MPFS Strengthening Behavioral Health Billing for 2023

CY 2023 Medicare Physician Fee Schedule (MPFS)

The Centers for Medicare and Medicaid Services (CMS) on Nov. 1, 2022, released the final 2023 Medicare Physician Fee Schedule (MPFS), addressing Medicare payment and quality provisions in the coming year. The U.S. Department of Health and Human Services (HHS) through its Centers for Medicare & Medicaid Services (CMS) is expanding access to behavioral health care. The Calendar Year 2023 Physician Fee Schedule (PFS) final rule announced today also promotes innovation and coordinated care in the Medicare program through Accountable Care Organizations (ACOs). This rule directly supports the Administration’s commitment of strengthening behavioral health, which the President outlined in his first State of the Union Address, and the comprehensive strategy to tackle the nation’s mental health crisis. In this article, we shared key behavioral health billing updates from CY 2023 MPFS which would act as a baseline for your behavioral health billing for 2023.

MPFS Strengthening Behavioral Health Billing for 2023

In light of the current needs among Medicare beneficiaries for improved access to behavioral health services, CMS has considered regulatory revisions that may help to reduce existing barriers and make greater use of the services of behavioral health professionals, such as licensed professional counselors (LPCs) and Licensed Marriage and Family Therapists (LMFTs). Therefore, CMS is finalizing the proposal to add an exception to the direct supervision requirement under our ‘incident to’ regulation at 42 CFR 410.26 to allow behavioral health services to be provided under the general supervision of a physician or non-physician practitioner (NPP), rather than under direct supervision, when these services or supplies are furnished by auxiliary personnel, such as LPCs and LMFTs, incident to the services of a physician (or NPP).

CMS is also clarifying that any service furnished primarily for the diagnosis and treatment of a mental health or substance use disorder can be furnished by auxiliary personnel under the general supervision of a physician or NPP who is authorized to furnish and bill for services provided incident to their own professional services. CMS believes that this change will facilitate access and extend the reach of behavioral health services. Finally, CMS indicated in the final rule that we intend to address payment for new codes that describe caregiver behavioral management training in CY 2024 rulemaking.

Coverage for Opioid Use Disorder Treatment

In the 2022 CMS Behavioral Health Strategy, CMS included a goal to improve access to, and quality of, mental health care services and included an objective to ‘increase detection, effective management, and/or recovery of mental health conditions through coordination and integration between primary and specialty care providers.’ In line with the 2022 CMS Behavioral Health Strategy, CMS is strengthening access to vital behavioral health services. CMS is making it easier for Medicare beneficiaries to get behavioral health services, by allowing behavioral health clinicians like licensed professional counselors and marriage and family therapists to offer services under the general (rather than direct) supervision of the Medicare practitioner.

Medicare will pay for Opioid Treatment Programs that use telecommunications with patients to initiate treatment with buprenorphine. 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.  These policies may increase access in rural and other underserved areas. CMS is also finalizing policies to pay for clinical psychologists and licensed clinical social workers to furnish integrated behavioral health care as part of a primary care team. Finally, Medicare will provide a new monthly payment for comprehensive treatment and management services for patients with chronic pain. These new services offer a whole-person approach to care.

We referred recent CMS announcement regarding the ‘CY 2023 Medicare Physician Fee Schedule Final Rule’ to discuss how MPFS is strengthening behavioral health billing for 2023, you can refer following links for a detailed understanding. Medical Billers and Coders (MBC) is a leading medical billing company providing complete revenue cycle services. In such a revised behavioral health billing environment, we can assist you in receiving accurate reimbursement for delivered services. To know more about our behavioral billing and coding services, email us at: or call us at: 888-357-3226.


Calendar Year (CY) 2023 Medicare Physician Fee Schedule Final Rule

HHS Finalizes Physician Payment Rule Strengthening Access to Behavioral Health Services and Whole-Person Care