CEO Update 237
CMS Releases CY 2026 Outpatient Prospective Payment System Proposed Rule
The Centers for Medicare & Medicaid Services (CMS) on Tuesday, July 15 released its Calendar Year 2026 Outpatient Prospective Payment System (OPPS) proposed rule along with an accompanying fact sheet.
In it, CMS proposed to increase payment rates by 2.4%, reflecting an inpatient market basket increase of 3.2% minus a productivity adjustment of 0.8 percentage point.
The agency also proposed collecting hospitals’ median negotiated payer-specific charges with Medicare Advantage organizations by Medicare Severity Diagnosis Related Groups (MS-DRGs), which would be used to inform changes to the Inpatient Prospective Payment System MS-DRG relative weights beginning in Fiscal Year 2029.
Other changes specific to behavioral healthcare services are largely limited to partial hospitalization programs (PHPs) and intensive outpatient programs (IOPs) delivered by community mental health centers, for which CMS proposes modifying the payment rate methodology to be 40% of the corresponding hospital-based rates to promote payment accuracy and stability. Meanwhile, the payment rate methodology for hospital-based PHPs and IOPs would remain the same.
NABH continues to review the OPPS proposed rule. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.
CMS Proposes Broader Medicare Coverage of Select Behavioral Health Services in CY 2026 Physician Fee Schedule
CMS also released its CY 2026 Medicare Physician Fee Schedule (PFS) proposed rule and accompanying fact sheet earlier this week.
The agency CMS estimates that the proposed policy changes would, on average, affect allowed charges for behavioral health specialists as follows:
- Psychiatrists: +6% (non-facility), -9% (facility)
- Clinical psychologists: +5% (non-facility), -3% (facility)
- Clinical social workers: +6% (non-facility), -2% (facility)
These changes can be attributed to broader modifications to reimbursement calculation, such as practice expense methodology changes to capture increased indirect costs of non-facility practitioners, and a higher conversion factor for practitioners participating in a qualifying alternative payment model (+3.83%) compared with those who are not (+3.62%).
NABH is pleased to see the proposed rule aims to improve coverage of certain behavioral healthcare services in various ways, such as creating three optional add-on codes to advanced primary care management that would better enable the provision of behavioral health integration and collaborative care model services; expanding coverage of digital therapeutics to include those to treat attention-deficit/hyperactivity disorder; and permitting clinical social workers, marriage and family therapists, and mental health counselors to bill for community health integration services.
CMS is also seeking public comment on the possible expansion of coverage of motivational interviewing; and potential changes to the query of prescription drug monitoring program quality measure, including transitioning the measure from attestation- to performance-based, and expanding the scope of the measure to include Schedule II non-opioids.
NABH continues to review the PFS proposed rule and will solicit feedback from members soon. Please contact NABH Vice President of Public Policy Dan Schwartz if you have questions.
MedPAC Releases 2025 Data Book on Medicare Spending
The Medicare Payment Advisory Commission (MedPAC) has released its 2025 data book, which provides data on Medicare spending, demographics of the Medicare population, beneficiaries’ access to care, and quality of care in the program, among other information.
Click here to see the book’s section about acute inpatient services, which includes data about inpatient psychiatric facilities.
ICYMI: CHCS Webinar on Medicaid Innovation to Improve Behavioral Healthcare Access
The Center for Health Care Strategies this week hosted Medicaid Innovation in Improving Access to Behavioral Health Care, 75-minute webinar featuring state leaders from Colorado, Massachusetts, and Wyoming who discussed how they are tackling behavioral healthcare challenges and using Medicaid policy to improve access to high-quality care in their states.
Panelists explored how states can expand access, improve coordination, and modernize behavioral healthcare through cross-sector partnerships, workforce development, cross-agency data sharing, and integrated approaches to care.
ICYMI: HHS Announces Funding Opportunity for Behavioral Health Information Technology Pilot
HHS recently announced a funding opportunity to promote behavioral health data exchange and pilot the implementation of a specified set of behavioral health data elements.
HHS anticipates distributing $5 million across six to 10 participants, which will include a wide range of provider organizations that receive SAMHSA grant funds or partner with recipients. More information can be found in the Request for Application and Frequently Asked Questions document.
The deadline for the expression of interest was Wednesday, July 2. For those who expressed interest, full applications are due Wednesday, Aug. 27.
An HHS representative has offered to schedule a meeting between NABH members and the contractor administering the program to provide more detailed information and answer questions ahead of the application deadline.
Please contact Dan Schwartz if you are interested in attending such a meeting. NABH will schedule a meeting if there is sufficient interest.
Reminder: CMS Releases RFI to Gather Information on Improving Hospital Price Transparency
The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking public feedback about whether and how the agency can improve hospital price transparency (HPT) compliance and enforcement processes.
This RFI relates to the President’s Executive Order 14221 to ensure compliance with the transparent reporting of complete, accurate, and meaningful HPT data. Click here to read the RFI.
The deadline to respond to the RFI is Monday, July 21.
Fact of the Week
Psychiatric recommendations from four large language models (LLMs) – AI programs designed to understand and generate human language – changed when a patient’s record noted they were African American, researchers recently reported in the journal NPJ Digital Medicine.
For questions or comments about this CEO Update, please contact Jessica Zigmond.