Digital Mental Health Treatment (DMHT) is the latest shiny “innovation” being pushed into behavioral health. CMS created the codes. A handful of FDA-authorized products exist. Vendors are knocking on doors to promote the latest, greatest thing for DMHT. And practices are wondering if they should jump in.

Here’s the reality:
DMHT in the rulebook and DMHT in a real practice are two very different things.

Too many organizations are looking at the opportunity but skipping the review of limitations, the clinical requirements, and the operational lift. And that’s exactly where organizations get themselves into trouble.

Let’s talk about what DMHT truly is and what it…is not.

DMHT is designed as a clinical extension, not a grab-and-go service line

The entire DMHT benefit was built for FDA-authorized digital therapeutics tools that deliver a validated mental health treatment and integrate directly into an existing treatment plan.

Meaning:

• The patient already has a diagnosed mental health condition
• The clinician prescribes or orders the product
• The device treats a specific condition and nothing outside its clearance
• The product is used with therapy, not instead of therapy

Most practices don’t realize they have to furnish the product themselves

This is the part that catches almost everyone off guard.

To bill DMHT, the billing practitioner must:

• Furnish the product
• Absorb the cost upfront
• Provide it as a supply under their plan of care

That eliminates:

• Anything a patient downloads themselves
• Any subscription paid directly by the patient
• Any vendor model where the company “owns” the relationship

This mismatch between CMS requirements and many vendor sales models explains why DMHT claims are so low right now. Practices simply can’t bill for a model they don’t control.

Let’s talk about apps because this is where confusion lives

A huge portion of the digital mental health market is built on apps and SaaS platforms that support mood, anxiety, CBT, or symptom management. They can be great tools. They can genuinely help patients.

But they are not necessarily considered DMHT based on CMS’ outline.

Here’s some reasons why:

• They’re not FDA-authorized medical devices
• They’re not supplied by the clinician
• They don’t meet the therapeutic validation requirements CMS built into the benefit
• They were designed for consumers not for Medicare’s clinical framework

I’d venture to guess that almost nothing sold as a “digital mental health solution” qualifies for DMHT billing. That’s just me stating my opinion!

Yes, CMS is exploring future options for non-device tools. But that’s future-state. Today, DMHT is a narrow, highly regulated lane.

The monthly workload is not a light lift

To bill ongoing management each month, a practice must:

• Review patient-specific data from the device
• Interpret it clinically
• Communicate with the patient
• Document the interaction
• Tie everything back to the treatment plan

This is real clinical work.
It’s not passive monitoring.
It requires structure, workflows, and provider time.

If your organization struggles with CCM, PCM, BHI, or care management models, DMHT will feel overwhelming. The infrastructure has to exist first.

So, is DMHT worth pursuing?

Yes, but only when it’s approached in the right way.

DMHT makes sense when:

• Your clinical model is already structured and measurable
• You have systems for follow-up, monitoring, and documentation
• You have a compliance lens
• You understand the difference between “device” and “app”
• You have the staff and capacity for monthly engagement
• You’re willing to invest in devices the practice must furnish

In other words:
DMHT belongs in an intentional, compliant practice not a reactive one trying to chase revenue.

Where organizations should focus right now…

This is not the time to run toward every digital tool being marketed as “Medicare billable.”
It’s the time to understand:

• What DMHT truly requires
• Which products actually qualify
• What it costs to lift this operationally
• Whether your clinical workflows can support it

Digital mental health is absolutely growing.
Patients want this.
CMS is inching forward.
But the guardrails are still narrow and if organizations ignore them, it will quickly become a compliance headache disguised as innovation.

Bottom Line

DMHT is promising.
It’s forward-looking.
It’s needed.

But it is not the wide-open digital playground people imagine.
The organizations that succeed will be the ones who resist the hype, understand the rules, and build a model that fits the actual operational realities of behavioral health.

Digital doesn’t mean simple.
And in this case, it definitely doesn’t mean automatic revenue.