The CMS Physician Fee Schedule: Submit comments, protect access, improve practice

Each year, psychologists have a tremendous opportunity to share their thoughts with the U.S. Centers for Medicare and Medicaid Services (CMS) on new policies, access to new services, and ways to improve coverage in Medicare by submitting comments on the Physician Fee Schedule proposed rule.

Released annually between June and August and followed by a 60-day comment period, the proposed rule outlines the agency’s new policy proposals, suggested changes to services, and forecasts provider payments for the coming year. After reviewing the public comments, CMS releases a final rule in November explaining which proposed changes will become final and take effect on January 1.

It’s an important time for psychologists to share feedback and concerns: CMS won’t know what psychologists and their patients need unless we tell them.

Psychologists who do not treat Medicare enrollees still have a stake in what’s happening with the nation’s largest health care program. Rules about coverage and codes for behavioral health services in Medicare—as well as the program’s reimbursement rates—heavily influence policies in state Medicaid programs and private health insurance companies. Your work in promoting psychology’s interests with CMS through the Medicare comment process will impact how behavioral health services are administered by other third-party payers such as private insurance, Medicare Advantage, and Tricare.

In 2025, thousands of psychologists shared their thoughts with CMS about critical issues in the proposed rule on the 2026 Medicare physician fee schedule.

Both CMS and members of Congress pay attention to Medicare issues that generate public outcries, and hearing from thousands of psychologists had a very positive impact. For 2026, CMS adopted several proposals offered by psychologists, including:

• Most psychological services received Medicare payment increases in 2026.
• Made all “provisional” telehealth services permanent, including psychological and neuropsychological testing and evaluation services.
• Added new services to the Medicare telehealth list, including multiple-family group psychotherapy (CPT 90849) and group behavioral counseling for obesity (G0473).
• CMS permanently allowed “direct supervision” via real-time audio/video technology, meaning the supervising provider can be remote (not physically present).

Psychologists, along with other specialty societies, made it clear that Medicare patients would lose access to critical behavioral health services if access to telehealth, including audio-only, was eliminated or restricted. CMS has since made changes, adding caregiver training services, continuing to allow the use of practice locations instead of home addresses, extending for CY 2026 the definition of direct supervision, and delaying the in-person visit requirement for telemental health services by Rural Health Clinics and Federally Qualified Health Centers.

Even though CMS did not make all our suggested changes for 2026, the agency indicated some issues are still up for discussion.

While CMS adopted several proposals for 2026 that benefited psychologists and their Medicare patients, the agency also deferred several issues for possible consideration in future rulemaking. Given what APA requested from CMS and the continued focus on behavioral health, we hope to see proposals focusing on the following areas:

• Work RVU adjustments to improve code valuation for psychological and neuropsychological testing and evaluation services
• Coding and reimbursement pathway for psychologists with prescription privileges
• Payment status for Family Without Patient Present CPT® codes
• Reform to the eligibility screening methods for the indirect practice expense floor

Before the 2027 proposed rule is released, psychologists should keep track of the challenges they face when treating patients. Adding real life examples to your comments helps CMS understand what impact the proposed changes will have if implemented. These examples are essential to improving care for beneficiaries residing in rural locations where access to services may be hampered by a limited number of providers, lack of public transportation, or little or no support from family or friends. Psychologists can speak on behalf of these patients when calling on Medicare for improvements in health care delivery.

As soon as the proposed rule is released, APA will alert members and conduct a thorough review of the proposed rule, outlining which issues are most important to psychologists and the provision of mental health, behavioral health, and health behavior services. APA will provide details on which proposals it supports and objects to, as well as samples of comment letters to help members prepare individual messages to send to CMS. APA’s Advocacy Office uses information from members’ comment letters when lobbying on Capitol Hill.

More information on the proposed rule, before and after its release, will be available on a dedicated action centeropens in new window, through state psychological associations, and APA’s grassroots network. Sign up to receive action alerts on the APA Services advocacy webpage and links to the action center once we have updated its content.