APA Practice Organization comments on proposed 2015 Medicare fee schedule

Key areas addressed include declining reimbursement, telehealth services newly recognized by Medicare and the Physician Quality Reporting System for 2015.

On Sept. 2, 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 2015 Medicare physician fee schedule.

The comment letter from Executive Director for Professional Practice Katherine C. Nordal, PhD, focuses on the need to ensure fair reimbursement for and equitable treatment of psychologists in Medicare. The letter highlights key areas in the proposed rule that affect the future participation of psychologists in the program. These key areas include: 

A 1 percent projected reimbursement loss due to practice expense changes

CMS is projecting a 1 percent decrease in allowed charges for clinical psychologists in 2015, with all of the loss being attributed to changes in the relative value units (RVUs) for practice expense. APAPO believes this latest cutback will drive more psychologists to opt out of the Medicare program, which would limit patient access to Medicare mental health services.

Reviewing select testing codes 

CMS proposes to include two Current Procedural Terminology (CPT®) codes 96101 and 96118 on its list of 65 potentially misvalued codes. These codes each have more than $10 million in Medicare allowed charges, one of the metrics that CMS uses to identify services that may be incorrectly priced (either too low or too high). APAPO plans to review the current descriptors and relative values for the psychological and neuropsychological testing codes created in 2006 carefully. 

Additional telehealth services

APAPO commends CMS for adding codes 90845 (psychoanalysis), 90846 (family psychotherapy without the patient) and 90847 (family psychotherapy with the patient) to the list of recognized telehealth services. The addition of these mental health services to Medicare’s telehealth program will help address critical needs for beneficiaries who have difficulty accessing mental health treatment. 

The Physician Quality Reporting System (PQRS)
  • Claims-based reporting: APAPO applauds CMS for not proposing any further changes to the claims-based reporting method in 2015.
  • Cross-cutting measures: APAPO questions the need for requiring that eligible professionals (EPs) who have a face-to-face encounter with a patient must include two of the newly proposed cross-cutting measures in their PQRS reporting. The comment letter asked CMS to withdraw this proposal. 
  • New measures: APAPO supports adding three new measures relevant to mental health providers but asks CMS to make a critical change. The new measures are: 

    1. Adherence to Antipsychotic Medications for Individuals with Schizophrenia.
    2. Adherence to Mood Stabilizers for Individuals with Bipolar I Disorder.
    3. Follow-Up after Hospitalization for Mental Illness.

Critical Change: Only one of the three measures, Adherence to Mood Stabilizers for Individuals with Bipolar I Disorder, is designated for use with claims-based reporting. APAPO is asking CMS to revise its proposal so that all three of these new mental health measures can be reported through claims as well as through registries.

Modifying the process for establishing code values

The proposed rule is working to streamline the process to make all code reviews efficient and to allow adequate review time for code evaluation. APAPO supports retiming for the coding and reimbursement processes.

The Value-Based Payment Modifier

CMS is proposing to apply a value-based payment modifier (VM), which is intended to reflect both quality and cost of care, when determining payments for all physicians and nonphysician EPs, including those in solo and small group practices (under 10) in 2017. CMS will first apply the VM to physicians in large groups of 100 or more EPs in 2015. In 2016 the VM applies to physicians in groups of 10 or more EPs. APAPO agrees that physicians and nonphysicians should be treated equally under the VM and supports CMS’ decision to only apply upward or neutral payment adjustments in 2017 for solo and small group practitioners who will have the VM applied to their payments for the first time. 

APAPO did express concern over how CMS will determine VM adjustments based on quality and cost measures for solo and small group practitioners who furnish only a limited number of services and have few PQRS measures to choose from. APAPO will continue to monitor how CMS implements the VM for solo and small-group practitioners.

The full comment letter submitted to CMS is available on the Legislative Advocacy Center

Medicare reimbursement remains a top priority of the APA Practice Organization. As challenges and opportunities arise, APAPO will continue to address related issues on the legislative and regulatory levels on behalf of practicing psychologists. 

The final rule is expected to be released in early November. APAPO will continue to keep members informed about our advocacy efforts to protect psychologists’ reimbursement and related developments throughout the remainder of 2014.