Medicare’s final physician fee schedule for 2027 does two things in opposite directions. It cuts the base rate every billing clinician is paid from, and it raises the value assigned to psychiatric collaborative care by more than it had proposed to in July. The revaluation is the larger number by a wide margin. The question it raises is not whether behavioral health gained, but whose claim the gain arrives on.
CMS put the rule, CMS-1848-F, on public display November 4. It is scheduled for Federal Register publication November 9 and applies to services furnished on or after January 1, 2027.
The revaluation, and the arithmetic
The collaborative care model is billed through four codes, and all four went up. CMS proposed in July to value them on a blended level 3 and 4 office visit benchmark. Commenters argued that was still inadequate and asked for a level 4 and 5 blend, with a stated fallback of no less than a level 4 valuation. CMS wrote, “We were persuaded by their comments,” and finalized on the level 4 benchmark, which is the fallback, not the request.
| Code | CY 2026 work RVU | Final CY 2027 | Change |
|---|---|---|---|
| 99492, initial month | 1.88 | 3.25 | +72.9% |
| 99493, subsequent month | 2.05 | 2.56 | +24.9% |
| 99494, add-on per 30 min | 0.82 | 1.28 | +56.1% |
| G2214, first 30 min | 0.77 | 1.28 | +66.2% |
Source: Addendum B to CMS-1832-F for CY 2026 and to CMS-1848-F, dated November 5, 2026, for CY 2027. The two APCM behavioral add-on codes, G0568 and G0569, were finalized at 3.25 and 2.56 to match.
Work relative value units are only part of a payment. The practice-expense side moved too: CMS finalized a higher clinical labor rate for the behavioral health care manager, from $0.57 to $0.70 a minute, replacing the genetic counselor benchmark used when the codes were created in 2017. For 99492, non-facility practice-expense RVUs went from 2.78 to 4.06.
Running the final total RVUs against the final conversion factors, at national rates before any geographic or practice-specific adjustment, the initial month of collaborative care goes from about $160 to about $247, up 53.9 percent. The subsequent month goes from about $145 to about $182, up 25.4 percent. A twelve-month episode billed as one initial month plus eleven subsequent months goes from about $1,755 to about $2,246, a gain of about 28 percent (Behavioral Wire arithmetic on CMS’s final relative values and conversion factors). That is revenue for a full course of care at national rates, not margin, and it assumes every month is billed; the rule documents no typical episode length.
Against that, the conversion factor itself falls. The qualifying rate goes from $33.5675 to $32.95, down 1.83 percent. The non-qualifying rate goes from $33.4009 to $32.63, down 2.31 percent. The cause is the expiry of the one-year 2.50 percent increase that applied in 2026, partly recovered by the statutory update (0.75 percent qualifying, 0.25 percent non-qualifying) and trimmed by a 0.12 percent budget-neutrality reduction. The cut is deeper than July’s proposal for one reason: the proposed rule carried a positive 0.53 percent budget-neutrality adjustment, and the non-qualifying factor was proposed at $32.84.
Who reports the claim
Here the rule is precise, and the precision is the story. A few commenters asked CMS to remove the requirements that limit who can bill for integrated care, so that psychologists, social workers, nurses and other behavioral health professionals could bill and be reimbursed directly for integrated care services they provide. CMS did not make that change and restated the existing structure from its 2017 rule: collaborative care services are reported by the treating physician or other qualified health care professional, and include that practitioner’s own services, the behavioral health care manager’s services furnished incident to them, and the psychiatric consultant’s consultative service, also furnished incident to them.
So the claim is the treating practitioner’s. The psychiatric consultant’s case review, treatment recommendations and weekly caseload consultation sit inside that claim, not beside it. Collaborative care is an integration model built around primary care, as CMS’s own framing of the section describes, though nothing in the codes restricts the treating practitioner to primary care. What the structure does establish is that a 28 percent increase in the modeled value of a collaborative care episode is an increase in what the billing practice collects, and the psychiatrist’s share of it is a matter of whatever contract sits between the psychiatrist and that practice.
That is a different economic event from a payment increase for psychiatry.
Psychiatry’s own line
CMS publishes an estimate of how the 2027 relative-value changes land by specialty. It measures work, practice-expense and malpractice RVU changes only. CMS’s own explanation of the table confirms that its combined-impact column covers those three and not the conversion-factor update, so the published figures are the picture before the rate cut.
| Specialty | CMS: impact of RVU changes | BW estimate, after the 2.31% cut | Allowed charges |
|---|---|---|---|
| Psychiatry | +2% | about -0.4% | $893M |
| Clinical psychologist | +9% | about +6.5% | $784M |
| Clinical social worker | +11% | about +8.4% | $979M |
| Family practice | +1% | about -1.3% | $6,065M |
| All specialties | 0% | about -2.3% | $95,014M |
The left column is CMS’s. The second is Behavioral Wire’s, combining CMS’s percentage with the non-qualifying conversion-factor change; CMS publishes no combined figure that includes the rate cut, and these two columns should not be read as one series. CMS rounds to whole percents, so the second column is good to about half a point. On the qualifying conversion factor the same arithmetic puts psychiatry at roughly +0.1 percent instead of -0.4.
Either way, psychiatry lands close to flat. The clinical social worker and clinical psychologist gain materially, mostly not from collaborative care: their gains come from practice-expense changes and from CY 2027 being the fourth and final year of a 19.1 percent upward adjustment to time-based psychotherapy work RVUs that CMS finalized in its CY 2024 rule. Psychotherapy payment rises about 9 to 10 percent for the 45 and 60 minute codes (Behavioral Wire arithmetic at national rates), the completion of a 2024 decision arriving on schedule, not a new one.
Psychiatry’s 2 percent is work RVUs up 1 percent and practice-expense RVUs up 1 percent, and it includes the psychotherapy phase-in described above; CMS does not break collaborative care out of it. The 72.9 percent rise applies to the treating practitioner’s claim, so unless a psychiatrist is that practitioner, it is a different measure of a different claim.
What CMS left alone
Commenters asked CMS to raise the general behavioral health integration codes, 99484 and G0323, alongside collaborative care, arguing that the general codes should stay model-agnostic to support diverse evidence-based care models and a broader workforce. CMS thanked them, welcomed further feedback, and said it may consider valuation updates in future rulemaking. The numbers show the result: 99484 pays about $57.45 in 2026 and about $57.43 in 2027, which is flat to two cents. Its work value stayed at 0.93; a 0.04 rise in practice-expense relative value units, taking the total from 1.72 to 1.76, offsets the conversion-factor cut.
So the rule rewards one specific model and leaves behavioral-health integration generally where it was. CMS gives a level 4 office visit benchmark as its rationale and states no preference for collaborative care over other integration models; the asymmetry is in the outcome. A practice choosing between a registry-based collaborative care program and a looser integration arrangement now faces a wider payment gap than in 2026.
Two provisions sit outside this comparison. The mental health telehealth in-person requirement stays delayed until January 1, 2028 under section 6209(d) of the Consolidated Appropriations Act, 2026, which covers all of 2027. And the 2.5 percent efficiency adjustment CMS finalized for CY 2026 is not reapplied in 2027; its next application is in CY 2029 rulemaking, with time-based codes, telehealth-list services and new CY 2026 codes exempt.
The reaction, and what it establishes
The American Psychiatric Association issued a release on November 6 applauding the increases and saying it directly advocated for them. APA’s September 14 comment letter is public, and it asked for the figures CMS describes: a level 4 and 5 blend of 3.67, 2.99 and 1.50 work RVUs, with a floor at a level 4 valuation of 3.25, 2.56 and 1.28.
What the rule itself establishes is narrower. CMS attributes the level 4 and 5 recommendation to “interested parties” and “commenters” and names none of them. It logged approximately 43,100 timely pieces of correspondence on the proposed rule. In the public-inspection version of the rule, 2,468 pages, the American Psychiatric Association is named only as a steward of quality measures, never as a commenter. Other commenters may have made the same request; the rule does not say. The final 99494 value of 1.28 is exactly half of the final 99493 value of 2.56, the 50 percent relationship the proposal attributed to the interested parties, applied to the level 4 floor instead of the 1.50 requested. Advocacy and outcome are both visible in the record, and the figures match; the causal link between them is not something the rule documents.
What the rule moved
The reimbursement question this rule answers is not whether Medicare is paying more for behavioral health. For psychiatry as a specialty, on CMS’s own estimates and before any practice-level variation, it is paying about the same. What changed is the price of one specific delivery structure: a registry-based program in which a treating practitioner bills, a care manager carries the follow-up, and a psychiatrist consults inside that claim. That structure got roughly 28 percent more valuable over a modeled year-long episode, its care-manager labor got repriced, and the looser alternative to it did not move at all.
The consequences below are Behavioral Wire’s reading of that structure, not statements in the rule, and they concern revenue, not margin. For a primary care group weighing whether to stand up a collaborative care program, that is a better revenue case in 2027 than in 2026. For a behavioral-health integration vendor paid as a share of the practice’s collaborative care revenue, the pool it draws from grew. For a psychiatrist supplying consultative hours into one of those programs, the money moved closer, but it did not move onto the psychiatrist’s own claim, and nothing in this rule changes who submits it.