Policy Update: Physician Fee Schedule Incl. Changes for
MH & SUD Providers & Care Recipients

November 2, 2022

Yesterday, the Centers for Medicare & Medicaid Services (CMS) announced the Calendar Year 2023 Physician Fee Schedule (PFS) final rule. We’re pleased to share that the final rule includes several National Council and New York State Council priorities that we fought to include. These are wins for mental health and substance use care organizations that will help expand access to care by strengthening the workforce.

Key highlights:

  • Telehealth Flexibility Extensions: CMS is extending a number of flexibilities implemented under the Public Health Emergency (PHE) for a 151-day period after the expiration of the PHE.
  • CMS is allowing behavioral health clinicians to offer services incident to a Medicare practitioner under general (rather than direct) supervision.
  • Licensed professional counselors and marriage and family therapists are now able to bill incident to Medicare practitioner for their services.
  • Medicare will allow opioid treatment programs to use telehealth to initiate treatment with buprenorphine for patients with opioid use disorder.
  • CMS is also clarifying that opioid treatment programs can bill for opioid use disorder treatment services provided through mobile units, such as vans, in accordance with Substance Abuse and Mental Health Services Administration (SAMHSA) and Drug Enforcement Administration (DEA) guidance.