APA Practice Organization comments on Medicare payment law implementation

Letter to CMS highlights the need to replace the flawed Medicare payment formula.

The APA Practice Organization (APAPO) submitted a comment letter (PDF, 77KB) on Nov. 13, 2015, to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s Request for Information regarding changes in payment involving the Medicare Merit-Based Incentive Payment System (MIPS) and alternative payment models (APMs). 

MIPS was established as part of the Medicare payment law known as the Medicare Access and CHIP Reauthorization Act of 2015. It will combine several current incentive programs, including the Physician Quality Reporting System among others, into one consolidated program. The goal of the consolidated program is to shift the focus of Medicare payment from volume to value. The first phase of MIPS is expected to include psychologists beginning in 2021.

In promulgating its Request for Information, CMS is looking for input about considerations for designing the new Medicare payment system from key stakeholders such as APAPO and other societies representing health care professionals who will be eligible to participate in the system.  

APAPO’s comment letter begins with a call for changing the Medicare payment formula so psychologists are appropriately and fairly compensated for treating Medicare beneficiaries. APAPO argues that continuing to apply a flawed formula perpetuates the inequities faced by psychologists and other mental health providers in Medicare.  

Other key points in the letter touched on: defining eligible professionals in MIPS; measuring quality and resource use performance; defining clinical practice improvement categories; and developing performance standards.  

Another portion of the comment letter addressed APMs. APAPO supports the APM concept and the possibilities these models hold for the greater integration of psychologists’ services into primary care. In the comment letter APAPO expressed concern that APM participation requirements will block the vast majority of psychologists and other mental and behavioral health providers from participating in APMs. Ensuring that psychologists have a role in APMs is critical because health care professionals who participate in APMs will receive bonus payments.  

Additional information about the Medicare Access and CHIP Reauthorization Act of 2015 and MIPS is available in the Spring/Summer 2015 issue (PDF, 2.2MB) of Good Practice, the magazine for APAPO members.