CMS releases proposed Medicare fee schedule rule for 2015

Projected reimbursement changes and additional telehealth codes are among the key changes in the proposed fee schedule rule that could affect psychologists.


On July 3, 2014, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule (published in the July 11 Federal Register) on the 2015 Medicare fee schedule. The APA Practice Organization (APAPO) anticipates submitting comments on the proposed rule by Sept. 2 based on a review by both APAPO and the APA Office of Health Care Financing.

Among the key changes that could impact psychologists in 2015:

  1. Projected Reimbursement Changes
    Medicare’s reimbursement pool for psychological services is anticipated to drop on average by about 1 percent in 2015 due to adjustments in practice expense. Ninety percent of Medicare providers will see a payment adjustment ranging from +1 percent to -1 percent. Audiology, chiropractic, cardiac surgery, social work and interventional radiology will also receive 1 percent less in 2015, while 24 specialties, including psychiatry, will remain flat at 0 percent. Independent laboratory services will receive the largest positive adjustment of 3 percent, while radiation oncology (-4 percent) and radiation therapy centers (-8 percent) will experience the biggest losses.

    The 1 percent projected decline for psychologists — if the 2015 payment rule is finalized as proposed — follows an 8 percent boost in the Medicare payment pool for psychological services in 2014.

    The proposed rule does not address possible adjustments to Medicare payment resulting from the Sustainable Growth Rate (SGR). The Protecting Access to Medicare Act of 2014 (PAMA) ensures no change in Medicare payments to providers due to SGR before April 1, 2015.
  2. Potential Codes for Review in 2015
    By law, CMS must periodically examine the “work values” for all codes to determine if they are “potentially misvalued.” When doing so CMS prioritizes high expenditure codes — those costing Medicare $10 million or more annually — whose values have not been reviewed in more than five years. Because of the length of time since their last reviews the codes may require changes in their work values and updates to the practice expense inputs.

    In this proposed rule CMS identifies 65 codes as being potentially misvalued, including 96101 (psychological testing by a professional) and 96118 (neuropsychological testing by a professional), both of which were last reviewed in 2005. APAPO will keep psychologists informed of future activity, if any, required by CMS of psychology involving these testing codes.
  3. Additional Telehealth Services for Mental Health
    CMS is proposing to add three psychiatric procedure codes to Medicare’s list of telehealth services: codes 90845 (psychoanalysis), 90846 (family psychotherapy without the patient) and 90847 (family psychotherapy with the patient). The agency stated in the proposed rule that these three services are similar to other psychiatric services that already are eligible for coverage as telehealth services, including psychotherapy.

    CMS rejected the idea of adding psychological testing (96101 and 96102) and neuropsychological testing (96118 and 96119) to the list of approved telehealth services because these services require close observation of how a patient responds while undergoing testing.

    Medicare’s specific telehealth requirements must be met in order to be reimbursed for telehealth services. Communication by telephone does not qualify as telehealth.
  4. The Physician Quality Reporting System (PQRS)
    CMS is proposing a number of changes to PQRS in 2015. Unlike in past years, however, the agency is not seeking to eliminate the claims-based reporting mechanism. The proposed changes include adding new measures and removing others that may no longer be of use to PQRS. After completing its analysis of the proposed rule APAPO will provide further information on the various proposed changes to PQRS.
  5. Expansion of the Value-Based Payment Modifier
    CMS is planning to exercise its authority to extend the use of the value-based payment modifier (VM) to services provided by non-physician eligible professionals, including psychologists, in 2017. Currently the VM is only applied to payments for physicians and physician groups. The VM provides for differential payment under the Medicare fee schedule to a provider or a group of providers based upon the quality of care furnished compared to cost during a performance period. APAPO will provide more explanation of the VM and its potential impact on psychologists in Medicare in future communications.

    APAPO and the APA Office of Health Care Financing will continue to keep members up to date about important developments related to the 2015 Medicare fee schedule.