CMS Focuses on SDoH and Behavioral Health Services in Proposed 2025 OPPS Ruling

In a move to support individuals at high risk of suicide or overdose, the Centers for Medicare & Medicaid Services (CMS) is proposing changes in the payment structure and services to expand telehealth options for care management and the inclusion of social determinants of health(SDoH) risk factors in outpatient treatment programs. These changes aim to provide better financial backing for practitioners who deliver critical interventions and follow-up care for at-risk populations.

Among the proposed changes, CMS is introducing separate payments for safety planning interventions. This new payment structure, GSPI1, will compensate practitioners for developing and implementing safety plans, which are vital for individuals identified as having a high-risk of suicide or overdose. This code is in addition to or separate from the evaluation and management (E&M) visit or psychotherapy services.

Additionally, post-discharge follow-up contacts will now have separate payment, ensuring continuous care and support during a critical recovery phase. The proposal is looking to create a monthly billing code to provide post-discharge follow-up contacts that are performed in conjunction with a discharge from the emergency department for a crisis encounter. This would be a bundled service describing four calls in a month, each lasting between 10-20 minutes, GFCI1, pricing would be a direct crosswalk with principal care management- 99426.

CMS is also focusing on the integration of telehealth into more behavioral health treatment services. The new payment and coding proposals will facilitate the use of technology to enhance treatment delivery. This initiative is part of a broader effort to modernize and improve access to behavioral health services. The proposal is specifically looking at the expansion of telehealth for General Behavioral Health Integration, 99484 and Principal Care Management, 99424-99427. As well as potential reimbursement for FDA approved digital mental health treatment (DMHT) devices (See page 377).  

CMS is proposing updates for Opioid Treatment Programs (OTPs). In relation to SDoH, CMS is making efforts and opening comment for inclusion of the health-related social needs tool for those with opioid use disorder in OTPs. Although the reimbursement for providing the SDoH risk assessment was added last year, there is a recommended expansion to include this same add on for OTP inclusive in the bundled intake. The enhanced payments will support a more thorough assessment of patients’ needs, including health-related social needs, harm reduction interventions, and recovery support services.

These proposed changes by CMS represent a proactive approach to addressing some of the most pressing issues in behavioral health and opioid treatment. For further details see the 2025 OPPS proposed ruling, starting around page 606.