APA Practice Organization comments on proposed 2016 Medicare fee schedule

Comment letter addresses payment formula, PQRS, collaborative care models and more.

On Sept. 8, the APA Practice Organization (APAPO) submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s proposed rule on the 2016 Medicare physician fee schedule.

Among the key points in the letter from the Practice Organization:

  • Medicare’s payment formula does not properly value psychologists’ work and needs to be changed so that psychologists are appropriately and fairly compensated for treating Medicare beneficiaries.
  • APAPO supports the adoption of additional proposed measures for reporting under the Physician Quality Reporting System (PQRS) that would expand the limited list of PQRS measures that now pertain to mental and behavioral health professionals.  
  • As the agency considers collaborative care models for treating beneficiaries with common behavioral health conditions, the Practice Organization encourages CMS to give appropriate consideration to models with psychotherapy as a core component of treatment.
  • The Practice Organization urges CMS to reconsider its policy of not paying for specialists’ (including psychologists’) phone consultations with primary care physicians regarding treatment of Medicare beneficiaries and to provide for billing codes that psychologists could use in connection with such consultations.   
  • While CMS is taking steps toward instituting payment for advance care planning, i.e., end-of-life, services, psychologists would be prohibited from billing Medicare for these services because they are currently ineligible to use the intended “evaluation and management” billing codes. APAPO asks CMS to allow psychologists to help beneficiaries facing end-of-life issues by reimbursing psychologists for these services.   

Additional content is included in the Practice Organization’s comment letter to CMS (PDF, 164KB).

The final rule from CMS on the 2016 Medicare fee schedule is expected to be released in early November. APAPO will continue to keep members informed about related developments and other advocacy efforts involving psychologists’ participation in Medicare.

Medicare reimbursement remains a top legislative priority of the APA Practice Organization.