Health Law Daily Wrap Up, PRESCRIPTION DRUGS—CMS LETTERS: HHS agencies press for expanded use of non-drug mental health care and ongoing medication review, (May 7, 2026)

By WK Editorial Staff

A federal Dear Colleague letter urges clinicians to integrate non-pharmacological interventions, shared decision-making, and structured medication review into mental health treatment to ensure care remains individualized and evidence-based.

Federal health agencies issued a coordinated policy letter emphasizing that treatment planning for mental health conditions should include meaningful access to evidence-based non-pharmacological interventions, alongside appropriate use of psychiatric medications. The guidance stresses that effective care requires ongoing assessment of symptoms, evaluation of medication efficacy, and consideration of deprescribing when clinically appropriate (CMS Letter, May 4, 2026)).

The agencies acknowledge that psychiatric medications can play an important and, at times, essential role in treatment by reducing symptoms, improving functioning, preventing relapse, and supporting recovery. However, they caution that medication should not be understood as the only treatment option and should not be initiated, continued, or discontinued without a careful, individualized discussion of risks, benefits, and available alternatives. For many mental health conditions, including depression, evidence supports the use of psychotherapy and other non-pharmacological interventions either as first-line treatment or as important concurrent components of a comprehensive care plan, depending on an individual’s symptom severity, treatment history, functional needs, and preferences.

The letter emphasizes a treatment approach grounded in shared decision-making, patient autonomy, and informed consent. Clinicians should provide clear and understandable information about the purpose of a medication, expected benefits, possible adverse effects, monitoring requirements, potential discontinuation symptoms, and risks of relapse or recurrence. Patients should also be informed about the availability of evidence-based non-pharmacological interventions, including psychotherapy, social connection, behavioral approaches, sleep-focused treatments, physical activity, and nutrition-related strategies, to support informed treatment choices.

The agencies stress that non-pharmacological interventions should be made available as part of a full continuum of evidence-based mental health care rather than treated as secondary options. Treatment decisions should reflect clinical judgment, the best available evidence, and the goals and preferences of the individual receiving care. The guidance cites evidence that exercise and dietary improvement interventions may reduce depressive symptoms in some populations, reinforcing their role in treatment planning when clinically appropriate.

The letter also highlights the importance of regular and deliberate review of psychiatric medication regimens. Clinicians should assess whether medications remain necessary and beneficial and consider reduction or discontinuation when medications no longer provide meaningful benefit, contribute to adverse effects, or create unnecessary complexity. Deprescribing is described as a structured and individualized clinical process that requires patient participation, careful risk-benefit assessment, and close monitoring, and should not involve abrupt discontinuation.

These principles are particularly important for populations more vulnerable to medication-related harms or reduced access to alternative care, including children and adolescents, older adults, pregnant and postpartum individuals, and those with complex conditions. The agencies also emphasize the role of integrated care settings in improving access to appropriate diagnosis, consultation, and referral to evidence-based services.

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