose covered services are limited by statute to services for the diagnosis and treatment of mental illness, including a verbal and written report to the patient’s treating/requesting practitioner; 5–10 minutes of medical consultative discussion and review

• Work RVU = 0.35
• Total nonfacility RVU = 0.53
• Medicare nonfacility payment = $17.14

G0547: 11–20 minutes of medical consultative discussion and review

• Work RVU = 0.70
• Total nonfacility RVU = 1.07
• Medicare nonfacility payment = $34.61

G0548: 21–30 minutes of medical consultative discussion and review

• Work RVU = 1.05
• Total nonfacility RVU = 1.62
• Medicare nonfacility payment = $52.40

G0549: 31 or more minutes of medical consultative discussion and review

• Work RVU = 1.40
• Total nonfacility RVU = 2.17
• Medicare nonfacility payment = $70.19

G0550: Interprofessional telephone/internet/electronic health record assessment and management service provided by a practitioner in a specialty whose covered services are limited by statute to services for the diagnosis and treatment of mental illness, including a written report to the patient’s treating/requesting practitioner, 5 minutes or more of medical consultative time

• Work RVU = 0.70
• Total nonfacility RVU = 1.00
• Medicare nonfacility payment = $32.35

G0551: Interprofessional telephone/internet/electronic health record referral service(s) provided by a treating/requesting practitioner in a specialty whose covered services are limited by statute to services for the diagnosis and treatment of mental illness, 30 minutes

• Work RVU = 0.70
• Total nonfacility RVU = 1.05
• Medicare nonfacility payment = $33.96

APA resources on interprofessional consultation services (codes 99446–99449, 99451–99452) are available online:

• How to report interprofessional telephone/internet/electronic health record consultations
• Utilizing interprofessional telephone/internet/electronic health record consultations CPT® codes for psychologists

These resources will be updated to account for the new HCPCS codes G0546–G0551.

Digital mental health treatment

CMS established three new HCPCS codes for digital mental health treatment (DMHT) devices furnished incident to or integral to professional behavioral health services used in conjunction with ongoing behavioral health care treatment under a behavioral health treatment plan of care.

The first code, G0552, is payable only when the following criteria are met:

• The DHMT device has been cleared, approved, or granted De Novo authorization by the Food and Drug Administration (FDA).
• The billing practitioner is incurring the cost of furnishing the DMHT device to the beneficiary.
• Furnishing of the DMHT device is incident to the billing practitioner’s professional services in association with ongoing behavioral health treatment under a plan of care by the billing practitioner.
• The billing practitioner diagnoses the patient with a mental health condition and orders the DMHT device.

HCPCS code G0552 is not payable in cases where the billing practitioner incurs no cost in acquiring and furnishing the DMHT device, or a patient procures the DMHT device independent of the practitioner.

Due to the rapidly evolving technologies and cost of DMHT therapies, CMS believes that they do not have sufficient information needed to establish national pricing for devices under HCPCS code G055; therefore, they have finalized contractor pricing for this service. APA Services will advocate that CMS determine a set reimbursement value, as we believe carrier pricing will serve as a barrier to psychologists using this technology and expanding access to behavioral health services.

Auxiliary personnel that meet regulatory requirements [42 CFR 410.26(a)(1)] may only provide part of the initial education and onboarding described in HCPCS code G0552, but cannot independently report the code, as they do not have the statutory authority to serve as the billing practitioner.

G0552: Supply of digital mental health treatment device and initial education and onboarding, per course of treatment that augments a behavioral therapy plan

• Work RVU = carrier priced
• Total RVU = carrier priced
• Medicare reimbursement = carrier priced

The patient’s use of the device is intended to treat or alleviate a mental health condition, in conjunction with ongoing behavioral health care treatment under a behavioral health treatment plan of care, delivering a mental health treatment intervention that has a demonstrable positive therapeutic impact on a patient’s health. Managing the patient’s use requires the billing practitioner or that billing practitioner’s clinical staff must monitor the patient’s therapeutic response to the DMHT device and adjust the behavioral health therapy plan as needed. This work is reported using HCPCS codes G0553 and G0554 which describe monthly treatment management services.

G0553: First 20 minutes of monthly treatment management services directly related to the patient’s therapeutic use of the DMHT device that augments a behavioral therapy plan, physician/other qualified health care professional time reviewing information related to the use of the DMHT device, including patient observations and patient specific inputs in a calendar month and requiring at least one interactive communication with the patient/caregiver during the calendar month

• Work RVU = 0.62
• Total nonfacility RVU = 1.60
• Medicare nonfacility payment = $51.75

G0554: Each additional 20 minutes of monthly treatment management services directly related to the patient’s therapeutic use of the DMHT device that augments a behavioral therapy plan, physician/other qualified health care professional time reviewing data generated from the DMHT device from patient observations and patient specific inputs in a calendar month and requiring at least one interactive communication with the patient/caregiver during the calendar month (List separately in addition to HCPCS code G0553)

• Work RVU = 0.61
• Total nonfacility RVU = 1.23
• Medicare nonfacility payment = $39.79

Treatment management services should only be billed when there is ongoing use of the DMHT device and should not be billed in cases where the patient discontinues use of the DMHT device.

Individual behavior management/modification caregiver training services

Current CPT coding (codes 96202 and 96203) allows for multiple family group behavior management and modification training, meaning that this caregiver training service can only be furnished in a group setting with multiple sets of caregivers representing multiple beneficiaries. In recognition of cases when caregiver behavior management and modification training is not furnished in a group setting, but instead provided to the caregiver(s) of an individual patient, CMS established coding and payment for two new HCPCS codes (G0539–G0540).

As with the group-based caregiver training services, providers are required to obtain the patient’s consent for the caregiver(s) to receive caregiver training services and this must be documented in the patient’s medical record.

G0539: Caregiver training in behavior management/modification for caregiver(s) of patients with a mental or physical health diagnosis, administered by physician or other qualified health care professional (without the patient present), face-to-face; initial 30 minutes

• Work RVU = 1.00
• Total nonfacility RVU = 1.61
• Medicare nonfacility payment = $52.08

G0540: Caregiver training in behavior management/modification for parent(s)/guardian(s)/caregiver(s) of patients with a mental or physical health diagnosis, administered by physician or other qualified health care professional (without the patient present), face-to-face; each additional 15 minutes

• Work RVU = 0.54
• Total nonfacility RVU = 0.79
• Medicare nonfacility payment = $25.55

Although APA strongly disagreed with the CMS proposal to value G0539 and G0540 by directly crosswalking them to CPT codes 97550 and 97551 respectively and encouraged them to instead consider a direct crosswalk to CPT code 90832; Psychotherapy, 30 minutes with patient, that has a work RVU of 1.78 and more accurately reflects the resource costs incurred when a billing practitioner performs individual behavior management/modification caregiver training services, CMS disagreed with our alternate valuation proposal and finalized the values as indicated above.

Another partial victory for APA as CMS agreed to permanently allow opioid treatment programs to furnish periodic assessments via audio-only telecommunications beginning January 1, 2025, but only in cases where a beneficiary does not have access to two-way audio-video communications technology. The agency is codifying that services to initiate treatment with methadone may be furnished via two-way interactive audio-video communication technology.

CMS has made the following changes for 2025:

• Adding caregiver training services (CPT codes 97550, 97551, 97552, 96202, 96203 and HCPCS codes G0541–G0543 and G0539–G0540) to the Medicare Telehealth Services list for CY 2025 on a provisional basis.
• Continuing to allow the use of practice locations instead of home addresses for telehealth services.
• Extending for calendar year 2025 the definition of direct supervision, which allows a supervising provider to be considered “immediately available” through virtual presence using audio/video real-time communications technology (excluding audio only).
• Continuing to allow teaching professionals to have a virtual presence in all teaching settings, but only for services furnished as a Medicare telehealth service.
• Will continue to delay the in-person visit requirement for telemental health services by Rural Health Clinics and Federally Qualified Health Centers to beneficiaries in their homes until January 1, 2026.

APA Services also recommended that CMS allow two-way, real-time audio-only communication technology for any telehealth service provided to a beneficiary at home, regardless of whether two-way audio-visual communication was available. In a partial victory, CMS agreed to permanently include audio-only communication technology for any telehealth services furnished to beneficiaries in their homes so long as the distant site practitioner is technically capable of using two-way, real-time interactive communication but the patient is not capable of, or does not consent to, the use of video technology.

A key concern of many psychologists was the extension of existing telehealth waivers and the implementation of the in-home visit requirement for telehealth services in 2025. Although the in-person requirement was written into federal law several years ago, it has subsequently been delayed by Congress.

Psychologists treating Medicare beneficiaries should note that behavioral health services for mental health disorders furnished via telehealth were permanently excluded from the site requirements under the Consolidated Appropriations Act of 2021. Payment for behavioral health services delivered to Medicare patients in their homes through telehealth is permanently set at the nonfacility rate.

The American Relief Act 2025 signed into law on December 21, 2024, extends key telehealth flexibilities in Medicare until March 31, 2025. This extension continues the delay of the in-person visit requirement for behavioral telehealth services in Medicare until April 1, 2025. APA Services is working to support federal legislation to eliminate the in-person requirement.

Psychological and neuropsychological testing will continue to be covered when provided via telehealth services on a provisional basis for all of 2025. APA will pursue the addition of these codes to the CMS permanent telehealth list.

CMS has acknowledged that the current rate-setting methodology for practice expense (PE) negatively impacts certain services, including behavioral health services, and has requested information on potential changes to improve the methodology and PE reimbursement. APA Services made three PE methodology recommendations to improve PE valuation and reimbursement for behavioral health services. CMS did not take action on APA’s recommendations. APA Services will continue to engage CMS and advocate for changes to improve PE valuation and reimbursement for behavioral health services.

CMS did not adopt the APA Services recommendation to increase the work values for the psychological and neuropsychological testing codes, commensurate with work value increase CMS has provided for psychotherapy services. APA Services will continue to engage CMS and advocate for work value increases for the psychological and neuropsychological testing codes.

Reimbursement, always critical to maintaining a viable practice, will vary depending upon the services psychologists provide. All clinicians will be impacted by the loss of 2.83% in Medicare payments due to the reduction in the conversion factor (CF) for 2025.

There was initially a provision in the American Relief Act 2025 to add 2.5% to the 2025 Medicare CF to help offset the projected 2.83% decrease but was dropped from the final version of the bill, so the CF has dropped from $33.29 in 2024 to $32.35 in 2025.

CMS has projected that on average psychologists as a profession will see an increase of 3% in payments, enough to offset the CF loss. This is due to increases in the work values for psychotherapy and health behavior assessment and intervention services. Beginning in 2024, CMS implemented an increase in the work values for these services by 19.1% over a 4-year period.

So, psychologists will see different changes in their payments depending on the services they provide. Because CMS has increased the work values for psychotherapy services, psychologists billing for psychotherapy will receive a slightly higher payment in 2025 than they did in 2024 despite the lower CF.

APA, along with a multitude of other specialty societies, is actively pursuing a fix to the 2025 CF through federal legislation.

The beginning of the calendar year is a good time for psychologists to review their patients’ current or potential Medicare status. Many patients may have changed their coverage during the 2024 Medicare enrollment period so psychologists would be wise to confirm whether their patients will be on traditional fee-for-service Medicare, a Medicare Advantage (MA) plan (and if so, which one), or have other third-party coverage in 2025. For patients with coverage under a new MA plan, verify what type of plan it is and if there are coverage restrictions for out-of-network providers.

Psychologists with patients signing up for Medicare Part B should confirm when the patient’s coverage starts as this can vary for several reasons, including when the patient enrolls, how long they have other third-party insurance, and if they choose to delay the start of Part B coverage. This information is especially important for psychologists who have opted out of Medicare and will only be able to continue to treat the patient under a private contract.

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