The Centers for Medicare & Medicaid Services’ latest proposed fee schedule includes codes for providers to bill Medicare for certain digital therapeutics.

On July 10, CMS released its proposed 2025 Physician Fee Schedule (PFS) rule. It contained several behavioral health-related provisions, including changes to how intensive outpatient programs (IOPs) and partial hospitalization programs (PHPs) will be compensated.

In the same rule, CMS proposes three new Healthcare Common Procedure Coding System (HCPCS) codes for compensating providers for the use of “digital mental health treatment (DMHT) devices furnished incident to or integral to professional behavioral health services used in conjunction with ongoing behavioral health care treatment under a behavioral health treatment plan of care.” Only devices that are cleared by the Food and Drug Administration qualify, according to the proposed rule. 

CMS modeled the proposed rules for the digital tools after the codes for remote therapeutic monitoring (RTM) services for other physical health services. The three codes address the initial supply and patient onboarding for the device, the first 20 minutes of reviewing device data and other patient inputs each month and each additional 20 minutes of data review. All three codes require that the device be used to “augment a behavioral therapy plan.”

CMS’ new codes follow up on the previous rule language referring to digital cognitive behavioral therapy. They further refine further references to digital mental health treatment devices to mean devices cleared by the FDA that generate or deliver mental health treatment interventions that have “a demonstrable positive therapeutic impact on a patient’s health.”

CMS continues to strike a conservative, if not cautious, tone in the rule language about the implementation of these devices, more often referred to as digital therapeutics in the market at large.

“We aim to both provide access to vital behavioral health services and gather further information about the delivery of digital behavioral health therapies, their effectiveness, their adoption by practitioners as complements in the care they furnish, and their use by patients for the treatment of behavioral health conditions,” the rule states.

CMS is struggling to assign a price to digital therapeutics. It highlights prices ranging from free to hundreds of dollars and has several sources of expense like per-use charges and licensing fees. The organization is deferring pricing to its regional contracting partners in an approach called ” contractor pricing.”

This development is likely an incremental boon to startups and other organizations trying to bring digital therapeutics into the mainstream. The two most mature businesses in behavioral health-related digital therapeutics have suffered immense failures for a lack of interest and clear avenues for revenue, in part because the collecting payer apparatus doesn’t know what to do with these services. The respective collapses of Pear Therapeutics and Akili cast doubt on their place in the behavioral health industry.

Despite the failure of these specific companies, the present and near future of behavioral health clearly points to greater technology adoption to refine the business aspect and improve the clinical aspect of the industry. Several of the largest organizations in behavioral health have clear plans to adopt more technology.