APA Advocacy Updates

APA Advocacy Prompts Blue Shield to Rescind Psychotherapy Billing Policies
Following APA advocacy, Blue Shield of California has agreed to rescind two psychotherapy reimbursement policies that conflicted with CPT coding guidance and created unnecessary administrative burden. Blue Shield will no longer require psychiatrists to append modifier 25 to E/M services billed with psychotherapy add-on codes. Additionally, Blue Shield Promise Health Plan will discontinue its claims editing policy that automatically denied payment for psychotherapy add-on codes when billed with higher-level E/M codes. Read more here.

Automatic Downcoding E&M Policy Survey
Effective July 1, 2026, HCSC’s BCBS plans in Illinois, Montana, New Mexico, Oklahoma, and Texas implemented automatic downcoding policies. Automatic downcoding means the payer changed the E/M code level without ever asking to see the physician’s clinical documentation. To better inform our advocacy efforts, APA is collecting information via a survey about how members are being impacted by this. Please include if you have appealed the downcoding decision and if you were successful in doing so, along with how long the process took. If you practice outside of these states (Il, MT, NM, OK, TX) or have experienced automatic E/M downcoding by another commercial payer, we encourage you to share your experience by completing the survey as well.

APA Advocacy Win: CMS Releases Proposed CY 2027 Physician Fee Schedule
CMS has released the proposed CY 2027 physician fee schedule that includes several changes APA has long advocated for, including greater flexibility for teaching physician telehealth supervision when either the teaching physician or resident is physically located with the patient. CMS is also proposing reimbursement increases to Collaborative Care Model services through higher work and practice expense RVUs, in response to requests from APA and others. However, due in part to the expiration of the temporary 2.5% legislative payment increase for CY 2026 enacted by H.R. 1, CMS proposes a 1.68% reduction in the Medicare conversion factor for non-advanced alternative payment model qualified participants, and a 1.19% decrease in the conversion factor for APM qualified participants.

APA Urges CMS to Revise the Interim Final Medicaid Community Engagement Requirements
APA responded to the Centers for Medicare and Medicaid Services interim final with comment period (IFC), Medicaid Program; Community Engagement for Certain Individuals urging revisions prior to finalization. APA highlights provisions in which the IFC exceeds the plain language of the statute and that finalizing the IFC as drafted, would increase hardship for beneficiaries, health care providers, and state Medicaid agencies. Read more here.

APA Submits Comments on Training and Care Delivery Models for Potential FDA-Approved Psychedelic Therapies
APA responded to the Health Resources and Services Administration (HRSA) Request for Information (RFI); Training and Care Delivery Models for Safe Administration of Potential FDA-Approved Psychedelic Therapies in Ambulatory Clinical Settings. APA supports continued rigorous research into the safety and efficacy of psychedelic medicines and recommends that HRSA also establish governance, surveillance, and accountability systems before supporting broad implementation. Read more here.

APA Supports Stronger Enforcement of Parity Law
The Mental Health Parity and Addiction Equity Act of 2008 (parity law) requires health plans that offer behavioral health coverage to ensure that financial requirements and treatment limits on these benefits are no more restrictive than those on medical and surgical benefits. However, patients across the country continue to face illegal barriers to mental health and substance use disorder treatment. Representative Tom Kean (R-NJ) introduced the Mental Health Parity Enforcement and Funding Act (H.R. 9551), which would help address enforcement issues by authorizing civil monetary penalties for parity violations, extending liability to plan sponsors, administrators, and service providers, and providing a $30 million annual appropriation for EBSA enforcement activities. APA supported this bill in a letter and action alert from members urging their representatives to support the legislation. Click here to write your legislator on this important effort.

APA Endorses Bills to Study AI Impacts
APA endorsed Representative Balint’s (D-VT) Addictive Design Act (H.R. 9948) that would put several requirements on AI chatbot companies, including banning them from allowing youth to access features of their AI chatbots known to increase addiction, unhealthy emotional attachment, and compulsive use. It would also invest in scientific research into the mental health risks associated with AI chatbots for youth and fund efforts to educate parents on how to identify warning signs in youth associated with AI chatbot use. “AI has the potential to improve mental health care, but innovation must be grounded in evidence and designed to protect patients – especially children and adolescents,” APA’s CEO and Medical Director Marketa M. Wills, M.D., M.B.A, said in a news release. “AI chatbots should never replace the physician-patient relationship, which remains essential to safe, evidence-based, patient-centered care.”