CMS proposed an update to Medicare reimbursement rates for TMS CPT codes 90867, 90868, and 90869 that would link approximately 8% of per-session payment to patient-reported outcome data. Under the proposal, clinics would submit standardized PHQ-9 scores at intake and at session 30. Clinics with documented response rates above the national mean would receive the full per-session rate; those below would receive a base rate.
The proposal is part of a broader CMS effort to tie behavioral health reimbursement to measurable outcomes. Industry response has been mixed. The Clinical TMS Society expressed support for the principle while raising concerns about case-mix adjustment — clinics treating more severely ill or treatment-resistant patients may show lower aggregate response rates despite providing high-quality care.
Public comment is open through August. A final rule is expected by year-end with implementation phased over 2026 and 2027. Private payers historically follow Medicare rate-setting decisions, so the proposal is being closely watched across the sector.
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Reporting based on coverage from CMS. This article is editorial summary intended for general information; it is not medical advice.