DTx Commercialization and Reimbursement

 View Only

Cy2026 CMS PFS Policy Changes

  • 1.  Cy2026 CMS PFS Policy Changes

    Posted 11-14-2025 12:21:00 PM

    Hello SIG Members, 

    Please see below for CY2026 Physician Fee Schedule final rule updates.

    Key Final Telehealth and Virtual Care Policies (CY2026)

    1. Telehealth Services List Process

    • CMS will streamline adding services to the Medicare Telehealth Services List by removing Steps 4 and 5 and eliminating the provisional and permanent categories.

    2. Additions to the Telehealth Services List (Effective CY2026)

    • Multiple-Family Group Psychotherapy – CPT 90849
    • Group Behavioral Counseling for Obesity – CPT G0473
    • Infectious Disease Add-on – CPT G0545
    • Auditory Osseointegrated Sound Processor Services – CPT 92622, 92623

    3. Telehealth Codes and Coverage Updates

    • G0136 (Health Risk Assessment) – retained on the Telehealth Services List (CMS withdrew the proposal to delete)
    • HCPCS G0552 (Behavioral Health Integration) – CMS will work with MACs to clarify billing rules and may consider national pricing in future rulemaking
    • RTM, RPM, and DMHT services – no place of service code required

    4. Critical Care and Frequency Limitations

    • Removes telehealth frequency limits for critical care consultations and certain inpatient/nursing facility services

    5. Direct Supervision Definition

    • Permanently adopts a definition allowing "immediate availability" via real-time audio/video communication for services under §410.26 (excluding surgical services with 010 or 090 global periods)

    6. Teaching Physician Flexibility

    • Virtual presence of teaching physicians is permanently allowed across all settings when services involve a three-way telehealth visit (physician, resident, and patient in separate locations)

    7. Digital Mental Health Therapeutic (DMHT) Devices

    • Finalizes payment for FDA-cleared or De Novo-authorized DMHT devices for ADHD digital therapy
    • Clarifies that patients must have a mental health diagnosis; the billing practitioner does not need to make the original diagnosis

    8. Medicare Diabetes Prevention Program (MDPP)

    • Establishes a temporary four-year "online delivery period" (Jan2026 – Dec2029) to test asynchronous MDPP delivery
    • MDPP suppliers may operate virtually; clarify that MDPP suppliers are not required to maintain in-person delivery capability through December 31, 2029.

    9. Provider Enrollment and Location Policies

    • CMS will not extend the temporary home address policy; guidance remains available via CMS FAQ
    • State licensure and Medicare enrollment requirements continue to apply
    • Future policy updates will occur through subregulatory guidance, not formal rulemaking

    10. Remote Monitoring

    • Finalized changes to allow billing for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) when data is collected for 2 to 15 days in a 30-day period (previously, a minimum of 16 days was required)



    ------------------------------
    Alexis Apple
    Director, Federal Affairs
    American Telemedicine Association
    ------------------------------