The 2026 Landscape for Behavioral Health
The 2026 Physician Fee Schedule has introduced groundbreaking changes, acknowledging the role of Artificial Intelligence in therapy audits and permanently cementing telehealth access.
1. New AI-Assisted Therapy Codes
For the first time, CMS has introduced "add-on" codes for sessions where AI tools are used for note-taking and sentiment analysis:
- +908AI1: AI-assisted documentation review (Add-on to 90837)
- +908AI2: Automated sentiment analysis reporting
Note: These codes are currently for tracking purposes but are expected to become reimbursable by Q3 2026.
2. Telehealth Permanency Act 2026
The uncertainty is over. Audio-only visits (90832-90837 with modifier 93) are now permanently covered for established patients, provided an in-person visit occurs once every 12 months.
3. Collaborative Care Expansion
New reimbursement rates for inter-professional consultations (99452) have increased by 8% to encourage PCP-Psychiatrist collaboration.
Billing Strategy for 2026
- Update EHRs to capture AI-usage timestamps.
- Audit all telehealth claims for the new "Permanent Place of Service" codes (POS 10 vs POS 02).
- Ensure modifier FQ is used for audio-only services in rural areas.