Navigating Mental Health Billing Changes in 2025
Introduction
In 2025, mental health billing regulations will experience significant shifts, particularly in telehealth policies, digital therapeutics, reimbursement rates, and care management. Below is an in-depth exploration of mental health billing changes in 2025 with practical actions for mental health providers.
Mental Health Billing Changes in 2025
1. Telehealth Flexibility Extensions
CMS has extended telehealth flexibilities for mental health providers through the end of 2025. Key provisions include:
- Continuation of Audio-Only Services: Providers can deliver audio-only telemental health services for Medicare patients, which is particularly beneficial for those in rural or underserved areas.
- Waiver of In-Person Requirement: RHCs and FQHCs are allowed to offer telehealth without requiring an in-person visit until 2025, ensuring continuous remote care options.
Practical Actions:
- Review Telehealth Workflow: Ensure your practice’s telehealth platforms are compliant with CMS guidelines.
- Document Thoroughly: Clearly document the necessity for audio-only visits in patient records to support reimbursement claims.
- Billing Adjustments: Verify billing codes used for telehealth services to align with CMS updates and prevent denials.
2. New Digital Therapeutics Codes
CMS is introducing three new billing codes (GBMT1, GBMT2, GBMT3) for mental health treatment involving FDA-cleared digital therapeutic devices. These codes cover both the device costs and the clinician’s interaction time with the patient.
Practical Actions:
- Adopt Digital Tools: Evaluate and integrate FDA-approved digital therapeutic tools into your practice to enhance patient outcomes.
- Staff Training: Train staff to effectively use these devices and document patient interactions thoroughly to maximize billing efficiency.
- Consult Billing Experts: Collaborate with billing specialists to accurately utilize these new codes and avoid errors in claims submission.
3. Medicare Conversion Factor Adjustment
The 2025 proposed Medicare Physician Fee Schedule reduces the conversion factor by 2.8%, from $33.29 in 2024 to $32.36. This decrease may reduce reimbursements for mental health services.
Practical Actions:
- Maximize Coding Accuracy: Ensure accurate coding, including using modifiers like -25 when billing multiple services, to capture full reimbursement.
- Optimize Claims Management: Partner with billing services to reduce errors, expedite claims, and ensure prompt payments.
- Review Payer Contracts: Negotiate contracts with commercial payers to secure favorable reimbursement rates.
4. Advanced Primary Care Management (APCM) Codes
APCM codes (GPCM1, GPCM2, GPCM3) aim to streamline care management by bundling services related to chronic care management (CCM) and transitional care management (TCM). While primarily for primary care, these may overlap with behavioral health in integrated care settings.
Practical Actions:
- Collaborate with PCPs: Work closely with primary care providers to ensure that mental health services provided within a care team are billed correctly under APCM codes.
- Integrate Care Models: Explore integrating mental health care within APCM frameworks for patients with multiple chronic conditions.
5. Permanent Telehealth Policy Considerations
While many telehealth waivers require Congressional action to become permanent, CMS has proposed continuing virtual supervision and waiving the home address reporting requirement through 2025.
Practical Actions:
- Stay Informed: Monitor CMS and Congressional updates for permanent policy changes.
- Enhance Virtual Supervision: Leverage virtual supervision allowances for clinical staff to improve service delivery.
- Future-Proof Telehealth: Invest in robust telehealth platforms that meet evolving CMS and payer requirements.
To conclude,
These 2025 changes require proactive adjustments by mental health providers. Staying informed, optimizing billing practices, and leveraging expert billing support will be crucial to maintaining cash flow and enhancing service delivery. For tailored assistance, consider partnering with a specialized billing company like PrimeCare MBS to navigate these changes smoothly.
