ASAM Comments on Proposed 2026 Medicare Physician Fee Schedule

On September 12, ASAM submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) on its proposed 2026 Medicare Physician Fee Schedule. In its letter, ASAM outlined several suggestions to improve access to behavioral health services, including substance use disorder (SUD) treatment, and to better align treatment codes with this goal in mind. ASAM's recommendations focused on three key areas: outpatient SUD treatment, intensive outpatient treatment, and motivational interviewing.

ASAM suggests that:

• CMS review Medicare’s office-based SUD treatment codes to ensure they are meeting their intended purpose and consider several actions, including:
  • Make significant coding modifications to the office-based SUD treatment set that account for medical management in cases where a billing practitioner is providing comprehensive biopsychosocial initiation services directly or through supervision, like the existing OTP payment structure. ASAM has outlined the Patient-Centered Opioid Addiction Treatment (P-COAT) model which describes three types of treatment initiation payment structures: (1) treatment supervision and medical management by a non-ASP, (2) treatment supervision and medical management by an ASP, OR (3) comprehensive medical management and psychosocial services. Additional coding granularity would also mirror the OTP code set which is much more detailed, structured, and financially sustainable;
  • Add several codes limited to OTPs as services eligible for billing by non-OTP practices to the extent those services are not duplicative of existing services described by the initiation codes; 
  • and more.
• CMS takes additional action to expand access to intensive outpatient (IOP) for SUD
• If CMS were to create new coding to describe motivational interviewing, it should consider a coding structure that reflects existing screening, brief intervention, and referral to treatment (SBIRT) codes. Any new coding should permit any clinician eligible to bill Medicare for behavioral health services to bill these services, as well as by clinicians billing incident to and under the general supervision of a billing practitioner.

Read the full comment letter and list of recommendations here.