Call for Comments

Centers for Medicare & Medicaid Services Call for Comments

In response to an August 3rd Executive Order, CMS has proposed changes to several rules and is now requesting feedback.


Ensure that psychiatric-mental health nursing's voice is heard!

To share your feedback and help inform APNA's organizational Response:

  • Review the information below and see this fact sheet for more information. You can view the proposed rule in its entirety on the Federal Register here.
  • Submit your electronic comments via the website here by October 5th.
  • Email a copy of your comments to by September 30th to inform APNA's organizational response.

Proposed changes relevant to psychiatric-mental health nursing from the Physician Fee Schedule Proposed Rule include:

  • Adding certain services to the 2021 Medicare telehealth list, including: Group Psychotherapy, Neurobehavioral Status Exam, Care Planning for Patients with Cognitive Impairment, Home Visits, Psychological and Neuropsychological Testing, and more.
  • Clarifying that licensed clinical social workers, clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) can furnish the brief online assessment and management services as well as virtual check-ins and remote evaluation services.
  • Allowing direct supervision to be provided using real-time, interactive audio and video technology (excluding telephone that does not also include video) through December 31, 2021.
  • Revaluing code sets to align with increase in values finalized for for office/outpatient evaluation and management visits, including Psychiatric Diagnostic Evaluations and Psychotherapy Services
  • Allowing nurse practitioners, clinical nurse specialists, physician assistants, and certified nurse-midwives (instead of only physicians) to supervise others performing diagnostic tests consistent with state law and licensure.
  • Opioid Use Disorder Treatment Services Furnished by Opioid Treatment Programs (OTPs): Creating two new add-on codes, one for nasal naloxone and another for auto-injector naloxone and allowing periodic assessments via two-way interactive audio-video communication technology
  • Implementing SUPPORT Act requirement that Initial Preventive Physical Examinations and Annual Wellness Visits include screening for potential substance use disorders (SUDs) and a review of any current opioid prescriptions
  • Implementing SUPPORT Act requirement that the prescribing of a Schedule II, III, IV, or V controlled substance under Medicare Part D be done electronically in accordance with an electronic prescription drug program (Request for comments here regarding exceptions and penalties.)
  • Proposing to include new evaluation and management and care management CPT and HCPCS codes in the methodology used to assign beneficiaries to ACOs to update the definition of primary care services to reflect services for cognitive impairment and chronic care management
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