Advocacy & Policy Updates (2025)
APA Telehealth Services added to AMA CPT Manual (10/22/25)
APA recently reported that "several new services... will be recognized in the (American Medical Association) AMA’s 2026 CPT Professional (the official Current Procedural Terminology codebook/manual) as telehealth services". According to the APA:
-services "may be rendered via a real-time (synchronous) interactive audio-video and/or audio-only telecommunications system"
-the codes include those for "group psychotherapy (code 90853), group caregiver behavior management/modification training (codes 96202, 96203), developmental testing services (codes 96112, 96113), psychological and neuropsychological testing evaluation services (codes 96130, 96131, 96132, 96133), and psychological and neuropsychological test administration and scoring services (codes 96136, 96137, 96138, 96139)"
-"having codes listed on both the AMA and CMS telehealth lists should make it easier to advocate with commercial payers for continued reimbursement of these services provided by telehealth."
Read more here:
https://www.apaservices.org/practice/reimbursement/health-codes/telehealth-reporting-2026
CMS Claims Hold Lifted (10/22/25)
From the October 21 update: "CMS instructed all Medicare Administrative Contractors (MACs) to lift the claims hold and process claims with dates of service of October 1, 2025, and later for certain services impacted by select expired Medicare legislative payment provisions passed under the Full-Year Continuing Appropriations and Extensions Act, 2025...This includes telehealth claims that CMS can confirm are definitively for behavioral and mental health services."
Read more here: https://www.cms.gov/medicare/payment/fee-for-service-providers
CMS Medicare Claims- Updated Guidance (10/16/25)
From Dr. Stephen Gillaspy, APA's Deputy Chief, Health Policy and Healthcare Financing (with NCPA highlight):
"Overnight, CMS issued updated guidance to Medicare Administrative Contractors (MACs) instructing them to limit the Medicare claims hold for services provided on or after October 1, 2025, that are impacted by the expired Medicare legislative payment provisions, including telehealth services other than for behavioral or mental health care, and services provided in locations with a work geographic practice cost index (GPCI) below the 1.0 floor. For all other services, Medicare claims will continue to be processed and paid in a timely manner. To date, no payments have been delayed as statute already requires all claims to be held for a minimum of 14 days."
Read the full announcement from MLN Connects here:
Aetna and Duke Health Contract Negotiation (10/15/25)
On October 3, the office of the State Treasurer of North Carolina announced that Aetna and Duke Health had reached an agreement after months of negotiations. Aetna beneficiaries can continue to see Duke Health providers using their in-network benefits.
For more information:
Click here to read the NC State Treasurer press release.
Click here to read the Duke Health website.
NC DHHS Suicide Prevention Action Plan (10/15/25)
From the September 30 press release: "The North Carolina Department of Health and Human Services has released the state’s Suicide Prevention Action Plan for 2026–2030. The five-year plan outlines a coordinated, evidence-based approach and promising practices to reduce suicide deaths and self-harm injuries statewide."
Click here to read more.
NC Health Information Exchange Authority (HIEA) (10/15/25)
Click here to read the October newsletter.
Session Law 2025-37 and LPAs (10/15/25)
On July 1, Governor Stein signed HB 67 into law, becoming Session Law (SL) 2025-37. Part III of this new law addresses supervision and independent practice for Licensed Psychological Associates (LPAs) and becomes effective October 1.
NCPA has been advised that the NC Psychology Board will be sending information directly to licensees regarding this change.
For additional information or questions, members should contact the NC Psychology Board directly:
website: https://ncpsychologyboard.info/
email: info@ncpsychologyboard.org
Click here to read the new law here (Part III begins on Page 16).
North Carolina ACA Plans (10/8/25)
The North Carolina Department of Insurance (DOI) website provides information about individual and small-group market plans that are offered under the Affordale Care Act (ACA). In July, the DOI posted information about the rate changes that were requested by insurers for the 2026 plan year. Click here.
This page on the DOI website has "Rate Information for Public Disclosure" - Click here
This page on the DOI website has a link to a pdf with the "2026 Plan Year ACA Rate Filings" - Click here
In terms of the 2026 rates- according to an August WUNC article: "the health insurance companies offering marketplace plans have asked...for 2026 rate increases that range from 6.9 percent all the way up to an eye-popping 36.5 percent". Click here to read more.
Posting the requested rates is part of the rate review process required by the Centers for Medicare and Medicaid Services (CMS). Rates should be finalized before open enrollment for the 2026 ACA plans begins in November, and the final rates should be posted on the DOI website.
Aetna and the ACA
According to the DOI "2026 plan Year ACA Rate Filings" document referenced above, the following companies will be offering ACA plans in North Carolina in 2026: Ambetter, Amerihealth Caritas, BCBS, Care Source, Cigna, Oscar, and UnitedHealthCare.
Aetna is not on the list; according to multiple news sources, Aetna will withdraw all ACA individual and family plans at the end of 2025.
Forbes- Click here
NPR- Click here
Insurance News Net- Click here
Center for Medicare Advocacy (CMA) (10/8/25)
From the website: "The Center for Medicare Advocacy (CMA) is a national, non-profit, law organization that works to advance access to comprehensive Medicare coverage, health equity, and quality health care for older people and people with disabilities. Founded in 1986, CMA’s work includes legal assistance, advocacy, education, analysis, policy initiatives, and litigation of importance to Medicare beneficiaries nationwide, with an emphasis on the needs of people with longer-term and chronic conditions." Click here to learn more.
CMA offers a Comprehensive Medicare Handbook - Click here
Medicare and In-Person Visits for Telehealth (10/1/25)
The federal government shutdown took effect just after midnight today; Congress did not enact a budget bill that includes extension of the current waivers for in-person visits for Medicare telehealth beneficiaries. This Update includes information and resources to help psychologists navigate this transition and what this means for telehealth visits for Medicare beneficiaries.
APA (10/1/25)
According to APA:
1) "in-person visits will be required within 6 months prior to an initial telehealth visit and every 12 months thereafter"
2) "established patients who began treatment while the waiver was in effect and are currently receiving behavioral health services via telehealth do not need to have an in-person visit within 6 months of the September 30 expiration date."
The Teleheath Waiver: What Psychologists Need to Know
From APA staff Stephen Gillaspy, Deputy Chief, Health Policy and Healthcare Financing, and Marnie Shanbhag, Senior Director, Office of Independent Practice:
1) The in-person visit requirement applies to both traditional and Medicare Advantage plans.
2) No different coding is involved. If you are seeing the patient for psychotherapy you would code as you normally do for an in-person psychotherapy session.
3) For new Medicare patients, effective 10/1, psychologists will need to see the patient in person first; then you have up to 6 months to begin seeing them for telehealth services.
APA has sent an email to all the MACs (Medicare Administrative Contractors) including the guidance they've shared in the article above and requesting verification.
Palmetto GBA The MAC for North Carolina (10/1/25)
Psychologists can contact the MAC directly for guidance.
CMS/Medicare (10/1/25)
Medicare Learning Network (MLN) Connects Special Edition 10/1/25
Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown
https://palmettogba.com/jmb/did/cq6hasgliw
MLN 1986542 Medicare and Mental Health Coverage- Updated 10/1/25
Page 11: "Starting October 1, 2025, in-person visit requirements will apply for mental health services provided by telehealth. This includes a required in-person visit within the 6 months before the initial telehealth treatment, as well as the required subsequent in-person visits at least every 12 months....
The regulations at 42 CFR 410.78(b)(3)(xiv) describe 2 exceptions to the in-person requirements effective October 1, 2025:
●Patients who already get telehealth behavioral health services and have circumstances where in-person care may not be appropriate
●Groups with limited availability for in-person behavioral health visits have the flexibility to arrange for practitioners to provide in-person and telehealth visits with different practitioners, based on availability"
Exceptions to the In-Person Visit Requirement
Various sources address the possible exceptions to an in-person visit. For example:
1. The APA article cites the CY 2022 CMS PFS final rule, which states:
"Specifically, if the patient and practitioner agree that the benefits of an in-person, non-telehealth service within 12 months of the mental health telehealth service are outweighed by risks and burdens associated with an in-person service, and the basis for that decision is documented in the patient’s medical record, the in-person visit requirement will not apply for that particular 12-month period. For example, situations in which the risks and burdens associated with an in-person service may outweigh the benefit could include, but are not limited to, instances when an in-person service is likely to cause disruption in service delivery or has the potential to worsen the patient’s condition(s). The risks and burdens associated with an in-person service could also outweigh the benefit if a patient is in partial or full remission and only requires a maintenance level of care. Other examples of such instances may include the clinician’s professional judgment that the patient is clinically stable and/or that an in-person visit has the risk of worsening the patient’s condition, creating undue hardship on self or family, or if it is determined that the patient is at risk for disengagement with care that has been effective in managing the illness...Practitioners must note the exception for any applicable 12-month interval."
2. The Center for Connected Health Policy (CCHP) refers to the Code of Federal Regulations (CFR) and reports these exceptions:
- "Patients located in a rural area and in an eligible originating site as defined under permanent law do not need to meet the in-person requirement.
- Patients and providers may agree to waive the 12-month in-person visit if the risks and burdens of travel outweigh the benefits of an in-person encounter.
- Patients receiving treatment for a substance use disorder (SUD) or a co-occurring mental health condition are exempt from both the geographic and in-person requirements."
The CCHP article also addresses the question of established patients:
"One of the most frequent questions CCHP has received from providers regarding the upcoming in-person requirement is whether existing patients will need to complete an in-person visit before October 1, 2025 in order to continue to receive telehealth services. Based on the statutory language, the “first telehealth visit” after September 30, 2025, may be treated as the initial visit for compliance purposes, meaning that any in-person visit intended to meet the requirement must occur on or after March 30, 2025 to be valid. However, CMS has not explicitly addressed this issue and may provide additional clarification as the deadline approaches. It is also possible that CMS could allow continued coverage for patients already receiving telehealth services prior to the expiration of the waiver without meeting the initial 6-month in person requirement, though the annual 12-month in-person requirement would likely still apply."
Source: https://us9.campaign-archive.com/?u=c9fa99b7520aedfca5c453103&id=2a8e4dc47e
The news continues to evolve and we understand that members may have questions. NCPA will continue to monitor this transition and share information with members as soon as it becomes available.
CMS Medicare and the Government Shutdown (10/1/25)
Today, the Centers for Medicare and Medicaid Services (CMS) issued the following Medicare Learning Network (MLN) Special Edition titled "Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown". See the MLN article below.
Update on Medicare Operations: Telehealth, Claims Processing, and Medicare Administrative Contractors Status During the Shutdown
When certain legislative payment provisions (“extenders”) are scheduled to expire, CMS directs all Medicare Administrative Contractors (MACs) to implement a temporary claims hold. This standard practice is typically up to 10 business days and ensures that Medicare payments are accurate and consistent with statutory requirements. The hold prevents the need for reprocessing large volumes of claims should Congress act after the statutory expiration date and should have a minimal impact on providers due to the 14-day payment floor. Providers may continue to submit claims during this period, but payment will not be released until the hold is lifted.
Absent Congressional action, beginning October 1, 2025, many of the statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency will take effect again for services that are not behavioral and mental health services. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas and hospice recertifications that require a face-to-face encounter. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits. In the absence of Congressional action, practitioners who choose to perform telehealth services that are not payable by Medicare on or after October 1, 2025, may want to evaluate providing beneficiaries with an Advance Beneficiary Notice of Noncoverage. Practitioners should monitor Congressional action and may choose to hold claims associated with telehealth services that are not payable by Medicare in the absence of Congressional action. Additionally, Medicare would not be able to pay some kinds of practitioners for telehealth services. For further information: https://www.cms.gov/medicare/coverage/telehealth
CMS notes that the Bipartisan Budget Act of 2018 allows clinicians in applicable Medicare Shared Savings Program Accountable Care Organizations (ACOs) to provide and receive payment for covered telehealth services to certain Medicare beneficiaries without geographic restriction and in the beneficiary’s home. There is no special application or approval process for applicable ACOs or their ACO participants or ACO providers/suppliers. Clinicians in applicable ACOs can provide these covered telehealth services and bill Medicare for the telehealth services that are permissible under Medicare rules during CY 2025, irrespective of further Congressional action. For more information:
https://www.cms.gov/files/document/shared-savings-program-telehealth-fact-sheet.pdf
MACs will continue to perform all functions related to Medicare Fee-for-Service claims processing and payment.
APA CMS and Telehealth In-Person Requirement (9/24/25)
The waiver of the in-person visit requirement for Medicare coverage of telehealth services is due to expire on September 30. According to APA, Congress will need to pass either a budget bill or a separate package of health care extenders to extend this waiver past September 30. On Friday September 19, APA reported the following: "Congressional year-end funding discussions to avert a government shutdown in less than two weeks are stalling due to differences over how long a temporary funding extension (continuing resolution) should be, and whether to include healthcare premium tax credits. House and Senate Democrats introduced a month-long funding proposal Wednesday night that would keep the federal government open until Oct. 31. The Republican plan extends funding until Nov. 21." APA anticipates that the waiver will be extended again, possibly at the last minute.
On September 5, APA published an article about the waiver and September 30 deadline. The article addresses the requirements for both new and established patients, as well as the exceptions for in person visits for established patients. Learn more here:
Learn more about APA's advocacy at the APA/APASI Response Center:
https://updates.apaservices.org/
ASPPB Job Task Analysis Survey for the EPPP (9/24/25)
From the ASPPB website: "The Association of State and Provincial Psychology Boards (ASPPB) invites all licensed psychologists in the United States and Canada to participate in a crucial undertaking that will help define the future of professional psychology...ASPPB is conducting a Job Task Analysis (JTA) Survey of the Practice of Psychology—an essential step in updating the Examination for Professional Practice in Psychology(EPPP)®. This process only happens once every 7 to 10 years and directly shapes the examination specifications and content used to evaluate the knowledge and skills required for licensure."
The survey deadline is September 29, 2025.
Read more and take the survey here:
BCBS Annual NCQA Provider Assessment for Directory (9/24/25)
From the August 12 announcement: "As part of Blue Cross and Blue Shield of North Carolina (Blue Cross NC) NCQA accreditation requirements, the Provider Network Operations and Strategy department will be conducting an annual assessment of its provider directories." Learn more here:
State Health Plan, Aetna, and the Clear Pricing Project (9/17/25)
As a reminder to NCPA members, the NC State Health Plan (SHP) is ending the Clear Pricing Project (CPP) effective 12/31/25. The SHP has announced the new Behavioral Health Access Program (BHAP) beginning January 1, 2026. According to the SHP website: "The BHAP program will offer a custom fee schedule. The fee schedule will apply to Behavioral Health provider types and specialties and a defined list of CPT codes. The fee schedule will be set at 140% of current year NC Medicare (updated annually effective May 1st) for a limited set of CPT codes (psychotherapy, evaluation and management and psychological testing)." Read more on the NC SHP website: https://www.shpnc.gov/nc-state-health-plan-network
NCPA leaders have been communicating with Aetna representatives regarding this upcoming change (please see the May 21 and July 17 APC Updates for more information). According to Aetna:
1. Aetna sent termination letters to providers in July via certified mail. The letter tells providers that "we’re terminating your North Carolina State Health Plan Network Provider Participation Amendment To Network Provider Agreement with us effective 12/31/2025".
Click here to see Aetna’s sample term letter.
Click here to see the SHP insert.
2. Aetna provided the following information about the new Behavioral Health Access Program (BHAP):
- The SHP is offering a new custom fee schedule to BH providers
- Most fees are based on 140% of current year Medicare
- There will not be a differential copay for BHAP providers (and no badge in the provider search)
- Providers can sign an online amendment similar to how they signed up for CPP: Go.Aetna.com/joinbhap
- The BHAP amendment and FAQ document are posted on the Aetna website above under "helpful resources"
- There is currently no plan to “close” BHAP signup, but the effective date will be January 1, 2026 or the 30th day after the BHAP amendment is mutually signed, whichever is later
- The BHAP signup tool went live on July 3
Additional Resources:
Aetna SHP site for providers: https://www.aetna.com/health-care-professionals/north-carolina-state-health-plan.html
NC SHP provider site (includes 2026 benefit plan comparison): https://www.shpnc.gov/nc-state-health-plan-network
Telehealth Awareness Week September 14-20 (9/17/25)
Telehealth Awareness Week highlights the critical role of virtual care in healthcare. Related resources:
American Telemedicine Association
https://telehealthawareness.org/
Center for Connected Health Policy
Office for the Advancement of Telehealth (OAT)
South Central Telehealth Resource Center
https://learntelehealth.org/2025/09/telehealth-awareness-week-2025/
APA Congressional Advocacy/ Medicare and Telehealth (9/10)
AI in Health Care
"On Sept. 3, APA’s Vaile Wright, PhD, testified at a House Committee on Energy and Commerce Health Subcommittee hearing on “Examining Opportunities to Advance American Health Care Through the Use of Artificial Intelligence Technologies.” Wright underscored the critical need for psychological science in shaping oversight of AI in health care at every step and ensuring “a human remains in the loop.” She called for clear regulatory guardrails, age-appropriate safeguards to protect youth and other vulnerable populations, a strong federal privacy law to protect patient data, and other critical protections. “The core mission of health care—to help and do no harm—must be our guiding principle,” said Wright. “AI should be seen as tool to augment, not replace, the clinical judgment and therapeutic relationship that are the bedrock of quality health care.”
Click here to read the testimony here.
Department of Veterans Affairs
"This week APASI submitted comments in response to the Department of Veterans Affairs (VA) proposed rule to exclude abortion and abortion counseling from both the VA medical benefits package and from the Civilian Health and Medical Program (CHAMPVA). APASI has tremendous concern about this proposed rule given research that suggests that barriers to accessing reproductive services may increase symptoms of stress, anxiety and depression and disproportionately impacts underserved populations. Furthermore, APASI is concerned that the limitations on "abortion counseling" were not defined and could entail an even broader prohibition applying to general discussions of reproductive health as part of comprehensive mental health treatment. Lastly, APASI stressed that the impact of this proposal on veterans with a history of military sexual trauma (MST) must be considered and addressed." Click here to read APA's comments.
Medicare and the Telehealth Waiver
"Access to health care services via telehealth has broad bipartisan support in Congress, but little time remains before the current Medicare flexibilities expire on Sept. 30. APA Services advocacy staff are hearing that Congress may include another short-term delay of the in-person visit requirement. Our advocacy team is also continuing to support legislative efforts to eliminate the requirement." Read the full update here, including information about the waiver for the in-person visit requirement set to expire on September 30:
https://www.apaservices.org/practice/reimbursement/government/medicare-inperson-telehealth-requireme
Carolina Complete Health Standard Plan Medicaid (9/3/25)
In August, Carolina Complete Health released a special bulletin titled "Modifier Requirement for Doctoral-Level Licensed Psychologists". The bulletin notes that the plan "now requires all doctoral-level Licensed Psychologists to include a credential-specific modifier on claims", with an effective date of 1/1/24:
https://mailchi.mp/cch-network/modifiers-doctoral-psychologists?e=[UNIQID]
The bulletin also notes that "Providers can submit corrected claims with the applicable modifiers for reprocessing if it is determined the incorrect rate was reimbursed" and provides information regarding filing corrected claims.
The NC Department of Health and Human Services (DHHS) website provides information regarding claims and reimbursement. In November 2024, NC DHHS published a bulletin titled "Health Plan Interest for Provider Claims" which applies to LME/MCO services in NC Medicaid Direct and NC Medicaid Managed Care health plans.
https://medicaid.ncdhhs.gov/blog/2024/11/19/health-plan-interest-provider-claims
Action Alert on CMS’ CY 2026 Physician Fee Schedule (PFS) Proposed Rule (8/27/25)
APA Services has released an Action Alert on CMS’ CY 2026 Physician Fee Schedule (PFS) Proposed Rule, and we are asking for your help in sharing it broadly with your networks. Your engagement is critical to ensuring psychologists’ voices are heard in this important process.
Why This Matters
The PFS sets federal reimbursement policy and influences coverage decisions across the entire health care system. This year’s proposed rule includes several significant wins for psychology—made possible through years of advocacy and strong participation in prior federal regulatory comment campaigns. However, it also contains provisions where CMS needs the expertise and input of psychologists to make improvements.
Key Positive Provisions
- Preserves access to psychological services furnished via telehealth
- Permanently adopts a definition of direct supervision allowing “immediate availability” via two-way audio/video
- Creates a new pathway for neuropsychologists to participate in MIPS
Provisions Needing Improvement
- Removal of a reimbursement code for clinician assessment of Social Determinants of Health
- Inconsistent reimbursement for Digital Mental Health Treatment and Remote Therapeutic Monitoring tools
- Problematic changes to reimbursement codes for outpatient behavioral health services, including those vital to neuropsychological assessment and chronic illness management
Call to Action
Please disseminate APA’s action alert and encourage your members, colleagues, and networks to send comments to CMS. Broad engagement will help solidify these positive policies and shape improvements in the final rule. The comment period closes at 11:59pm EDT on September 12, 2025
NCPA Practice Toolkit Updated (8/27/25)
The Practice Toolkit is a benefit for NCPA members at the Investor level or above. The Toolkit includes 24 pages of resources covering a wide range of practice areas and topics. The entire Toolkit has recently been refreshed and updated, and each page has new resources added. For example:
The "Billing and Coding" page has new resources from APA and CMS, including information about the Physician Fee Schedule (PFS) and Place of Service (POS) codes.
Two pages- "Duty to Protect/Warn and Duty to Report" and "North Carolina General Statutes"- have new links to laws related to the practice of psychology.
The "Patient Resources" page has an extensive list of resources- such as books, TED Talks and videos, websites, and podcasts- addressing a wide range of mental health topics.
The "Record Keeping, Retention, and Destruction" page has additional resources, including a new section called "Cures Act, Open Notes, and Information Blocking".
The Practice Toolkit can be found under the "Members" tab on the NCPA website: https://www.ncpsychology.org/
ASPPB EPPP Survey (8/20/25)
From the ASPPB website: "The Association of State and Provincial Psychology Boards (ASPPB) invites all licensed psychologists in the United States and Canada to participate in a crucial undertaking that will help define the future of professional psychology.
ASPPB is conducting a Job Task Analysis (JTA) Survey of the Practice of Psychology—an essential step in updating the Examination for Professional Practice in Psychology (EPPP)®. This process only happens once every 7 to 10 years and directly shapes the examination specifications and content used to evaluate the knowledge and skills required for licensure." The survey deadline is September 29, 2025. Read more and take the survey here:
Palmeto GBA Behavioral Health Integration Services Webinar (8/20/25)
Palmetto GBA is the North Carolina MAC (Medicare Administrative Contractor). On september 2 at 11 AM, their Provider Outreach and Education team is offering a webinar "to review coverage and billing for Behavioral Health Integration Services... This session reminds providers that there is now coverage for these important services, defines them, and identifies updates from the CY 2025 Medicare Physician Fee Schedule Final Rule as related to billing." Learn more and register here:
https://palmettogba.com/jjb/did/evyq3lqlc8pi6q0902
Social Security Compassionate Allowances List (8/20/25)
From the August 11 press release: "The Social Security Administration (SSA) today announced the addition of 13 new conditions to the agency’s Compassionate Allowances (CAL) list. The CAL initiative accelerates the disability application process for individuals with the most serious diseases and medical conditions that, by definition, meet Social Security's statutory standard for disability benefits." Read the press release here:
To learn more about Compassionate Allowances and see the complete list of conditions:
https://www.ssa.gov/compassionateallowances/
CMS Psychotherapy for Crisis Services (8/13/25)
Palmetto GBA is the Medicare Administrative Contractor (MAC) for North Carolina. The following information comes from Palmetto GBA's August webinar about Psychotherapy for Crisis services.
Medicare pays for psychotherapy for crisis services under the Part B Physician Fee Schedule. The following services are included:
–Providing an urgent assessment and history of a crisis state
–Performing a mental status exam and psychotherapy
–Mobilizing resources to defuse the crisis and restore safety
–Using interventions to minimize the potential for psychological trauma
Psychotherapy for crisis services:
-Are appropriate for patients in high distress with life-threatening, complex problems that require immediate attention
-Can help reduce a patient’s mental health crisis (including SUD) through:
Urgent assessment and history of a crisis state
Mental status exam
Disposition (what happens next for the patient)
Psychotherapy for Crisis Services can be furnished in facility or nonfacility locations; they can also be furnished via telehealth if all requirements are met (see MLN Booklet 901705 below for more information)
CPT Codes
90839 Psychotherapy for crisis; first 60 minutes
90840 Each additional 30 minutes; use in conjunction with 90839
Don’t bill psychotherapy for crisis with the following codes:
–90791 (Psychiatric diagnostic evaluation)
–90792 (Psychiatric diagnostic evaluation with medical services)
–90785–90899 (Psychiatric services and procedures)
–90832–90838 (Psychotherapy services and procedures)
Additional Resources
CMS Psychotherapy for Crisis page https://www.cms.gov/medicare/payment/fee-schedules/physician-fee-schedule/psychotherapy-crisis
CMS Medicare Learning Network (MLN) Booklet 1986542 Medicare and Mental Health Coverage
CMS Medicare Learning Network (MLN) Booklet 901705 Telehealth and Remote Patient Monitoring
APA CMS 2026 Physician Fee Schedule (PFS) Proposed Rule (8/6/25)
From APA: "As part of the rulemaking process, APA Services is continuing its analysis of the Centers for Medicare and Medicaid Services’ (CMS) Calendar Year 2026 Physician Fee Schedule (PFS) proposed rule. In addition to running our annual grassroots campaign in the very near future, we will submit a comment letter to CMS by September 12. Topics will include: reimbursement changes, efficiency adjustment, indirect practice expense adjustment, and the conversion factor."
Click here to read more in this July 24 Practice Update article
CMS White House Plan to Create "Digital Health Ecosystem"
On July 30, the Centers for Medicare and Medicaid Services (CMS) issued a press release titled "White House, Tech Leaders Commit to Create Patient-Centric Healthcare Ecosystem". The announcement states that during a recent White House event with CMS, "the Administration secured commitments from major healthcare and information technology firms – including Amazon, Anthropic, Apple, Google, and OpenAI – to begin laying the foundation for a next-generation digital health ecosystem that will improve patient outcomes, reduce provider burden, and drive value... The Administration’s efforts focus on two broad areas: promoting a CMS Interoperability Framework to easily and seamlessly share information between patients and providers, and increasing the availability of personalized tools so that patients have the information and resources they need to make better health decisions." The announcement includes information such as 1) a link to a "full list of companies who have currently pledged their support for CMS’ Health Tech Ecosystem initiative" and 2) a link to an introductory video with Amy Gleason, Strategic Advisor to HHS/CMS and Acting Administrator of the US DOGE Service.
Click here to learn more.
SAMHSA 988 Option 3 for LGBTQ+ Youth Eliminated
The 988 National Suicide and Crisis Lifeline was established in July 2022. According to the Substance Abuse and Mental Health Services Administration (SAMHSA), effective July 17, the Press 3 option for LGBTQ+ youth is no longer available.
Click here to read the SAMHSA statement.
NC Health News posted an article about this change, which includes state-specific information. Click here to read
APA Services Update on H.R. 1 (7/23/25)
On July 9, APA Services (APASI) published an article about H.R. 1 titled: "Massive tax bill impacting behavioral health now law- The bill recently signed into law includes billions of dollars in cuts to Medicaid, higher education, and other critical federal programs to offset tax reforms". Read the full article here: https://www.apaservices.org/advocacy/news/tax-bill-impacting-behavioral-health
On July 16, APASI also published an "Update on Cuts to Medicaid Funding and Restrictions to Medicaid Access":
https://updates.apaservices.org/update-on-proposed-cuts-to-medicaid-funding
APA 2026 CMS Physician Fee Schedule (7/23/25)
From APA: "The 2026 Centers for Medicare and Medicaid Services (CMS) Physician Fee Schedule proposed rule was released on July 15 and APA staff are working on our analysis. The proposed rule contains the new policy proposals for CMS, suggested changes to Medicare services, and provider payments for the coming year. APA Services encourages all psychologists to comment."
Guidance from APA about sharing feedback: https://www.apaservices.org/practice/reimbursement/government/cms-physician-fee-schedule
Link to APA/APASI Action Center:
https://www.votervoice.net/APAAdvocacy/News#/Blog/7769
Palmetto GBA Webinars (7/23/25)
Palmetto GBA, the MAC (Medicare Administrative Contractor) for North Carolina, is offering these upcoming webinars:
1. July 25 10 AM ET: Part B Quarterly Medicare Updates Webinar
Learn more and register here: https://palmettogba.com/jjb/did/evwasmflpvujtr0725
2. July 30 9 AM ET: Medicare's 60th anniversary and updates
"Join us in celebrating Medicare's 60th birthday on Wednesday, July 30, 2025! This milestone is a great opportunity to learn about Medicare, its history, and the various contractors involved. We'll also share important updates for Medicare Parts A and B, as well as home health and hospice." Learn more and register here: https://palmettogba.com/jja/did/eve89wux3134840730
3. August 6 12:30 PM ET: Psychotherapy for Crisis Services
"Join the Palmetto GBA Part B Provider Outreach and Education team...to review coverage and billing for psychotherapy for crisis services." Learn more and register here: https://palmettogba.com/jjb/did/ev95a3ohqwnlyl0806
Update: State Health Plan, Aetna, and the Clear Pricing Project (7/17/25)
As NCPA has previously reported, the NC State Health Plan (SHP) is ending the Clear Pricing Project (CPP) effective 12/31/25. The SHP has announced the new Behavioral Health Access Program (BHAP) beginning January 1, 2026. According to the SHP website: "The BHAP program will offer a custom fee schedule. The fee schedule will apply to Behavioral Health provider types and specialties and a defined list of CPT codes. The fee schedule will be set at 140% of current year NC Medicare (updated annually effective May 1st) for a limited set of CPT codes (psychotherapy, evaluation and management and psychological testing)." Read more here:
https://www.shpnc.gov/nc-state-health-plan-network
NCPA staff and leadership have been communicating with Aetna representatives regarding this upcoming change (please see the May 21 APC Update for more information). Aetna recently provided the following information to NCPA:
1. Aetna sent termination letters to providers last week via certified mail. The letter tells providers that "we’re terminating your North Carolina State Health Plan Network Provider Participation Amendment To Network Provider Agreement with us effective 12/31/2025".
Click here to see the sample term letter
2. Aetna provided the following information about the new Behavioral Health Access Program (BHAP):
- The SHP is offering a new custom fee schedule to BH providers
- Most fees are based on 140% of current year Medicare
- There will not be a differential copay for BHAP providers (and no badge in the provider search)
- Providers can sign an online amendment similar to how they signed up for CPP: Go.Aetna.com/joinbhap
- The BHAP amendment and FAQ document are posted on the Aetna website above under "helpful resources"
- There is currently no plan to “close” BHAP signup, but the effective date will be January 1, 2026 or the 30th day after the BHAP amendment is mutually signed, whichever is later
- Aetna has already had 446 TINs sign up for BHAP since the signup tool went live on July 3
Additional Resources:
- Aetna SHP site for providers: Go.Aetna.com/ncshp
- NC SHP provider site (includes 2026 benefit plan comparison): shpnc.gov/nc-state-health-plan-network
BCBSNC Medicare Advantage Audits (7/16/25)
BCBSNC issued an update regarding Medicare Advantage audits (please see the initial announcement in the June 25 APC Update). According to the update, "The correct payment years CMS will audit all eligible MA contracts beginning in June is from 2019 through 2024. The correct provider dates of service Blue Cross NC will request charts for these audits are from years 2018 through 2023." Read more here:
BCBSNC Antitrust Settlement- Deadline July 29, 2025 (7/16/25)
As NCPA has previously reported, psychologists who treated patients insured by any Blue Cross Blue Shield company between July 24, 2008, and October 4, 2024, may be eligible for compensation from a significant antitrust litigation settlement. (Please see the February 26 and July 2 APC Updates.) The deadline for submitting claims is July 29, 2025 (online or postmarked by this date.)
APA has posted articles about this lawsuit, which include background information, information about submitting claims, and a link to contact APA with questions:
"Important information for psychologists regarding the Blue Cross Blue Shield settlement" (Feb. 24, 2025)
"Update on the Blue Cross Blue Shield antitrust settlement" (Feb. 28, 2025)
BCBS Provider Settlement website:
https://www.bcbsprovidersettlement.com/
FAQ page:
https://www.bcbsprovidersettlement.com/Home/FAQs
NC HIEA Newsletter (7/16/25)
Read the most recent newsletter here:
https://hiea.nc.gov/blog-entry-list
APA Services Letter on Medicaid and Budget Reconciliation (7/9/25)
APA Services is a member of the Mental Health Liaison Group (MHLG), a coalition of national organizations representing people with mental health conditions and substance use disorders, family members, mental health and addiction providers, advocates and other stakeholders. One June 30, the MHLG sent a letter to Rep. Mike Johnson, House Speaker, and Rep. Hakeem Jeffries, House Minority Leader, expressing concern about the changes to Medicaid within the budget reconciliation bill and the impact these changes would have on both beneficiaries and service providers. Read the letter here.
APA Services Response to CMS RFI (7/9/25)
The Centers for Medicare and Medicaid Services (CMS) previously issued a Request for Information (RFI) titled "Unleashing Prosperity Through Deregulation of the Medicare Program" (please see the June 4 APC Update for more information). Individual psychologists were encouraged to provide feedback prior to the June 10 deadline. APA Services also provided feedback; their letter addressed the RFI's main topic areas, making multiple suggestions within each area:
1) Streamline Regulatory Requirements
2) Opportunities to Reduce Burden of Reporting and Documentation
3) Identification of Duplicative Requirements
4) Additional Recommendations
CMS Fraudulent Medicare Accounts (7/9/25)
On June 30, the Centers for Medicare and Medicaid Services (CMS) issued a press release saying that in response to call center complaints, CMS "launched an investigation and discovered that malicious actors had fraudulently created new accounts between 2023 and 2025 using valid beneficiary information, including Medicare Beneficiary Identifiers (MBI), coverage start date, last name, date of birth, and zip code." CMS estimates that "approximately 103,000 beneficiaries may have been impacted". Read more here, including steps CMS has taken to respond:
BCBS Antitrust Settlement Update (7/2/25)
As NCPA has previously reported, psychologists who treated patients insured by any Blue Cross Blue Shield company between July 24, 2008, and October 4, 2024, may be eligible for compensation from a significant antitrust litigation settlement. (Please see the February 26 APC Update.) The deadline for submitting claims is July 29, 2025 (online or postmarked by this date.)
APA has posted articles about this lawsuit, which include background information, information about submitting claims, and a link to contact APA with questions:
"Important information for psychologists regarding the Blue Cross Blue Shield settlement" (Feb. 24, 2025)
"Update on the Blue Cross Blue Shield antitrust settlement" (Feb. 28, 2025)
BCBS Provider Settlement website:
https://www.bcbsprovidersettlement.com/
FAQ page:
https://www.bcbsprovidersettlement.com/Home/FAQs
Medicare Advantage Plan Audits (6/25/25)
CMS
On May 21, the Centers for Medicare & Medicaid Services (CMS) issued a press release to announce a "significant expansion of its auditing efforts" for Medicare Advantage (MA) plans. The press release states that CMS "will begin auditing all eligible Medicare Advantage contracts each payment year" and will "add resources to expedite completion of 2018 to 2024 audits". The press release also states that CMS plans to:
-"increase its team of medical coders from 40 to approximately 2,000 by September 1, 2025"
-"increase its audits from ~60 MA plans a year to all eligible MA plans each year in all newly initiated audits (approximately 550 MA plans)"
Read the full announcement here:
Blue Cross NC
On June 13, BCBSNC issued this announcement about these audits:
APA Response to CMS Request for Information (6/25/25)
In the May 28 APC Update, we notified members that the Centers for Medicare and Medicaid Services (CMS) had released a Request for Information (RFI) called "Unleashing Prosperity Through Deregulation of the Medicare Program". The RFI addressed administrative barriers related to Medicare and Medicare Advantage; the response deadline was June 10, 2025. Individual psychologists were invited to respond; the APA also sent a response based on psychologists' feedback.
Click here to read APA's Response.
APA Advocacy (6/18/25)
Telemental Health Care Access Act
APA has been working to secure reintroduction of the Telemental Health Care Access Act. On Tuesday, June 10, the bill was reintroduced in the US House by Representatives Doris Matsui (D-CA) and Troy Balderson (R-OH). The bill is also supported by Senators Tina Smith (D-MN) and Bill Cassidy (R-LA). Rep. Matsui issued a press release which featured a quote from APA Services CEO Arthur C. Evans, Jr., PhD:
According to APA: “This bill would accomplish two objectives: (1) it would repeal the Medicare in-person visit requirement set to take effect at the end of FY2025; and (2) it would extend certain statutory telehealth flexibilities for "mental health" services to "behavioral health" services as well.”
APA has received information that in addition to repealing the in-person visit requirement, the Senate version of the bill will address the "mental health"/"behavioral health" statutory flexibilities, which it has not included in the past. According to APA, a temporary extension of the current telehealth rules is more likely by the end of September 2025, but this bill opens up the possibility of Congress working on a longer-term solution next year.
Centers for Medicare and Medicaid Services (CMS)
APA/APA Services recently submitted comments on the CMS proposed rule for the FY 2026 Inpatient Psychiatric Facility Prospective Payment System:
Read more about the proposed rule here: https://www.cms.gov/medicare/payment/prospective-payment-systems/inpatient-psychiatric-facility
Click here to read APA's comments
NC Suicide Prevention Action Plan Posted for Public Comment (6/18/25)
As part of the North Carolina Department of Health and Human Services commitment to transforming mental health care, the department is seeking public comment on its Suicide Prevention Action Plan (2026-2030). This work is critical in improving the lives of all North Carolinians and addressing the mental health crisis. The public is invited to read the plan and provide feedback by July 9, 2025.
The Suicide Prevention Action Plan is a collaboration between NCDHHS, the North Carolina Department of Public Safety’s Office of Violence Prevention (OVP) and the North Carolina Department of Public Instruction (DPI).
Strategies highlighted in the plan include having a statewide coordinated infrastructure, implementing and promoting safe storage practices, providing expanded mental health training in non-traditional settings and ensuring at-risk populations are reached effectively.
“We have to ensure people receive care when they need it, before they reach a crisis, especially among groups that are more vulnerable, like our teenagers, young adults and veterans,” said NC Health and Human Services Secretary Dev Sangvai. “This collaborative effort is a step forward in creating a system that works for everyone that will have impact for generations to come.”
Suicide is one of the top 10 leading causes of death in North Carolina for people ages 10-65, according to data from the N.C. State Center for Health Statistics. Suicide is the third leading cause of death for youth ages 10-18 in North Carolina, and the second leading cause of death for those ages 19-34.
Additionally, military veteran residents are disproportionally impacted by suicide with the average suicide rate from 2018-2022 being 2.7 times higher among North Carolina veterans than non-veterans.
“Public input is essential to strengthening and shaping the continuum of mental health care in North Carolina,” said Kelly Crosbie, MSW, LCSW, Director of the NCDHHS Division of Mental Health, Developmental Disabilities, and Substance Use Services. “We want to meet people where they are, in schools and in their communities, to ensure the right care at the right time.”
NCDHHS is also partnering with the UNC Suicide Prevention Institute, NC DPI and Village of Care on the development of a strategic plan dedicated to preventing suicide among Black youth. This is the first strategic plan of its kind in the history of NCDHHS and was driven by data that show Black people, including the 10-24 age group, are overrepresented in suicide-related emergency department visits.
If you or someone you know is struggling with their mental health or need someone to talk to, you are not alone. Resources are available on the NCDHHS Suicide Prevention website for social or family situations, depression, anxiety, panic attacks, thoughts of suicide, alcohol or drug use, or if you just need someone to talk to. Our Crisis Services Communications Toolkit includes free flyers, posters and other resources to promote and explain crisis services in your community in English and Spanish.
· For those in a mental health crisis, NCDHHS provides somewhere to go, someone to talk to and someone to respond. The 988 Lifeline Chat and Text - 988 Suicide & Crisis Lifeline is free, confidential, and available to everyone 24/7 by call, text, or chat. Targeted resources are available for Veterans, Spanish speakers, and LGBTQ+ youth and young adults.
· North Carolinians can call the Peer Warmline (1-855-PEERS NC [855-733-7762] 24/7) to speak with a Peer Support Specialist. Peer Support Specialists (or “peers”) are people living in recovery with mental illness and/or substance use disorder who provide support to others who may have similar life experiences and can benefit from their lived experiences.
· NCDHHS crisis services include mobile crisis teams that can come to you and community crisis centers, which are safe places where you can get help from a licensed clinician, without needing to go to the emergency room.
APA Departments announce nonenforcement of the 2024 Mental Health Parity Rule (6/11/25)
From APA Services May 21: "In an announcement on May 15, 2025, the agencies that enforce the federal mental health parity law—the U.S. Departments of Labor, Health and Human Services, and the Treasury (the Departments)—declared that they will not enforce the final rule “Requirements Related to the Mental Health Parity and Addiction Equity Act (MHPAEA)” (2024 Final Rule) and will likely make other changes to parity enforcement...
It is crucial to remember that MHPAEA’s statutory obligations, as amended by the CAA, 2021, remain in effect. The core principle of parity—requiring that mental health and substance use disorder benefits be no more restrictive than medical/surgical benefits—is still the law. Important, the administration’s current action is a decision of nonenforcement, not a rescission of the 2024 Final Rule itself."
Read the full article, which addresses these latest developments and reviews what parity laws remain in effect, here:
https://www.apaservices.org/practice/news/nonenforcement-2024-mental-health-parity-rule
Palmetto GBA New Medicare Providers Webinar(6/4/25)
Palmetto GBA is the MAC (Medicare Administrative Contractor) for North Carolina. On June 19, Palmetto GBA is hosting a webinar "Steps to Success for New Medicare Providers". Learn more and register here: https://palmettogba.com/jmb/did/evxjpgmuwzw9wu0619
CMS Request for Information- Medicare and MR Advantage (5/28/25)
The Centers for Medicare and Medicaid Services (CMS) has issued a Request for Information (RFI) titled "Unleashing Prosperity Through Deregulation of the Medicare Program". The deadline is June 10, 2025. APA will be submitting an official response to the request, but this is a great opportunity for individual psychologists to provide examples and make recommendations to CMS to address some of the administrative barriers related to Medicare and Medicare Advantage. Specifics related to real life experiences carry a lot of weight in these public comment situations. Many psychologists are also small business owners, which also carries weight.
Tips from APA: There are 9 specific questions (3 questions within each of 3 categories) and then an opportunity to provide any additional thoughts or comments. If you are really tight on time, after entering your demographics on the submission form, you can go to question 4A and list your concerns. You don’t need to spend a lot of time entering your concerns into the previous question boxes by category of administrative requirement.
Link to the online submission form: https://www.cms.gov/medicare-regulatory-relief-rfi
Don't miss this opportunity to provide feedback to CMS!
NCPA Member Advocacy: Meeting with Aetna Representatives (5/21/25)
On Monday April 21, NCPA leaders, along with representatives of other North Carolina behavioral health associations, met with Aetna representatives for the third in a series of biannual meetings. NCPA leaders had the opportunity to put forth member-identified concerns and questions as part of the agenda for discussion. The following is a summary of key highlights from that meeting:
Credentialing, Claims and Reimbursement
Issues related to credentialing and prompt and accurate claims reimbursement were addressed. Aetna advised that:
1. Clinicians provide and maintain accurate demographic and licensure data with CAQH, Aetna, and Availity. Reimbursement is based on licensure, so accuracy is important.
2. Availity is not directly connected to Aetna.
3. If credentialing or reimbursement problems persist after contacting provider services, clinicians may use this email for additional assistance: northcarolinanetwork@aetna.com
Clear Pricing Project (CPP)
Members may be aware of news reports related to the State Health Plan (SHP) budget. According to the SHP website, the SHP is facing a $507 million deficit for 2026, and in response, is “evaluating all programs, like CPP, to determine the best way to stabilize the Plan’s financials… As such, the Plan will be ending CPP in its current form as of December 31, 2025.” Members may read more on the SHP website:
https://www.shpnc.org/nc-state-health-plan-network
Aetna representatives reported that they are working closely with the SHP to determine what these future CPP changes will look like. Preliminary reports suggest that there will be a revised version of the CPP (a name change is possible) effective January 1, 2026. Providers wishing to participate in the revised program will need to sign up again through Aetna- even those already currently enrolled. Aetna reported that there will be a simple sign-up, similar to the online sign-up previously offered. Termination letters for the current CPP will be sent to providers in May.
Vita Health
From the Aetna March 2025 OfficeLinks Update:
“Vita Health provides subspecialty enhancement to current outpatient treatment. This enhancement isn’t meant to replace a general behavior therapist or crisis line. Vita Health provides virtual, easy to access therapy for teens and adults that’s proven to reduce suicide attempts and death.”
In our discussion of this program, Aetna reported that:
1. Vita Health holds contracts with entities such as payors, colleges, and employer groups and offers services to those 12 and older.
2. Aetna’s partnership with Vita Health provides an additional benefit for Aetna members with no copay for members.
3. Providers can refer patients to Vita Health; services typically last about 12 weeks.
Read more in the Office Links Update, pages 39-40.
BCBSNC (5/14/25)
1. Behavioral Health On Demand program
On April 17, BCBS announced a new phone number for the telemedicine Behavioral Health On Demand (BHOD) program, which is "an additional resource for members going to the Emergency Department when they have an urgent behavioral health need". Read more here:
2. Medicare Advantage Behavioral Health concurrent review for additional inpatient days
The effective date is now June 1, 2025- read more here:
Corporate Transparency Act- Beneficial Ownership Information (BOI) Reporting
From the Financial Crimes Enforcement Network (FinCEN) website: "All entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners are now exempt from the requirement to report beneficial ownership information (BOI) to FinCEN. Existing foreign companies that must report their beneficial ownership information have at least an additional 30 days from March 26, 2025—until April 25, 2025, for most companies—to do so." Read the Alert here: https://www.fincen.gov/boi
The FinCEN March 21 press release states that they are releasing an interim final rule that "removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act...Thus, through this interim final rule, all entities created in the United States — including those previously known as “domestic reporting companies” — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN... FinCEN is accepting comments on this interim final rule and intends to finalize the rule this year." Read the full press release here:
FinCEN Interim Final Rule Q&A:
https://www.fincen.gov/boi/ifr-qa
US Dept of the Treasury press release:
https://home.treasury.gov/news/press-releases/sb0038
APA US DHHS Report (5/7/25)
From the APA: "The Department of Health and Human Services (HHS) released a 409-page review of medical interventions for gender dysphoria in children and adolescents which aims to evaluate existing medical treatments for minors with gender dysphoria. The report lacks transparency and scientific integrity. HHS did not disclose who authored or reviewed the report."
Learn more here:
APA/APASI Response Center https://updates.apaservices.org/
APA Update on Policies Affecting Gender-Diverse Populations
https://updates.apaservices.org/update-on-biological-sex-and-gender-diversity-related-eos
NC Health Information Exchange Authority (HIEA)
Read the April newsletter here: https://hiea.nc.gov/blog-entry-list
NC Psychology Board
Read the Board's Spring newsletter here: (link to pdf attached)
7 Cups Online Directory (4/20/25)
NCPA is aware that psychologists are reporting being listed in the 7 Cups online therapy directory without their knowledge or consent. The 7 Cups website offers options to connect with a licensed therapist, "trained volunteer listeners", and/or "Noni, your AI counselor".
Marnie Shanbhag, PhD, Senior Director for the APA's Office of Independent Practice, is quoted in a Mashable article about 7 Cups and the issue of clinicians being included in directories without their consent or participation:
https://mashable.com/article/7-cups-therapist-directory-ghost-networks
Steps for members:
1. To see if you're included in the 7 Cups directory, do an internet search for your name and "7 Cups". (It can be difficult to find your profile if you search the website itself.)
2. If you're included in the 7 Cups directory but don't wish to be:
- go to the 7 Cups Support and Feedback page: https://help.7cups.com/hc/en-us
- click on Submit a Request at the top right
- choose "Data Removal Request" from the dropdown menu, fill in the boxes, and hit submit
Both NCPA and APA are tracking this issue. Please feel free to share any feedback with our DPA, Cristin Saffo, PsyD at: dpa@ncpsychology.org
CMS Proposed Rule- Psychiatric Inpatient Facilities
"On April 11, 2025, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that proposes updates to Medicare payment policies and rates for Inpatient Psychiatric Facility... for fiscal year (FY) 2026. CMS is publishing this proposed rule consistent with its statutory authority to update Medicare payment policies for IPFs annually." CMS is proposing a 2.4 % increase for fiscal year 2026.
Read the Fact Sheet here:
Federal Register page to view and comment on proposed rule:
https://www.federalregister.gov/public-inspection/current
Palmetto GBA MayFest May 12-13
"Palmetto GBA is pleased to present our annual MayFest 2025 virtual conference Monday and Tuesday May 12-13, 2025. MayFest is designed to keep you informed and up-to-date on Medicare guidelines and coverage requirements. MayFest features in-depth sessions on a wide range of clinical and billing topics. It’s a great opportunity to strengthen your Medicare knowledge and stay aligned with current updates from CMS and Palmetto GBA. Attendees will receive helpful resources and reference materials, as well as access to live Q&A sessions." Registration is free. Learn more and register here:
https://web.cvent.com/event/ae4ac603-9cb0-43f5-93f3-9a1b36b344dc/summary
BCBSNC (4/16/25)
"Effective May 1, 2025, requests for Medicare Advantage Behavioral Health concurrent review for additional inpatient days will be reviewed utilizing the Centers for Medicare & Medicaid Services (CMS) Medicare Coverage Database." Read more here:
CMS Dr. Mehmet Oz Shares Vision for CMS
From CMS: "As Dr. Mehmet Oz completes his first week as the 17th Administrator of CMS, he is sharing his agenda and vision for the agency. A cardiothoracic surgeon and former host of an award-winning TV show, he now leads the largest agency under HHS, with a $1.7 trillion budget, tasked with delivering health outcomes for more than 160 million people." Read the press release here:
https://www.cms.gov/newsroom/press-releases/dr-mehmet-oz-shares-vision-cms
APA AI Information and Resources (4/9/25)
Artificial Intelligence in Mental Health Care:
https://www.apa.org/practice/artificial-intelligence-mental-health-care
AI Tool Guide for Practitioners: "This step-by-step guide discusses how to decide which AI tools are right for your practice":
Using Generic AI Chatbots for mental health support: A dangerous trend
"APA urges the Federal Trade Commission to put firm safeguards in place to prevent the public from harm"- read more here:
https://www.apaservices.org/practice/business/technology/artificial-intelligence-chatbots-therapists
NC Health Information Exchange Authority (HIEA)
Read the March newsletter here: https://hiea.nc.gov/blog-entry-list
APA (4/2/25)
In February 2025, the APA Council of Representatives approved the following:
Resolution on Protecting Psychological Test Security, Test Validity, and Public Safety
https://www.apa.org/about/policy/test-security-validity-public-safety
Resolution on the Protection of Neural and Cognitive Data
https://www.apa.org/news/press/releases/2025/03/privacy-protections-psychological-data
Resolution on Advancing Evidence-based Health Promotion and Prevention across the Lifespan
https://www.apa.org/about/policy/guidelines-health-care-delivery-systems
Professional Practice Guidelines (PPGs) for Measurement-Based Care (MBC)
https://www.apa.org/about/policy/guidelines-measurement-based-care
Ageism Policy Statement
https://www.apa.org/about/policy/ageism-policy-statement
Caregiving Policy Statement
https://www.apa.org/about/policy/caregiving-policy-statement
CMS New Medicare Numbers
According to news reports, as a result of a 2023 data breach at Wisconsin Physicians Service Insurance Corporation (WPS), nearly one million Medicare beneficiaries are being issued new Medicare Beneficiary Identifiers (MBIs) and Medicare cards. CMS began issuing these cards in October 2024. Read more here:
From the Medicare Resource Center:
From CMS.gov:
https://www.cms.gov/outreach-and-education/look-up-topics/medicare/new-medicare-card-message
APA SAMHSA Statement (3/26/25)
From APA: "The CEO Alliance for Mental Health (APA CEO Arthur C. Evans Jr., PhD, is a member) has issued a statement of concern about proposed cuts to SAMHSA that would interrupt services for people with mental health conditions and substance use disorders. The alliance underscores the importance of protecting SAMHSA’s funding and U.S. communities. APA/APA Services has also posted a statement on the proposed cuts: “Now is not the time to slash an agency that has made great strides in addressing the mental health, substance use, and suicide crises in America,” the statement underscores." The statement was sent to Congressional policy makers and key individual in the administration.
Read the APA statement here: https://updates.apaservices.org/apa-statement-on-proposed-cuts-to-samhsa
Read the CEO Alliance statement here:
BCBS
BCBS has announced (January 22, March 14) that it will be collecting members’ medical records for the annual Healthcare Effectiveness Data and Information Set (HEDIS) reporting requirements. According to BCBS: "The Centers for Medicare & Medicaid Services (CMS) requires all Medicare Advantage Organizations and Qualified Health Plans on Exchange(s) to report HEDIS results, as does the National Committee for Quality Assurance (NCQA) for accreditation and quality initiative monitoring. HEDIS Medical Record Review reflects the care patients receive that is not captured through the claims process." Read more here:
CMS Medicare Telehealth Flexibilities (3/19/25)
On March 15, House Resolution (HR) 1968, the "Full-Year Continuing Appropriations and Extensions Act, 2025" was signed into law. This government funding bill is in effect through September 30, 2025:
https://www.congress.gov/bill/119th-congress/house-bill/1968
Section 2207 of HR 1968 addresses the extension of telehealth flexibilities, including delaying the in-person requirement through September 30, 2025:
According to Becker's Health IT:
"Here are five key telehealth-related elements of the bill:
- The bill removes geographic and originating site restrictions, allowing patients to receive telehealth services from various locations, including their homes, regardless of where they live.
- It expands the range of healthcare practitioners authorized to provide telehealth services.
- Federally qualified health centers and rural health clinics will remain eligible to furnish telehealth services.
- The legislation delays the implementation of in-person visit requirements for mental health services delivered via telehealth.
- The bill maintains the authorization of audio-only telehealth services and extends the use of telehealth for hospice care recertification.
Becker's Hospital CFO Report:
"The funding bill does not address the 2.83% Medicare physician pay cut." Read more here:
Additional News:
American Telemedicine Association (ATA):
APA BCBS Antitrust Settlement
APA has updated their statement about the BCBS antitrust settlement - Click here to read
Important notes:
• applies to psychologists who treated patients insured by any Blue Cross Blue Shield company (collectively BCBS) between July 24, 2008 and October 4, 2024
• the deadline for submitting claims is July 29, 2025
• the deadline to opt out of the settlement is March 4, 2025. According to APA, this option appears to be mainly for those who wish to pursue their own antitrust claims against BCBS
From APA: "After reviewing the opt-out guidance, you can direct questions to praclegal@apa.org but there may be limited capacity to respond if there is a high volume of inquiries."
APA Telehealth Waiver - What Psychologists Need to Know (2/19/25)
"Answers to your questions about the evolving Medicare in-person telehealth requirement and upcoming expiration deadline"
Click here to read the article
APA Five Ways to Take Action (2/19/25)
APA publishes the Advocacy Washington Update, which is "a newsletter that highlights how APA Services is working to advance the discipline and practice of psychology on Capitol Hill and beyond". This week's edition highlights five ways that psychologists can take action.
Click here to read more
NC HIEA Teletown Hall February 26 (2/19/25)
The NC Health Information Exchange Authority (HIEA) will hold an online town hall for providers to learn more about the state-designated health information exchange.
Click here to learn more and register
APA Action Alert (2/12/25)
Please take 2 minutes today to ask Congress to take steps to stop funding cuts at the National Institutes of Health (NIH).
Click here to learn more and contact your legislators here.
APA Letter to Members and Psychologists (2/12/25)
On February 7, APA sent a letter to members and psychologists addressing recent and proposed policy changes.
Click here to read the letter.
APA Response Center Website (2/12/25)
APA/APA Services has launched a Response Center website which includes regular updates on policies, APA's advocacy efforts, and actions that psychologists can take. In addition, APA is hosting a live advocacy update on February 25 at 7 PM Eastern.
Click here to learn more.
Aetna and the Clear Pricing Project (CPP) (2/5/25)
Effective January 1, 2025, Aetna became the Third Party Administrator (TPA) for the NC State Health Plan (SHP). For the past two years, NCPA leadership has been working in collaboration with Aetna representatives in preparation for this transition. Information has been shared with members via the Listserv and the weekly APC Updates.
A summary of key points previously shared regarding this transition:
1. Aetna continues to support and administer the Clear Pricing Project (CPP), which was developed by the SHP
2. The CPP fee schedule is separate and distinct from a psychologist's Aetna fee schedule
3. Providers must participate in the Aetna network to serve SHP members as of 1/1/25
4. Providers must elect to join the CPP with Aetna (even if they were currently enrolled in the CPP)
5. If providers don’t enroll in the CPP, Aetna contract rates will apply
6. The CPP fee schedule is determined by the SHP and will continue to function as it did prior to the 1/1/25 transition
7. CPP professional fees are based on 160% of current year Medicare fees
8. Aetna providers were required to enroll in the CPP using a specific Aetna website link. After signing the State Health Plan (SHP) participation agreement on the website, providers would get an immediate receipt and a link to the CPP fee schedule
NCPA is aware that questions regarding enrollment with Aetna and the CPP have arisen subsequent to the January 1 transition. In response to these questions, we reached out to our Aetna contacts and received this information:
Regarding the CPP, the state has decided to close enrollments for all providers regardless of if they are new or existing Aetna providers. This also applies to if they were part of the CPP with BCBS. They were required to re-enroll through the website to continue CPP participation. Re-enrollment requirements were provided on the CPP website for the last year. If the provider did not previously use the online page to enroll, they will not be able to join the CPP in 2025.
If a provider enrolled into CPP via the online Amendment, and is not showing as a participating CPP provider, they can reach out to our designated inbox to inquire on their participation. Please let them know they can reach out to: NorthCarolinaNetwork@aetna.com
Additional Resources:
NC State Health Plan network website - Click here
State Health Plan CPP webpage - Click here
Aetna CPP webpage - Click here
APC Updates - Click here to access
Please note: these updates are archived on the NCPA wesbite behind the member paywall. Refer to the updates dated: 12/13/23; 12/20/23; 1/10/24; 1/31/24; 11/20/24; 12/4/24
CMS (2/5/25)
"To safeguard beneficiaries from Medicare fraud, the Centers for Medicare & Medicaid Services (CMS) has issued Change Request (CR) 13754, instructing Medicare Administrative Contractors (MACs) to disable beneficiary eligibility information from their Interactive Voice Response (IVR) systems by March 31, 2025...Palmetto GBA has removed this feature effective January 31, 2025, at 7 p.m. ET. This means eligibility information is no longer accessible via the IVR...This pilot program involves most MACs, including Palmetto GBA."
Click here to see the announcement.
Click here to read the CR.
NC HIEA (2/5/25)
Click here to read the January newsletter.
Change Healthcare (1/28/25)
From the Change Healthcare HIPAA Website Substitute notice - updated January 24, 2025:
"The review of personal information potentially involved in this incident is substantially complete. Since June 20, 2024 CHC has been providing this notice to help individuals understand what happened, let them know that their information may have been impacted, and give them information on steps they can take to protect their privacy, including enrolling in two years of complimentary credit monitoring and identity theft protection services if they believe that their information may have been impacted...
The last round of impacted customers with attributed individuals was notified to confirm whether they want CHC to handle notifications on their behalf. Notices were sent to impacted customers on June 20, 2024, August 8, 2024, September 16, 2024, November 21, 2024, and December 4, 2024. At this time, CHC does not anticipate that it will identify any additional customers."
From the United Health Group Change Healthcare Cyber Response webpage - updated January 27, 2025
"Change Healthcare clearinghouse services are now restored and the repayment phase of the Temporary Funding Assistance Program is in process. As of October 15, recipients of program funding have repaid $3.2B."
Click here to read more.
Becker's Health IT article- January 16, 2025 - Click here to read more.
APA (1/22/25)
The Department of Health and Human Services (HHS) issued an amendment to the HIPAA privacy rule specifically designed to enhance privacy protections for reproductive health care. APA Services published an article on January 9 addressing the new amendment and what it means for psychologists. Some key takeaways:
1. "The new HIPAA rule aims to safeguard patient privacy by restricting the disclosure of sensitive health information related to reproductive health care, which is defined broadly under the rule to include not just abortion care but also contraception, fertility treatments, and other related services."
2. "Compliance with the Final Rule is required starting on December 23, 2024, for every aspect of the Rule except for the Notice of Privacy Practice (NPPs), which is not required until February 16, 2026."
3. "HHS clarifies that requests for PHI made by patients,their authorized representatives, HHS, or other third parties for purposes of treatment, payment, or health care operations are not considered prohibited. Therefore, providers, including psychologists, can continue to disclose PHI in those situations as they did before this new rule."
4. "When receiving requests for PHI that may relate to reproductive health care, the new rule requires providers to obtain an attestation confirming that the PHI is not used for a prohibited activity and signed by the requesting party before any reproductive health information is disclosed pursuant to certain HIPAA exceptions, including: (1) health oversight activities; (2) judicial and administrative proceedings; (3) law enforcement purposes; and (4) disclosures to a medical examiner about a decedent."
The article includes links to the HIPAA Privacy Rule amendment, the APA's FAQs about abortion laws and psychology practice, and a model attestation form.
Click here to read the full article.
NCPA will continue to share updates about this new amendment as we receive the information.
Substance Abuse and Mental Health Services Administration (SAMHSA) (1/22/25)
"Substance Use Disorder Treatment Month (Treatment Month), which will launch in January 2025, serves to support:
- People contemplating or seeking help for their substance use
- Practitioners treating or considering treating substance use disorder
- Friends, family, and loved ones of those with substance use conditions"
Click here to learn more and access the events calendar and social media toolkit.
BCBSNC (1/15/25)
1. "Blue Cross and Blue Shield of North Carolina (Blue Cross NC) is committed to improving collaboration with providers / ACOs in our value-based reimbursement programs – Blue Premier℠ and Medicare Advantage Quality Incentive Program (MAQIP). As a part of this effort, Blue Cross NC will be implementing our annual provider satisfaction survey.
In early January 2025, Quality Provider Engagement Analysts will email the 2025 Annual Provider Satisfaction Survey to designated provider quality contacts with a survey completion deadline of February 28, 2025. This 15-minute survey will serve as a road map to enhance 2025 Quality Provider education and strengthen collaboration with our provider / ACO partners."
Click here to read more.
2. "Providers in the Blue Cross and Blue Shield of North Carolina (Blue Cross NC) network recently received a Provider Relationship Survey in their email. We would like to know about your experience as a partner of Blue Cross NC. Please share your honest feedback on your satisfaction level as a participating Blue Cross NC network provider. We value your response, and it will help to inform internal improvements."
Click here to read more.
NC Health Information Exchange (HIE) (1/15/25)
Click here to read the latest newsletter.
UHC (1/15/25)
Updated 2025 Care Provider Administrative Guide - Click here to view.
APA (1/8/25)
1. Important Information for Psychologists Regarding the Blue Cross Blue Shield Settlement
"Psychologists who treated patients insured by any Blue Cross Blue Shield company (collectively, BCBS) between July 24, 2008, and October 4, 2024, may be eligible for compensation from a significant antitrust litigation settlement. This article provides preliminary information about the BCBS settlement and the claims process, and to inform you that the deadline for submitting claims is July 29, 2025."
Click here to read the full article.
2. Medicare and Telehealth
The following was shared by Diane Pedulla, JD from APA's Office of Health Care Financing:
"The American Relief Act 2025, signed into law by President Biden on December 21, 2024, keeps the federal government running and extends key telehealth flexibilities in Medicare until March 31, 2025. Most important to psychologists, this extension continues the delay of the in-person visit requirement for behavioral telehealth services in Medicare. Other flexibilities extended under the Act, such as the geographic and originating site requirements and the use of audio only technology, only concern medical services as these flexibilities were made permanent for behavioral health in previous legislation.
Regarding Medicare payments, a provision to add 2.5% to the 2025 conversion factor to help offset the projected 2.83% decrease was dropped from the final version of the bill. This results in a decrease from $33.29 in 2024 to $32.35 in 2025. Psychologists will see different changes in their payments depending upon the services they provide. Because CMS increased the work values for psychotherapy services, psychologists billing for psychotherapy will receive a slightly higher payment, despite the lower conversion factor. To illustrate, a psychologist in Seattle, WA will see payments for 90834 rising from $111.31 in 2024 to $112.45 in 2025. When that same psychologist bills 96130 for a psychological testing evaluation in 2025, the payment will be $127.05, a reduction from $129.65 in 2024. Exact payment amounts will differ depending on geographic location.
APA and other specialty societies will continue their advocacy efforts when Congress returns for the next round of government funding."
Additional resources for members:
HR 10545, American Relief Act, 2025 - Click here
(Section 3207 addresses telehealth flexibilities)
HHS Telehealth provider resource page - Click here
CMS Physician Fee Schedule Search page - Click here
ProPublica (1/8/25)
Two new articles in the ProPublica series:
Insurers Continue to Rely on Doctors Whose Judgments Have Been Criticized by Courts
Click here to read
Her Mental health Treatment was Helping. That's Why Insurance Cut Off her Coverage
Click here to read
CMS 2025 Physician Fee Schedule (1/2/25)
The Calendar Year 2025 Physician Fee Schedule (PFS) Final Rule, which addresses Medicare payments and policies, will be in effect as of January 1, 2025.
Resources:
CMS 2025 PFS Fact Sheet - Click here
CMS PFS webpage - Click here
PFS Look-up Tool Overview page - Click here
Place of Service Codes for Professional Services (updated May 2, 2024) - Click here
North Carolina Executive Order: Bereavement Leave for State Employees (1/2/25)
On November 1, Governor Ray Cooper issued Executive Order 325 which provides bereavement leave for state employees who lose a family member or a coworker.
From the press release:
"Employees will be eligible for up to 40 hours of paid leave following the loss of an immediate family member, including a spouse, child, sibling, parent, or grandparent. Step, half, and in-law family members are included as well as any dependent living in the employee’s home.
The bereavement leave covers the loss of a loved one for any reason and is retroactive to September 27, 2024 due to Hurricane Helene. Any eligible employee who suffered a loss after September 27, whether due to the storm or other causes, will have access to the leave. Eligible employees have up to six months after the death to take bereavement leave.
Employees who lost a colleague will be eligible for up to eight hours of bereavement leave to attend a funeral or memorial service for their coworker."
Click here to read the full press release.
Additional Resources:
Link to Executive Order 325 - Click here
Bereavement Leave FAQs - Click here
