By: Christopher A. Parrella, Esq., CPC, CHC, CPCO Parrella Health Law, Boston, Ma. A Health Care Provider Defense and Compliance Firm

On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) finalized changes to the Medicare Physician Fee Schedule (PFS) and Part B policies, marking a significant step in expanding access to healthcare services. Effective January 1, 2025, these changes address outpatient visit billing, broaden telehealth service coverage, and enhance support for behavioral health and opioid treatment programs.

Key Updates in 2025 Medicare Payment Policies

1. Enhanced Evaluation and Management (E/M) Services
   • CMS will allow a complexity add-on code, HCPCS code G2211, for office and outpatient E/M services, enabling practitioners to bill for additional complexity when performing an annual wellness visit, vaccine administration, or any preventive service.
   • The flexibility to include this complexity add-on emphasizes a commitment to reimbursing providers for the comprehensive care Medicare beneficiaries require.
2. Expanded Telehealth Services
   • The new rule preserves some COVID-era telehealth flexibilities, even as pre-COVID restrictions on geographic and provider locations come back into effect. Notably, CMS will add caregiver training, PrEP counseling, and safety planning interventions to the Medicare Telehealth Services List, solidifying permanent telehealth access for critical services.
   • Additionally, CMS will permit audio-only technology in cases where video communication isn’t feasible for the patient, ensuring continued access for patients who lack reliable internet or technology.
3. Behavioral Health Services Support
   • To bolster access to mental health support, CMS introduces separate billing codes for safety planning interventions, including suicide prevention. These interventions are billable in 20-minute increments, allowing providers to dedicate time to safety planning without risking reduced compensation.
   • CMS is also approving payments for digital mental health treatment devices as part of behavioral health care. This will allow Medicare beneficiaries access to FDA-approved digital tools to support mental health treatment plans.
4. Intensive Outpatient and Crisis Stabilization Services
   • CMS has invited further feedback on coding and payments for Intensive Outpatient Programs (IOP) and Certified Community Behavioral Health Clinics (CCBHCs). The agency’s focus on these services aims to address gaps in care for behavioral health patients needing urgent care or stabilization, potentially improving access in future rulemaking.
5. Opioid Treatment Programs (OTPs)
   • CMS introduces multiple telecommunication flexibilities to expand opioid use disorder (OUD) treatment access, such as allowing audio-only assessments and permitting virtual direct supervision for certain services.
   • New payment codes for nalmefene nasal spray and injectable buprenorphine formulations underscore CMS’s commitment to enhancing OUD treatment access. OTPs will now also receive reimbursement for critical care navigation and peer recovery support, addressing the social determinants of health that impact patient recovery.

Impact and What’s Next

These changes reflect CMS’s ongoing strategy to create an equitable, high-quality healthcare system with greater access and affordability. For healthcare providers, adapting to these new billing codes and policies is essential to leverage expanded reimbursement options fully. Behavioral health providers, telehealth practitioners, and OTPs, in particular, can take advantage of the updated policies to enhance care delivery and improve patient outcomes.

Call to Action

Healthcare providers should review these changes carefully and incorporate them into their billing practices to optimize care for Medicare beneficiaries in 2025. Behavioral health providers and OTPs are encouraged to leverage the new billing codes and consider integrating digital health tools into treatment plans. For assistance in navigating these updates or adjusting compliance protocols, please contact Parrella Health Law at 857-328-0382 or contact Chris directly at cparrella@parrellahealthlaw.com for guidance on implementing these Medicare changes.