Create HCPCS codes for tech-based treatments
Recommendation
The Centers for Medicare and Medicaid Services (CMS) should fast-track the creation of Healthcare Common Procedure Coding System (HCPCS) codes for Food and Drug Administration (FDA)-approved technology-based treatments, digital interventions, and biomarker-based interventions. The National Institutes of Health (NIH) should develop a means to evaluate behavior modification apps for effectiveness.[1]
Background/summary
Digital tools such as software-driven applications, wearable devices, as well as detective or biomarker-based interventions can be leveraged to identify needs, assess care, and deploy substance use disorder (SUD) treatments.[1][2][3] An example of such a technology are “devices that transmit findings from smartphones directly into the medical record.”[1]
No independent regulatory agency, such as the Food and Drug Administration (FDA), is charged with consistently examining all mental health and substance use technology or applications. While the FDA may review certain apps (e.g., those that may require a prescription or function as a medical device), the agency uses its enforcement discretion with respect to many other mental health and substance use applications. The Federal Trade Commission (FTC) can also investigate potential false claims that an app developer may make.
While Congress should designate a regulatory body to oversee these emerging technologies, patients and providers would benefit from foundational research on how best to evaluate behavior modification apps to ensure they are effective. This information would support the development of a new regulatory framework for this technology, including how the FDA currently may review mobile health applications for the treatment of mental health and substance use disorders.
Once a technology or product is deemed safe and effective, it is critical for payers, including Medicare and Medicaid, to ensure the timely creation of reimbursement codes so that consumers can access emerging technology that helps meet their needs.[2]
citations
1. Presidential Commision. The President’s Commission On Combating Drug Addiction and the Opioid Crisis. (Commission Recommendations). Last Updated November 1, 2017.
2. Powell, Adam PhD., Patrick J. Kennedy., Garry Carneal, JD., Steve Daviss, MD, and Henry Harbin, MD. New Technologies for Improving Behavioral Health. Kennedy Forum. Issue Brief. Last Updated 2015.
3. Villa, Lauren. Top 6 Smartphone Addiction Recovery Apps. American Addiction Centers. Last Updated June 30, 2023.