Making sense of the Medicare Access and CHIP Reauthorization Act: Medicare and your practice

This is the second in a series of articles on how psychologists fit into Medicare’s new payment models.

Starting in 2019, new quality-reporting requirements in the Medicare Access and CHIP Reauthorization Act (MACRA) may affect psychologists who work in all types of settings. In this article, Diane Pedulla, JD, director of regulatory affairs at the APA Practice Organization, answers your questions about how MACRA, the Merit-Based Incentive Payment System (MIPS) and other Medicare rules impact all kinds of psychology practices (Read the previous column, Making sense of MACRA: The low-volume threshold.

Will MACRA’s requirements affect psychologists working in nursing homes?

Possibly, depending upon how many Medicare patients they treat and how much they bill to Medicare in allowed charges. Psychologists who see large numbers of institutionalized patients may exceed the low-volume threshold (LVT) and therefore will not be exempt from MIPS reporting. The LVT currently exempts eligible clinicians (ECs) treating 100 or fewer Medicare beneficiaries or billing Medicare for $30,000 or less in annual charges.

At this time, the Centers for Medicare and Medicaid Services (CMS) are proposing that in 2018 the LVT be changed to exempt ECs who treat 200 or fewer Medicare beneficiaries or bill Medicare for $90,000 or less in allowed charges. This fall the agency will announce its decision in a final rule on Medicare's Quality Payment Program.

For more on the low-volume threshold, read Making sense of MACRA: The low-volume threshold.

How do neuropsychologists fit into this system? We do not provide treatment, only assessment.

Participation in MIPS is not limited to therapeutic services, so neuropsychologists should expect to be reporting under MIPS if psychologists are added in 2019, provided they are not exempt under the LVT. There are several quality measures related to dementia that involve services commonly provided by neuropsychologists.

We are thinking of opting out of Medicare as a practice. If we do this, would this negatively impact our ability to practice in a hospital setting; or can the hospital bill for our services under Medicare even if we have opted out?

Opting out of Medicare will greatly limit your ability to practice in a hospital setting. Once you opt out, no claims can be submitted to Medicare for your services, whether directly by you or an organization on your behalf. The one exception would be in an emergency situation where there was no other provider available who could furnish the same service and who was enrolled in Medicare.

If I opt out of Medicare, does that make it illegal for me to see a patient who is willing to pay me out of pocket?

Just the opposite. Opting out of Medicare and privately contracting with each Medicare beneficiary allows psychologists to treat Medicare patients who are willing to pay out of pocket. It’s important to keep in mind is that once a psychologist opts out of Medicare he or she can no longer treat any Medicare beneficiaries unless it is done under a private contract.

Practice MIPS reporting now with MIPSPRO

In two years, psychologists who are Medicare providers may be required to report quality measures to the Centers for Medicare and Medicaid Services under MACRA’s Merit-based Incentive Payment System, referred to as MIPS. Psychologists are not eligible for MIPS right now, but this is expected to change in 2019, when CMS will be authorized to expand the definition of eligible clinicians for purposes of MIPS reporting. Other health insurance companies could adopt similar quality-based payment models in the future.

Psychologists can practice MIPS reporting using MIPSPRO, the APA Practice Organization’s online registry for reporting MACRA/MIPS.

Read the previous column: Making sense of MACRA: The low-volume threshold.

Visit the MACRA for Psychologists: How Medicare payments will change webpage to get a link to the Practice Organization’s webinar about MACRA and MIPS reporting.

Have more questions about MACRA? Send an email. For more resources on Medicare enrollment and payment, visit the Complete Guide to Medicare for Psychologists.