Digital mental health has long been positioned as a promising revolution in mental healthcare — it holds the potential to address the ongoing mental health access crisis by offering scalable, flexible, and innovative solutions. Yet, one of the most significant hurdles in realizing this promise lies in cost. For digital mental health to truly bridge the gap, we must ensure that cost is no longer a barrier for families. One powerful way to achieve this is by leveraging established Current Procedural Terminology (CPT) codes. These codes enable health plans to allocate funds from their medical budgets to cover digital mental health services, ensuring that individuals and families can access care without out-of-pocket burdens.
CMS Paves the Way: New CPT Codes for Digital Mental Health
In recent years, the Centers for Medicare & Medicaid Services (CMS) has made groundbreaking progress in this area by introducing two new sets of CPT codes:
Remote Therapeutic Monitoring (RTM) and Digital Mental Health Treatment (DMHT)
- Remote Therapeutic Monitoring: These codes focus on tracking patient health data outside of traditional clinical settings. Through RTM, providers can monitor mental health conditions remotely, using digital tools to track symptoms, adherence, or patient-reported outcomes related to the delivery of Cognitive Behavioral Therapy. This creates opportunities for ongoing, real-time engagement between patients and providers, making it easier to adjust treatments and improve outcomes.
- Digital Mental Health Treatment: This code set supports the delivery of clinically validated digital mental health interventions, such as structured therapy programs or behavioral health modules. These interventions are designed to be evidence-based, accessible on digital platforms, and effective for treating mental health conditions. By creating a reimbursement pathway, CMS is taking a large step in ensuring that health plans can support the use of these cutting-edge tools in mental health care.
Together, these CPT codes signify a major shift toward integrating digital health into the broader healthcare system, empowering providers, and reducing barriers for patients.
Continued Update to Digital Mental Health CPT Codes in 2024
As a part of their yearly cycle, it is customary for CMS to propose updates to the language of, and solicit public comments on, newer codes or to propose new codes all together. Public comments are then reviewed by CMS and codes are finalized for the next year. CMS released their Final Rule for 2025 in early November, providing some notable updates to the RTM and DMHT code sets described above:
· RTM codes remain contractor priced, meaning that plans and billing clinicians must establish and contract for a rate. While this is burdensome and may prohibit widespread adoption it allows CMS to gather information on the scope of devices that RTM is being billed for. Given the frequently changing nature of this field, and the widespread variability in RTM appropriate solutions and devices, this path is a reasonable one.
In response to comments in previous years regarding the relatively limiting language of Remote Therapeutic Monitoring in providing a digital intervention, CMS has introduced DMHT as a new code set in 2024. However, finalized language requires that in order to be reimbursable through DMHT codes, devices “must be cleared under section 510(k) of the FD&C Act or granted De Novo authorization by FDA and in each case must be classified under 21 CFR 882.5801 for mental or behavioral health treatment.” This narrow eligibility criteria will likely hurt adoption of solutions even if they have scientific evidence demonstrating safety and effectiveness through other means.
In sum, CMS continues to demonstrate an openness toward paving reimbursement pathways for digital mental health treatment in 2024. We’re beginning to see these new codes reflected on state fee schedules, even if rates are often not established, demonstrating that this openness is permeating into practice within each state. We’re committed to continuing to support and work with regulatory bodies to ensure that effective digital mental health solutions are accessible in the future.
How Mightier is Leveraging Coding to Increase Access
All of us at Mightier are excited and proud to partner with Medicaid plans to make Mightier accessible to some of the country’s most underserved children and families via these new coding mechanisms. The ability to partner with payers and bill through medical claims is a win for everyone involved—Medicaid plans, which often face challenges in providing access to 1:1 therapy for kids, can now offer the program as a highly accessible, effective, and cost-efficient solution. For our part, Mightier is able to bill for these services seamlessly within the familiar frameworks of Medicaid operations, ensuring a smooth integration. Most importantly, kids and families benefit tremendously by gaining access to Mightier in the comfort of their own homes, on their own terms, without the burden of out-of-pocket costs. Together, we are bridging gaps in care and transforming how mental health support reaches those who need it most.
Reach out to learn how your organization can increase access to pediatric mental health care by partnering with Mightier: https://www.mightier.com/health-plans/get-in-touch.
About the Expert
Dr. Alyssa Peechatka, PhD, is a Licensed Clinical Psychologist and the Director of Clinical Product at Mightier, where she works to develop and validate novel, accessible mental health solutions. She is passionate about bridging the gap between available mental health services and need, and believes that novel, scalable, and systematic approaches hold the key to better mental health and wellbeing outcomes. Dr. Peechatka received her PhD from Suffolk University and completed her internship and Post Doctoral Fellowship and McLean Hospital/Harvard Medical School.
