The Centers for Medicare and Medicaid Services releases proposed rule on the 2019 physician fee schedule detailing a new billing code structure.

Editor's Note: This article was updated July 19, 2018, to provide additional information on the 2019 CMS proposed rule. 

Many psychologists who provide psychological and neuropsychological testing services will likely receive an estimated 6 percent increase in reimbursement for a battery of outpatient testing services under a proposed rule by the Centers for Medicare and Medicaid Services (CMS). This 6 percent increase would apply to all psychological testing. Neuropsychological testing where data is collected by a technician would also receive a 6 percent increase.

This is a major win for psychologists and the APA, whose Practice Organization advocated successfully to obtain higher reimbursement rates, even in this era of financial cuts.

The APA's Practice Organization initial review of the 2019 Medicare Physician Fee Schedule proposed rule does suggest that practitioners who gather their own neuropsychological test data may see a 3 percent decrease in their payments. The reason for this change is because CMS currently reimburses these providers at a slightly higher rate than neuropsychologists who use technicians. The 2019 proposed rule levels out payments between these two groups of neuropsychologists.

“The proposed reimbursement increases from CMS represent a crucial advocacy victory for practicing psychologists,” says APA Chief of Professional Practice Jared L. Skillings, PhD, ABPP. "Our team is here and ready to help psychologists and neuropsychologists understand and comply with new ways of practicing.”

APA advocacy prevents drastic payment cuts

During the complicated and highly confidential process for valuing health care services, APA staff learned that psychologists and neuropsychologists could have been facing alarmingly deep cuts to payments for testing services.

Staff from APA’s Health Care Financing and Government Relations teams spent more than two years advocating on psychologists’ behalf to prevent a major drop in reimbursement for testing and data collection. APA Chief Executive Officer Arthur C. Evans Jr., PhD, and Past President Tony Puente, PhD, met with CMS officials to explain the value of neuropsychological and psychological testing services.

By increasing the rates, CMS directly acknowledged APA’s robust advocacy efforts. The agency agreed that there is “no evidence... to merit a reduction in the valuation for [psychologists’] professional services.” As a result, the agency decided to raise the reimbursement rates for most psychologists who provide these services in 2019.

“APA and its Practice Organization advocated fiercely to prevent steep cuts. We appreciate that CMS heard our arguments and understood the value of services psychologists provide,” said Evans. “These proposed reimbursement increases represent a major advocacy victory for practicing psychologists.”

Next steps: Advocate and educate

When APA staff complete their final analysis of the 1,400-page rule, they will submit a comment letter to CMS addressing the agency’s changes to the testing codes and other relevant issues in the proposed rule. In the near future the APA will also launch a grassroots initiative for psychologists, neuropsychologists and other stakeholders to submit their own comments to preserve this proposed reimbursement increase.

To learn more about the Physician Fee Schedule and how psychological services are valued, register for a free one-hour webinar on Thursday, July 19, at 11:30 a.m. EST.

Psychologists going to APA convention 2018 can also attend the symposium: 

  • "Securing Psychology’s Identity in Health Care: The Next Decade of Psychological and Neuropsychological Testing”
    Saturday, Aug. 11, 2-3:50 p.m.
    Moscone Center, Room 207

Questions and resources

Email us if you have questions about the proposed rule and its implications.

Register for our free one-hour webinar, "Getting reimbursed: Changes coming to testing codes."

Read “Up-to-Code,” the Practice Update column on billing and reimbursement.

Visit APA Practice Central for more information on Medicare, codes and billing.