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Editor’s Note: This article has been reviewed by our Premier Policy Partner, Meadows Mental Health Policy Institute.
In the wake of funding uncertainty and renewed attention to technology-enabled care, behavioral health policy is at an inflection point. The choices made now will determine who stays connected to care and how innovation is stewarded in service of public good rather than convenience alone.
Those dynamics were already top of mind across the field, including conversations at the 2025 Behavioral Health Tech Conference (BHT2025) in November, where more than 2,300 policymakers, providers, payers, innovators, and advocates reflected on the policy forces influencing access, delivery, and equity.
Telehealth utilization has declined across much of health care, yet mental health and addiction treatment remain clear exceptions. Telehealth use for behavioral health has stayed consistently high even as other services return to in-person norms.
That persistence tells us something important. For many people seeking mental health and substance use treatment, telebehavioral health is the most practical way to access care, particularly in communities facing workforce shortages, transportation barriers, or stigma around treatment.
Recent congressional action extending Medicare coverage for telemental health services at federally qualified health centers and rural health centers reflect this reality. While these extensions preserve access in the near term, they also underscore the need for a clearer, more durable policy framework that moves telebehavioral health beyond temporary authorization toward long-term quality, accountability, and integration.
Sustaining telebehavioral health will require more than extending payment policies. Across the policy discussions, a clear need emerged for greater attention to continuity of care and clinical standards. Policymakers now have an opportunity to treat telehealth as an integrated part of how behavioral health is delivered.
Proposed work requirements for Medicaid expansion populations raise the risk of coverage loss for millions, even when exemptions exist for individuals with substance use disorders or serious mental health conditions.
Speaking at BHT2025, Mary Giliberti, chief public policy officer at Mental Health America, emphasized a reality advocates know well: People most often lose Medicaid not because they are ineligible, but because systems fail to recognize eligibility in time. Fragmented data, complex documentation, and uneven outreach create churn that interrupts treatment and undermines trust.
As Giliberti described, the greatest risk to Medicaid coverage is not statutory eligibility, but administrative churn, particularly during redeterminations, when gaps in data, documentation, and outreach cause eligible individuals to lose coverage. Addressing that risk requires action by state and administering agencies, including investing in interoperable eligibility systems that communicate with one another, training frontline workers to navigate behavioral health exemptions, and partnering with community organizations that can support enrollment and retention.
The Centers for Medicare & Medicaid Services’ Rural Health Transformation Fund offers states flexible resources to support workforce development, integrated care, and telehealth in rural areas. That flexibility matters because rural communities are not uniform. Tribal nations, frontier regions, and agricultural areas face distinct needs and strengths.
At BHT2025, Dr. Miriam Delphin-Rittmon, former assistant secretary for mental health and substance use at SAMHSA and now vice president of the Center for Training, Technical Assistance and Consultation at Advocates for Human Potential, highlighted the potential of the $50 million fund.
“We submitted a few [proposals] at Advocates for Human Potential to put forward some innovative ideas. One of my favorites is the idea around building internal capacity. Particularly in tribal or other rural communities, working within communities to be able to build capacity to help with things like health navigation, connecting people to care.”
The Rural Health Transformation Fund reflects a broader recognition that durable rural solutions depend on local design and implementation. Speakers at BHT2025 reinforced that pairing flexibility with accountability gives states room to strengthen rural behavioral health systems without defaulting to one-size-fits-all models.
Artificial intelligence is already influencing behavioral health, yet policy conversations have struggled to keep pace. Al Guida, president and CEO of Guide Consulting Services, noted that one challenge is confusion between consumer-facing tools and the broader range of AI tools used to support clinicians in back-end operations.
Consumer-facing tools, such as chatbots that interact directly with patients, raise distinct safety, privacy, and clinical oversight concerns. By contrast, operational and clinical AI applications, including tools for documentation, scheduling, intake, and care coordination, primarily support providers and workflows and generally carry lower risk while offering significant potential value to the workforce. When these distinctions are lost, policy risks focusing regulatory attention on consumer-facing use cases while underinvesting in lower-risk, high-value applications that could meaningfully improve care delivery and reduce clinician burden.
The stakes here are not theoretical. Behavioral health has already experienced what happens when federal technology policy advances without intentional inclusion of behavioral health. Under the HITECH Act, passed in 2009 as part of broader health system modernization efforts, federal incentives accelerated adoption of electronic health records across hospitals and physician practices, while largely excluding behavioral health providers from meaningful use payments. The result was not simply slower modernization. It was a lasting structural gap in interoperability and technology capacity that the field is still working to close.
There is a real risk that AI policy, particularly if reimbursement proceeds use case by use case, could repeat that result unless behavioral health is explicitly included in federal payment and incentive frameworks.
The current policy environment feels unsettled. How Medicaid work requirements are implemented at the state level. Whether rural investments like the Rural Health Transformation Fund translate into durable, locally grounded capacity. How emerging AI tools are incorporated into federal payment and incentive structures. These decisions will shape access, delivery, and equity for years to come.
At BHT2025, speakers emphasized that what will determine their impact is not any single decision, but how effectively stakeholders move together. Progress in behavioral health rarely comes from singular policy wins. It emerges when policymakers, states, providers, payers, and technology partners coordinate around implementation and stay aligned on how decisions land in real systems and real lives.
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