CEO Update 252
NABH Wants to Hear from You: Please Rank the 2026 Annual Meeting Breakout Session Topics!
NABH is revising its Annual Meeting format in 2026 and will introduce Breakout Sessions to engage attendees during the meeting in between the General Sessions.
Please take a moment to answer this one-question survey and rank the listed issue areas from your greatest priority (1) to your lowest priority (8).
Thank you for your time, and please read upcoming issues of CEO Update for more 2026 Annual Meeting information.
CMS Incorporates NABH Recommendations in the Final 2026 Physician Fee Schedule Rule
NABH is pleased to report the Centers for Medicare & Medicaid Services (CMS) incorporated some of the association’s recommendations in the final calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) rule the agency released on Oct. 31.
In our comments to CMS on the proposed rule, NABH supported adding the three new HCPCS G-codes to incentivize and compensate for collaborative care for behavioral health conditions for Advanced Primary Care Management (APCM) services. CMS finalized the three new codes, expanding coverage to address comorbid physical health conditions that are common among people with behavioral health conditions.
NABH is also pleased that CMS finalized coverage for digital mental health treatment (DMHT) devices used in the treatment of Attention-Deficit/Hyperactivity Disorder. Presently, CMS covers DMHT devises that have received U.S. Food and Drug Administration (FDA) clearance, approval, or authorization. In the proposed rule, we expressed concerns with CMS expanding coverage for digital tools that have not been subjected to FDA oversight. In the final rule, CMS did not establish coding for a broader set of digital tools intended as complements to mental health treatment but will consider doing so in future rulemaking.
CMS finalized its proposed policy to include marriage and family therapists (MFTs) and mental health counselors (MHCs) as practitioners who can bill Medicare directly for Community Health Integration services (HCPCS codes G0019 and G0022), Principal Illness Navigation services (HCPCS codes G0023 and G0024), and Principal Illness Navigation – Peer Support (HCPCS code G0146).
NABH also supported CMS’ proposal to extend or make permanent certain telehealth flexibilities, including permanently removing frequency limitations for subsequent inpatient visits. CMS finalized that proposal, as well as a proposal to adopt permanently a definition of direct supervision to include virtual presence via appropriate audio/video real-time communication technology.
Finally, NABH urged CMS to consider extending the waiver allowing providers to report practice addresses instead of home addresses when they perform telehealth services from their home. We are disappointed CMS did not address this issue in the final rule.
Please see CMS’ fact sheet about the final PFS rule for more information.
Center for Connected Health Policy Releases 2025 State Telehealth Policy Summary
The Center for Connected Health Policy (CCHP) recently released its 2025 State Telehealth Policy Summary.
The Fall 2025 Summary Report includes state telehealth laws and Medicaid program policies and links to an updated online Policy Finder tool. The report provides a national overview of state telehealth policy and the Policy Finder offers state-specific information for the 50 states, District of Columbia, Puerto Rico, and the Virgin Islands.
The report includes laws, regulations, and policy documents on an array of telehealth topics, including Medicaid and Medicare reimbursement, private payer laws, professional requirements, and federally qualified health centers (FQHCs).
AAPC to Host Webinar on Improving Accuracy & Documentation in Behavioral Health Claims
Experts from firm AAPC – the nation’s largest education and credentialing organization for medical coders, billers, auditors, practice managers, documentation specialists, compliance officers, and revenue cycle managers – will host a webinar next week to share insights into how credentialed professionals can navigate behavioral health compliance challenges.
The webinar will help attendees learn how to recognize documentation and coding pitfalls, prevent payor denials through staff credentialing and structured training, strengthen audit readiness, and more.
Click here to register for the webinar on Tuesday, Nov. 11 at 1 p.m. ET.
Please Submit Your Updates for NABH’s Online Membership Directory
NABH asks all members to submit any changes to their organization’s profiles for the association’s Membership Directory, which we publish online only.
Your system’s information is the critical data we need to provide a more accurate description of our members to policymakers, regulators, and the media in our advocacy efforts.
To help ensure we have the most accurate member information, please use the link to our membership update tool that was sent in September to all system members and verify your system’s information. Please be sure to enter information on all of your system’s facilities so that we have a better picture of our diverse membership.
Please contact Maria Merlie at maria@nabh.org or 202-393-6700, ext. 104 for assistance or if you require the membership update tool link to be resent. Thank you for your time.
Fact of the Week
North Carolina Gov. Josh Stein (D) signed a law this past summer requiring the North Carolina Department of Health and Human Services to suspend, rather than terminate, Medicaid coverage for people entering jails, bringing the state in line with federal requirements that become effective on Jan. 1, 2026. This distinction is notable because Medicaid generally does not pay for health care provided in state and local prisons and jails. Learn more here from a Pew report about the issue.
Many Thanks to All Veterans!
As Veterans Day approaches, NABH thanks its members and their families who have served or are serving in the U.S. military. We appreciate your sacrifice and service.
For questions or comments about this CEO Update, please contact Jessica Zigmond.