Medicare 2027 Fee Schedule and Telehealth: A Therapist's Guide

Status on October 31, 2026: the 2027 Medicare physician fee schedule is still a proposed rule. CMS released it on July 14, 2026, and comments closed September 14 (Federal Register). The final rule usually comes out in early November. We'll update this guide when it does; until then, every 2027 figure below is a proposal.

The telehealth dates are different. Congress set those in law in February 2026, so they don't depend on the final rule.

The short version

• Psychotherapy pays a bit more under the proposal. The timed psychotherapy codes get the last step of a 4-year increase. CMS estimates total Medicare payments rise 11% for clinical psychologists and 12% for clinical social workers, before a lower conversion factor takes back about 1.7 points.
• The conversion factor drops. A one-time 2.5% increase for 2026 ends, so the proposed 2027 factor is lower.
• Telehealth from home stays open through 2027. The in-person visit requirement for mental health telehealth now starts with services on January 1, 2028.
• Nothing new is proposed specifically for marriage and family therapists or mental health counselors. They're still paid 75% of the psychologist amount.

The conversion factor

The conversion factor turns each service's relative value units into dollars. The proposed 2027 factors, from the rule's tables:

The drop comes from a 2.5% increase that the 2025 budget law (Pub. L. 119-21, section 71202) applied only to services from January 1 to December 31, 2026. CMS starts 2027 from the 2026 factor without it, then adds the regular update of 0.25% (0.75% for qualifying model participants) and a small budget-neutrality adjustment.

Psychotherapy codes

The last step of a 4-year increase. In 2024, CMS began raising the work value of timed psychotherapy codes by 19.1% in four steps. The proposal calls 2027 "the fourth year." Proposed work values from the rule:

Work value is one of three parts of a code's payment, so these percentages aren't the change in what Medicare pays. The intake code 90791 isn't timed and isn't part of the increase.

The efficiency cut doesn't apply. CMS finalized a 2.5% cut to work values for many services in 2026, and it exempted timed codes, services on the telehealth list and new codes. The psychotherapy codes are timed.

Practice expense changes. CMS proposes to change how it spreads overhead costs across services, phase out an older index over two years, and cap how much a service's practice expense value can move in one year at 5%. In the rule's words, these changes "would have a significant positive impact on clinical psychologists and clinical social workers."

Estimated effect by specialty. CMS's impact table estimates the change in total allowed charges for each specialty, leaving out the conversion factor:

The lower conversion factor (-1.68% for most clinicians) isn't in those figures. Dollar amounts for each code come from CMS's payment files, which we'll add when the final rule is out. Figures you see elsewhere before then are estimates.

Medicare telehealth for mental health

The Consolidated Appropriations Act, 2026, signed February 3, 2026, set the current dates in section 6209:

These flexibilities lapsed twice: from October 1 to November 12, 2025, during the government shutdown, and again from January 31 to February 2, 2026. Both were restored by later laws.

What happens in 2028 under current law. The client's home stays a permanent place to receive mental health telehealth. What returns is the in-person rule in 42 CFR 410.78: an in-person visit within 6 months before the first telehealth service, then at least once every 12 months, unless you and the client agree the risks of an in-person visit outweigh the benefits and you document why. Congress has moved this date several times, so watch for another change.

What the 2027 proposal adds:

• Audio-only after 2027. CMS proposes allowing audio-only for clients at home when you can do video but the client can't use it or doesn't consent to it, with a modifier on the claim.
• New claim modifiers. The law requires modifiers by January 1, 2027 for telehealth delivered through a contracted virtual platform and for telehealth billed incident to another clinician. CMS proposes BB and BC. They don't change payment.
• No new psychotherapy codes on the telehealth list. CMS says it received no requests to add or remove services for 2027.
• Supervision. Virtual direct supervision through real-time audio and video is already permanent for most services, from the 2026 final rule.

Marriage and family therapists and mental health counselors

MFTs and MHCs have been able to bill Medicare since January 1, 2024. Under 42 CFR 414.53, Medicare pays clinical social workers, MFTs and MHCs "at 75 percent of the amount determined for clinical psychologist services." We found nothing in the 2027 proposal aimed specifically at MFTs or MHCs.

If you see Medicare clients privately

Private-pay therapists who see Medicare clients usually choose one of two paths:

1. Enroll and bill Medicare for those clients, at Medicare's rates.
2. Opt out. Psychologists, clinical social workers, MFTs and mental health counselors can file an opt-out affidavit with their Medicare contractor for a 2-year period that renews unless canceled (42 CFR 405.400 to 405.410). Each Medicare client then signs a private contract agreeing not to submit a claim to Medicare, and you set your own fee.

Charging a Medicare client privately without opting out isn't a third path: federal law (42 USC 1395w-4(g)(4)) requires clinicians who haven't opted out to submit the claim for the client, at no charge. Superbills don't work for Medicare clients the way they do for commercial plans, because Medicare doesn't pay claims for services from opted-out clinicians. If you're not sure which path fits, ask your Medicare contractor or a billing consultant before you see the client.

Medicare is also a common reference point when setting private-pay fees. Our guide to what private-pay therapists charge compares the two, and our reimbursement calculator shows the 2026 Medicare amount in each state.

Sources: Federal Register, CY 2027 PFS proposed rule (91 FR 43842) and its public inspection copy (Tables A-D9, D-B1, D-B2 and D-B5) · CY 2026 PFS final rule (90 FR 49266) · Pub. L. 119-21 · Pub. L. 119-37 · Pub. L. 119-75 · 42 CFR 410.78 · 42 CFR 414.53 · HFMA summary of the proposed rule

Read on October 31, 2026. The 2027 figures are proposals and may change in the final rule. This is general information, not billing or legal advice.