Grassroots advocacy yields positive changes in neuropsychology assessment policy
By Communications staff
April 26, 2012—Starting May 15, new regional Medicare policy that should improve access to and reimbursement for neuropsychological assessment will take effect in several states as a result of grassroots organizing and other advocacy efforts of a joint task force of neuropsychology organizations. Following a multifaceted strategy that lasted several months, a group of neuropsychologists succeeded in securing a positive outcome for the discipline.
In early spring 2011, Wisconsin Physician’s Service (WPS), the Medicare Administrative Contractor (MAC) for Wisconsin, Minnesota, Michigan and Illinois, released a draft policy on neuropsychological testing. Known in Medicare as a local coverage determination (LCD), these policies are established by MACs to inform practitioners and beneficiaries about the criteria for Medicare coverage of various services. The draft proposal recommended the use of the Functional Assessment Staging Tool (FAST) scale in place of a neuropsychological evaluation for individuals with suspected Alzheimer’s Disease and would have eliminated feedback sessions, among other unfavorable changes.
A joint task force of neuropsychology organizations, formed in May 2011 by Michael McCrea, PhD, ABPP-CN, and headed by Michelle Braun, PhD, ABPP-CN, which included representatives from the American Academy of Clinical Neuropsychology (AACN), APA Div. 40 (Clinical Neuropsychology) and the National Academy of Neuropsychology (NAN), drafted a model LCD for consideration by WPS. The task force worked for months creating an extensive model LCD document for Medicare coverage detailing what neuropsychological testing is, what billing codes should be used and when testing is and is not indicated.
The task force then engaged in a widespread grassroots campaign to educate stakeholders including neuropsychologists, professional organizations, physicians and other medical providers, and consumer organizations, and to mobilize letters and comments during the open comment period following the release of the proposed policy. More than 100 comments were submitted to WPS, reportedly an unprecedented number.
In addition, Dr. Braun’s ongoing communication with the policy coordinator at WPS, as well as personal connections fostered with various other insiders, provided insight for more effective advocacy.
The final policy released by WPS incorporates all substantive aspects of the Model LCD, reflecting many positive changes for neuropsychology as a discipline.
The major changes incorporated in the final WPS policy were:
The FAST scale was removed and neuropsychological assessment is once again allowed as a diagnostic tool for Alzheimer’s Disease.
Feedback sessions are now allowed.
Neuropsychological testing may be utilized as a diagnostic tool for Mild Cognitive Impairment (MCI), which was previously diagnosed through interview alone.
“This victory is a shining example of the type of major policy victory that we are capable of when we work together,” says Braun.
According to Braun, this new policy could be significant for all providers of neuropsychological services. As the largest Medicare Administrative Contractor, WPS has the potential to set the tone for national coverage, and many private insurers reference Medicare policy in developing their LCDs. In addition, this work could help provide a blueprint for responding to future proposed Medicare cuts to psychological services.
“The decision by Wisconsin Physicians Service to revise its policy on neuropsychological testing services and adopt changes sought by the task force speaks directly to the power of advocacy,” says APA Executive Director for Professional Practice Katherine C. Nordal, PhD. “We applaud the members of the task force and other psychologists for speaking up on behalf of their profession and persuading WPS to make improvements that will benefit both providers and their patients.”