Behavioral health organizations have billing needs that differ from other medical agencies. The Centers for Medicare & Medicaid Services (CMS) filed its Medicare Physician Fee Schedule (MPFS) with several behavioral health updates.

The changes are intended to increase access to behavioral health services, improve care coordination between general and specialty care physicians, and support other goals specified in the CMS Behavioral Health Strategy. This article will review some common questions concerning the new changes for behavioral health billing in 2023.

What is Incident-To Billing for Behavioral Health Services?

The Final Rule eases the criteria for physician and non-physician practitioner (NPP) supervision for mental health services, citing rising demand for behavioral health services and a shortage of workers.

Effective in 2023, auxiliary personnel, such as licensed professional counselors and licensed marriage and family therapists, are now permitted to provide behavioral health services under the general supervision of a doctor or NPP due to a new exception that CMS made to the “incident to” regulation’s direct supervision requirement.

For this direct supervision exception, CMS opted not to define “behavioral health services” through HCPCS codes, noting that the agency believed individual practitioners were best qualified to evaluate whether a given treatment or diagnostic service is a behavioral health service.

However, CMS asserts that it typically considers any service for diagnosing, assessing, or treating a mental health issue, including a drug use disorder, to be behavioral health care. According to CMS, behavioral health care might include, but is not limited to:

  • Psychotherapy
  • Screening
  • Short intervention and referral to treatment services
  • Psychiatric diagnostic examinations.

For the first time in 2023, the CMS will let doctors bill behavioral services provided by auxiliary personnel.


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Which Requirements are Under Behavioral Health Integration?

CMS finalizes procedures for paying clinical psychologists (CPs) and licensed clinical social workers (LCSW) who provide integrated behavioral healthcare as part of a primary care team in the Final Rule.

The Final Rule establishes a new Behavioral Health Integration (BHI) HCPCS code, G0323, allowing CPs and LCSWs to charge for monthly care integration where the mental health services they offer are the main point of care integration.

Care management services for mental health conditions will be at least 20 minutes each calendar month of a clinical psychologist or licensed clinical social worker time, with the following necessary elements:

  • Behavioral healthcare planning relating to behavioral or psychiatric health concerns, including revision for patients who are not progressing or whose status changes.
  • Facilitating and organizing treatment, such as psychotherapy, collaboration with, or referral to physicians and practitioners authorized by Medicare legislation to administer drugs and provide emergency services, counseling, and psychiatric consultation.
  • Initial evaluation or follow-up monitoring, including using validated rating scales as appropriate.
  • Care coordination with a specific member of the care team.

What are the Clinical Considerations and Allowable Services Under GO323?

The Final Rule adds G0323 to the specified care management services subject to general supervision. They include;

  • When all incident-to conditions are met, CPs are entitled to provide and bill for services supplied by clinical personnel incident to their professional services based on their statutory benefit category
  • LCSWs can only charge Medicare for services they provide directly and personally
  • All BHI services, including G0323, require an initiating visit for a new patient or a beneficiary who has not seen the billing agency within a year of the start of BHI services to establish the beneficiary’s relationship with the billing practitioner.
  • Recognizing that existing initial visit codes do not fully include a CP’s scope of practice, CMS is finalizing CPT 90791 psychiatric diagnostic examination as the initiating visit for G3023. CPs and LCSWs may bill this code.

Are There Any Changes Related to Opioid Treatment Programs?

The Final Rule also makes several changes to how Medicare would pay for services provided by OTPs to treat opioid use disorder (OUD).

Methadone Pricing

The Final Rule revises the price mechanism for the drug component of the methadone weekly bundle and the add-on code for methadone take-home supplies. The Final Rule will base the payment amount for the drug component of HCPCS codes G2067 and G2078 in 2023 and the following years on the payment amount for methadone. The agency expects to increase this value yearly to account for inflation.

Rates for Individual Therapy

Individual therapy rates in the bundle will be based on a 45-minute therapy session code rather than a 30-minute therapy session code in 2023. CMS notes that the modification is not intended to impose a time limit on individual therapy sessions for a service to qualify as an OUD treatment service.

An OTP may bill for an episode of care even if the only OUD treatment service provided to the beneficiary during the episode is a 45-minute individual therapy session. The move will boost funding for OUD treatment in the OTP context by acknowledging the severity of the OUD patient population’s demands and the time spent by an OTP delivering individual therapy.

Mobile OTP Units

Finally, the CMS stated that OTPs might bill Medicare for medically reasonable and necessary services provided via mobile units following DEA guidance in response to recently updated DEA regulations that allow OTPs to add a “mobile component” to their current registration.

Steps to Prepare for the New Behavioral Health Billing Opportunities

  1. Review and update your billing software features to enable the electronic transmission of approved clinical rating scales, which allows CPs and LCSWs to offer the follow-up monitoring specified by the code
  2. Agencies that provide outsourced care management services should consider adding LCSWs and other types of therapists to their clinical personnel to complement doctors and NPPs.
  3. Utilize software platforms that enable two-way audiovisual interactions between LCSWs and their patients, allowing them to do the initial evaluation and follow-up monitoring through these platforms.
  4. Educate CPs and LCSWs on the value of GO323 and support them in implementing and delivering the service

Logik Solutions Can Help You with the New Behavioral Health Billing Opportunities in 2023

Behavioral health services will continue to grow in 2023 and beyond, as CMS acknowledges that they have been under-resourced for too long. Behavioral health organizations should seek ways to enhance their billing processes and revenue cycle.

At Logik, we’ve partnered with behavioral health agencies for over 30 years. Our signature billing software, designed for enterprise-level behavioral health organizations, automates billing and patient administration, assisting agencies in maximizing revenue and efficiency. Schedule a demo and witness how our billing software streamlines billing and practice operations.