August 4, 2026
The Deprescribing Bottleneck Just Moved
By Jered Yalung, PharmD, CDP
There has never been a lack of evidence supporting deprescribing. We have known for years which medications quietly accumulate in older adults, the harm use of potentially inappropriate medications can create, and what they cost.
Excessive anticholinergic burden can be misinterpreted as early dementia and sedative/hypnotic use that can result in a hip fracture. The Beers guidelines have been clear for a long time. Until recently, we lacked a mechanism to receive payment for safe deprescribing interventions. In May, the Centers for Medicare & Medicaid Services (CMS) clarified that supervised medication deprescribing is billable under existing care management codes. A clarification that the work many of us have already been doing without a clear billing path (tapering plans, between-visit symptom monitoring, caregiver communication, team coordination) can be covered under Chronic Care Management, Principal Care Management, the behavioral health integration codes, and transitional care management when all criteria are met.
Table 1. Care management codes that can cover deprescribing
| Code family | CPT codes | When it applies |
|---|---|---|
| Chronic Care Management (CCM) | 99437, 99439, 99487, 99489, 99490, 99491 | Two or more chronic conditions lasting 12+ months. |
| Principal Care Management (PCM) | 99424, 99425, 99426, 99427 | One high-risk condition needing frequent medication changes. |
| Behavioral Health Integration, general (BHI) | 99484 | A behavioral health condition managed with primary care. |
| Psychiatric Collaborative Care (CoCM) | 99492, 99493, 99494 | Collaborative behavioral health care, such as SSRI tapers. |
| Transitional Care Management (TCM) | 99495, 99496 | The 30 days after a hospital discharge. |
Source: CMS, Billing for Supervised Medication Deprescribing Services under the PFS, May 2026. cms.gov/medicare/payment/fee-schedules/physician/care-management
CMS also confirmed that a clinical pharmacist’s time incident to the physician’s service is billable, and went a step further, explicitly encouraging team-based models that use pharmacists for medication management and deprescribing.
That is a meaningful shift. The honest constraint for years was that no one could bill for the time. Now there is an answer. Chronic Care Management and Principal Care Management codes cover longitudinal management: monitoring patient-reported symptoms between visits, catching discontinuation syndrome before it becomes a relapse, and adjusting the rate of drug dose tapering based on how the patient is actually responding. The billable activity is the monitoring. Signs and symptoms consistent with falls, new daytime drowsiness, missed doses, and new episodes of confusion following the addition of a new prescription are important cues for medication management.
These signs and symptoms may be first recognized by whoever is with the patient: the home care aide or family member at home, the medication technician in assisted living, the floor nurse in the skilled nursing facility (SNF), yet they may lack a structured process of communicating their observations to the prescriber.
The process can be represented by a three-legged stool comprised of the physician/prescriber, the pharmacist, and structured communication from caregivers in the patient’s living environment.
However, deprescribing can also result in patient harm. Lowering or stopping a long-standing medication can produce withdrawal or discontinuation symptoms that feel, to a worried patient, exactly like the original problem returning. The framework anticipates this, which is why contingency planning and counseling patients on when to seek care are named among the billable activities. Thus, it is important to communicate directly with the patient, their family, and caregivers about the process, how deprescribing will occur, over what time period, and the symptoms to be aware of. Failure to invest in patient and family conversation before starting the deprescribing process can result in failed medication tapering attempts.
This is where the observation leg earns its place. Someone who sees the patient regularly can reinforce the plan, differentiate an expected discontinuation symptom from a genuine relapse, and flag the difference before the family gives up. The mechanics are simple. Home care is already in the house several times a week. A standardized symptom check tied to the taper plan, routed to the supervising practitioner, turns what a caregiver notices into the documented monitoring these codes require. The observation was always there. It just never had anywhere to go.
Medical directors play an important role in orchestrating deprescribing of potentially harmful or unnecessary medications as part of the collaborative team's coordinated effort for their patients.
None of this works as a solo effort. The evidence was never the barrier, and now the billing is not either, which leaves the part that has always been hardest: connecting the prescriber, the pharmacist, and the people who see the patient day to day. When those roles are linked, the taper is planned deliberately, discontinuation symptoms are recognized early rather than mistaken for relapse, and the family understands that a few difficult days may be part of the plan instead of a reason to abandon it. When any one of the components is missing, the same taper stalls, the patient is restarted on a medication they were meant to stop, and the team concludes that deprescribing is too risky to attempt. The safeguard against both patient harm and failed deprescribing is less a matter of a better protocol than of the collaboration itself.
Jered Yalung is owner of Options Home Care, a pharmacist-owned home care agency in Greensboro, NC. Learn more at www.jeredyalung.com.