Among the eight internal medicine specialties, psychosomatic medicine is hit hardest by this revision.
A new proviso 13 to the outpatient and home psychotherapy fee reduces the fee to 60% of standard points at institutions that do not meet the facility criteria. For clinics without a designated mental health physician, or that otherwise fall short, this reaches the core of outpatient revenue.
1. What changed
| Item | Change | Old → New | Impact |
|---|---|---|---|
| Initial consultation tiers strengthened | Increase for 60+ minute initial consultations; new 30-to-60-minute tier | 60+ min (designated physician) 600 → 650 pts; 30–60 min 550 pts (new); home 60+ min 640 → 650 pts (verify) | Medium |
| Proviso 13 reduction for non-designated physicians (new) | Where the facility criteria (participation in emergency psychiatric care systems, or physicians with sufficient experience) are not met, bill at 60% of standard points | e.g. 650 → 390 pts; 550 → 330 pts (verify) | High |
| Billing restrictions when proviso 13 applies | Cannot be billed with three or more antidepressants or three or more antipsychotics. Cannot be billed alongside the psychological support add-on (proviso 9) | — | High |
| Psychotropic prescribing rationalization | Stricter counting of drug classes for multi-drug and long-term prescriptions (generic-name basis) | — (verify) | Medium |
The National Federation of Health Insurance Doctors' Associations submitted a request in May 2026 asking for proviso 13 to be withdrawn. Watch for follow-up Q&A and implementation notices.
2. What it means for the practice
The order of priority is clear.
(1) Assess eligibility under proviso 13 first. The criteria are reported as at least 20 years in psychiatric care as of 31 May 2026, or administrative service in the past year (Medical Treatment and Supervision Act examinations, public health center or child guidance center appointments) (verify). Confirm whether your physicians qualify, and file promptly if they do.
(2) If not, quantify the loss. For return visits under 30 minutes, reported levels are 315 points (designated), 290 points (non-designated meeting criteria), and 174 points (non-designated not meeting criteria). At 200 psychotherapy sessions a month, meeting versus not meeting the criteria is a difference of roughly 23,000 points — 230,000 yen a month, about 2.8 million yen a year.
(3) Work out how to compensate. The new 30-to-60-minute initial consultation tier means accurate recording of consultation time now feeds directly into revenue. Precise records of consultation time and content are also essential for audit readiness.
(4) Rationalize prescriptions. Under the reduction, patients on three or more antidepressants or antipsychotics cannot be billed at all. A dose-reduction plan needs to be part of the care plan.
This is also an opportunity to redesign how certified public psychologists are deployed — noting that under proviso 13, the psychological support add-on cannot be billed concurrently.
3. Practical checklist
- Have you confirmed whether your physicians meet the proviso 13 criteria, and filed if so?
- Have you quantified the monthly and annual loss if you do not?
- Is consultation time (under/over 30 minutes, 60+ minutes) recorded in the chart?
- Have you identified patients on three or more antidepressants or antipsychotics and planned dose reduction?
- Are the exclusions against the psychological support add-on reflected in the billing system?
4. Where an AI-native EMR fits — feature by feature
In 2026 this specialty is paid not only for what was done but for how long it took and what was prescribed. Here is how Pottech's AI-native EMR helps, feature by feature.
Feature 1: Charting and orders — capture consultation time and content
AI generates SOAP notes from the consultation audio, and set orders enter tests and prescriptions in one action.
With a 30-to-60-minute tier now in place, the record of consultation time directly determines the fee. Capturing both time and content accurately while staying present in a psychotherapy session is heavy work by hand or keyboard. Generating the note from audio keeps the time-tier record inside the flow of the consultation — which matters here more than in most specialties, and doubles as audit readiness.
Feature 2: Billing and claims management — flag unbillable prescriptions in advance
The automatic billing engine checks bundling, mutual exclusions, and frequency limits.
Under proviso 13, three or more antidepressants or antipsychotics make the psychotherapy fee unbillable outright. With drug-class counting now stricter and generic-name based, knowing at the moment of prescribing that "this combination cannot be billed" is far more practical than discovering it during month-end claim review. The psychological support add-on exclusion works the same way.
Feature 3: Management analytics dashboard — quantify the reduction
Visit volumes, revenue per patient, and monthly trends are aggregated and visualized automatically.
The impact of proviso 13 should be understood as sessions billed × the point difference, not as a vague sense of decline. The mix of time tiers, the share of patients on multi-drug regimens, and psychological support add-on billing, tracked monthly, support both the filing decision and progress on dose reduction.
Also review what applies to every specialty
Consultation fees, the inflation add-on, the wage increase evaluation fee, and the electronic clinical information coordination add-on are collected in "what applies to every specialty."
Sources (principal)
- MHLW, "About the FY2026 Fee Schedule Revision" https://www.mhlw.go.jp/stf/newpage_67729.html
- Seishinka Youmuin, "Key points of the outpatient and home psychotherapy revision" https://seishinkayoumuin.com/psychotherapy26/
- National Federation of Health Insurance Doctors' Associations, "Request for withdrawal of proviso 13" https://hodanren.doc-net.or.jp/info/declaration/2026-05-25/
- Tokyo Association of Medical Practitioners, "FY2026 revision: Chuikyo report (excerpt)" https://www.hokeni.org/docs/2026021200012/