May 26, 2026
On May 4, CMS released its FAQs on Billing for Supervised Medication Deprescribing Services Under Care Management Codes on the Medicare Physician Fee Schedule (PFS): https://www.cms.gov/files/document/billing-supervised-medication-deprescribing-services-under-pfs.pdf
CMS has taken a clear step toward advancing team-based care by encouraging these models that leverage the expertise of clinical pharmacists in medication management and deprescribing. In its FAQ guidance, CMS directly addressed the role of clinical pharmacists in deprescribing services, affirming:
"Pharmacists can provide services incident to the professional services of a physician or non-physician practitioner just as other clinical staff may do… These 'incident to' services can count as billable time… CMS encourages team-based care models that leverage the expertise of clinical pharmacists in medication management and deprescribing."
This clarification not only validates the contributions of clinical pharmacists but also establishes a payment pathway for comprehensive medication management services provided by clinical pharmacists. Pharmacists can receive reimbursement for clinical services delivered under "incident-to" billing using CPT codes 99439, 99487, 99489, 99490, 99426, and 99427.
Practitioners can also work with their MAC to address additional questions regarding criteria for billing deprescribing activities under various care management and other PFS services. The PFS Care Management webpage provides additional resources and billing guidance: https://www.cms.gov/medicare/payment/fee schedules/physician/care-management.