CMS Proposes New Telehealth Rules for Psychiatry: What Changes in 2027 and What to Do Before September 14

What Are the CMS 2027 Telehealth Changes for Psychiatry?

As of July 2026, the CMS CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) extends behavioral health telehealth flexibilities through December 31, 2027, introduces mandatory telehealth platform modifiers BB and BC effective January 1, 2027, and proposes converting the G2211 visit complexity add-on into a modifier that increases the associated E/M payment by 16%. For psychiatry practices that deliver a significant portion of care via telehealth, these changes affect how every remote session is billed and documented starting next year.

• Telehealth extension: The Consolidated Appropriations Act of 2026 extends geographic, originating site, audio-only, and in-person visit requirement flexibilities for behavioral health telehealth through the end of 2027.
• New modifiers BB and BC: Beginning January 1, 2027, telehealth claims must include modifier BB or BC when the billing practitioner has a contract or payment arrangement with the entity that owns the telehealth platform.
• Comment deadline: The 60-day public comment period for CMS-1848-P closes September 14, 2026. CMS is expected to release the final rule this November.

What CMS Proposed for 2027

On July 14, 2026, CMS released the CY 2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P), published in the Federal Register on July 16, 2026. The rule includes more than a dozen changes that touch telehealth, but three provisions matter most for psychiatry and behavioral health practices.

First, the Consolidated Appropriations Act (CAA) of 2026 directed CMS to extend key telehealth flexibilities through 2027. For behavioral health, this means patients can continue receiving telepsychiatry services in their homes without traditional geographic restrictions, audio-only sessions remain covered when the patient cannot access video, and the in-person visit requirement (one annual visit for established telehealth patients) carries forward with the same exception process. These flexibilities were set to expire, and the extension gives psychiatry practices an additional year of stable telehealth billing rules.

Second, CMS proposes mandatory modifiers BB and BC on telehealth claims where the billing practitioner contracts with or has a payment arrangement with the entity that owns the telehealth platform. Modifier BB applies when the practitioner uses a platform under a direct contract. Modifier BC applies when the services are furnished incident-to and through a contracted platform. The modifiers do not change payment amounts. They make platform-affiliated telehealth visible in Medicare claims data for the first time, which signals that CMS intends to use this data for future policy decisions.

Third, CMS proposes converting the G2211 visit complexity add-on from a standalone billing code into a modifier appended to the E/M base code, increasing the associated E/M payment by 16%. A separate modifier for ACO practitioners would increase the E/M by 32%. For psychiatrists who bill E/M services alongside psychotherapy, this structural change affects how the claim line is built and what the expected reimbursement looks like.

Does This Affect My Psychiatry Practice?

These changes apply to any psychiatry or behavioral health practice that bills Medicare for telehealth services. If your practice delivers psychotherapy, psychiatric evaluations, or medication management via video or audio-only telehealth to Medicare patients, the proposed rule directly affects your billing workflow for 2027.

Practices that use a telehealth platform such as Doxy.me, SimplePractice Telehealth, Zoom for Healthcare, or a similar third-party system need to determine whether their arrangement triggers the BB or BC modifier requirement. The key question is whether the billing practitioner has a contractual or payment relationship with the platform owner. If the answer is yes, every telehealth claim submitted through that platform must carry the applicable modifier starting January 1, 2027.

In our experience matching psychiatry practices with billing partners, the providers most affected by telehealth billing changes are solo practitioners and small groups that adopted telehealth rapidly during the pandemic but never formalized their billing workflows to account for modifiers, place-of-service codes, and platform disclosure requirements. A practice that has been billing telehealth sessions correctly under the current rules still needs to add the BB or BC modifier to every applicable claim next year, which means EHR templates, superbills, and claim scrubbing rules all need updating.

What Changes for Psychiatry Telehealth Billing in 2027?

Here is how the proposed 2027 rules compare to the current 2026 telehealth billing framework for psychiatry services:

The conversion factor decrease deserves specific attention for psychiatry. Because psychotherapy codes (90832, 90834, 90837) and psychiatric evaluation codes (90791, 90792) are valued under the same fee schedule, the 1.68% reduction applies across the board. For a practice billing 200 Medicare sessions per month, even a small per-session reduction compounds into meaningful annual revenue loss. For a deeper look at how psychiatry CPT codes interact with E/M and telehealth billing, see our coding guide.

What Should Psychiatry Practices Do Now?

These steps protect your telehealth billing workflow before the proposed changes take effect.

1. Confirm your telehealth platform arrangement. Determine whether your practice has a contract or payment relationship with the entity that owns the telehealth platform you use. If it does, every telehealth claim will need modifier BB or BC starting January 1, 2027.
2. Update your EHR templates and superbills. Add fields for the BB and BC modifiers so they can be appended to telehealth claims automatically. If your EHR does not support the new modifiers yet, contact your vendor before year-end to confirm an update timeline.
3. Model the conversion factor impact on your Medicare revenue. Pull your Medicare psychotherapy and E/M claim volume for the last 12 months, apply the proposed 1.68% reduction, and calculate the annual revenue impact. That number is your baseline exposure.
4. Verify your in-person visit documentation. The annual in-person visit requirement for behavioral health telehealth patients continues through 2027. Confirm that your scheduling system flags patients approaching their 12-month window so you do not lose telehealth billing eligibility mid-treatment.
5. Submit a comment to CMS if the changes affect your practice. Comments are accepted at regulations.gov under docket CMS-1848-P through September 14, 2026. Include specific volume data and revenue projections to strengthen your submission.
6. Ask your billing company whether they are tracking these changes. If your billing partner has not flagged the BB/BC modifier requirement or the conversion factor cut, that tells you something about their regulatory monitoring. Psychiatry practices need a billing team that stays ahead of CMS rule changes, not one that discovers them after claims start getting rejected.

Common Telehealth Billing Mistakes in Psychiatry

One question we hear constantly from behavioral health practice managers is whether their telehealth billing has been correct all along. In many cases, the answer is that it has been close but not fully compliant, and the 2027 changes will expose the gaps.

The most common telehealth billing mistake in psychiatry is using the wrong place-of-service code. Telehealth sessions billed with POS 11 (office) instead of POS 10 (telehealth provided in the patient’s home) or POS 02 (telehealth provided at a facility) change the reimbursement rate and can trigger post-payment audits. The second most common error is omitting modifier 95 or the GT modifier on telehealth claims where the payer requires it. Different payers have different modifier rules, and a claim that passes for one payer will deny for another.

The third mistake is failing to document audio-only sessions with the specific payer-required attestation that the patient could not access video. Medicare allows audio-only for behavioral health, but only when the provider is capable of video and the patient declines or lacks access. Without that attestation in the note, the claim is vulnerable to denial on audit. These are exactly the kinds of specialty-specific compliance details that a billing company with psychiatry billing experience catches before the claim goes out.

Frequently Asked Questions

Next Steps

• Review your telehealth platform contracts to determine whether modifier BB or BC will apply to your Medicare claims in 2027.
• Model the conversion factor reduction against your Medicare psychotherapy and E/M volume to quantify your revenue exposure.
• If your billing team has not raised these changes with you, consider whether a specialized psychiatry billing partner would better protect your telehealth revenue. Psychiatry Billers matches mental health practices with billing companies that understand behavioral health telehealth compliance, free for providers.