On May 4, 2026, the U.S. Department of Health and Human Services (HHS) introduced the MAHA Action Plan under the broader Make America Healthy Again (MAHA) initiative. Its focus—reducing psychiatric overprescribing while supporting appropriate use and deprescribing when clinically indicated—has already sparked strong reactions across the industry.
And that’s understandable.
Any time policy begins to intersect more directly with clinical decision-making, it can feel personal. For many prescribers, this may raise a natural concern: Is this an external entity trying to tell clinicians how to practice medicine?
That tension deserves to be acknowledged—not dismissed.
From a value-based care and risk adjustment perspective, it’s important to level-set:
This isn’t entirely new. It’s a shift in emphasis.
The core principles—accurate diagnosis reporting, clear documentation of medical necessity, and thoughtful treatment planning—have always been foundational. What’s changing is the level of attention and scrutiny around how psychiatric conditions are treated and documented.
In this environment, specificity matters more than ever:
- Clearly defined diagnoses
- Accurate severity and status (active vs. historical)
- Transparent treatment plans—whether medication-based or not
The absence of a medication will no longer imply the absence of treatment. But it will require stronger documentation to tell that story.
Meeting Provider Concerns with Context: It’s reasonable for prescribers to feel cautious about broad policy initiatives entering the clinical space—especially when psychiatric care is nuanced, individualized, and often complex.
However, this effort is not being developed in isolation.
Multiple agencies are involved, including the Substance Abuse and Mental Health Services Administration (SAMHSA) and the Health Resources and Services Administration (HRSA), both of which bring deep clinical and community-based expertise to the conversation.
That involvement matters.
It suggests this is less about restriction—and more about informed, balanced guidance that considers both appropriate prescribing and continued access to care.
What’s Coming Next: Education, Data, and Collaboration: Rather than immediate mandates, much of the near-term activity is centered on education and input.
SAMHSA is expected to:
- Issue a report on prescribing trends to better understand where inappropriate prescribing may exist—while still emphasizing the importance of maintaining access
- Develop fact sheets for both prescribers and patients to support informed decision-making
Throughout June and July, SAMHSA will also host educational webinars aimed at:
- Increasing awareness of psychiatric medication side effects
- Providing guidance on deprescribing and tapering strategies
- Highlighting evidence-based non-medication treatment options
In parallel, SAMHSA and HRSA will co-host a webinar specifically for Federally Qualified Health Center (FQHC) providers, focusing on:
- Holistic, patient-centered care
- Integration of non-pharmacologic treatments
- Safe and appropriate deprescribing when clinically indicated
For organizations working with FQHCs, this is an important signal—targeted education is on the way.
A Seat at the Table: The Technical Expert Panel: In July, HHS will convene a Technical Expert Panel to help shape future clinical guidance on psychiatric medication use, including tapering and discontinuation practices.
This panel will include:
- Health professionals
- Patients and families
- Government representatives
- Professional societies
This is a meaningful opportunity.
Rather than a top-down directive, this process invites real-world input from those directly involved in patient care. It creates space for nuance, for specialty-specific considerations, and for the realities providers face every day.
Participation matters. Voices from the field will influence what comes next.
Documentation Still Anchors Everything: While policy direction evolves, one constant remains: documentation drives the narrative.
For coding, CDI, and compliance teams, this moment reinforces—not reinvents—the fundamentals:
- Medical necessity must be clear
- Treatment plans must be explicit
- Non-pharmacologic care must be documented, not assumed
- Diagnosis specificity must support the patient’s clinical picture
From a risk adjustment standpoint, the takeaway is straightforward:
Accurate, specific diagnosis reporting is more important than ever—but the rules themselves haven’t changed.
A More Balanced Framing: It’s easy to frame this initiative as a crackdown. But a more balanced interpretation may be more useful:
This is an attempt to better understand prescribing patterns, support providers with education, and ensure that treatment decisions—whether to prescribe, continue, or taper—are as intentional and informed as possible.
At the same time, the concern about access remains front and center. The inclusion of agencies like SAMHSA and HRSA, along with planned data analysis and education, suggests that maintaining access is part of the goal—not in conflict with it.
Final Thought: Stay Engaged, Not Reactive: This is still early.
Guidance is being developed. Education is being rolled out. Input is being gathered.
For providers, coders, and healthcare organizations, the most productive response isn’t resistance or urgency—it’s engagement.
Pay attention to the upcoming webinars.
Review the data as it becomes available.
Participate in discussions where possible.
And when opportunities arise—like the Technical Expert Panel—make your voice heard.
Because if this does represent a shift toward a deprescribing era, the people closest to patient care should help define what that looks like in practice.
Turning Insight into Action: As expectations around prescribing, documentation, and medical necessity continue to evolve, many organizations are recognizing the need to take a closer look at their current practices. Translating policy direction into day-to-day workflows—especially in behavioral health—requires clarity, consistency, and alignment across clinical and coding teams.
That’s where the right support can make a meaningful difference.
At BCA, we partner with healthcare organizations to operationalize these changes through targeted audits, education, and consulting. Whether it’s evaluating documentation for psychiatric conditions, strengthening risk adjustment accuracy, or aligning providers with emerging expectations around treatment planning, our approach is designed to be practical, collaborative, and grounded in real-world workflows.
If your organization is looking to move from awareness to action, BCA can help ensure your documentation tells the full clinical story—clearly, compliantly, and with confidence.
Schedule a consultation with one of our experts.