Practice Organization comments on Centers for Medicare and Medicaid Services’ proposed rule on Merit-Based Incentive Payment System and Alternative Payment Models

Comment letter to CMS addresses low payment for psychological services and quality reporting mechanisms.

The APA Practice Organization submitted comments to the Centers for Medicare and Medicaid Services (CMS) on June 24 in response to the agency’s proposal for a new Medicare incentive payment system. The proposed Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) are designed to change the current Medicare payment structure so the focus is on value rather than volume.

MIPS combines key facets of three current programs in Medicare: the Physician Quality Reporting System (PQRS); the Value-Based Payment Modifier (VM), which compares quality of care to cost; and the Electronic Health Record (EHR) incentives, often referred to as “meaningful use.” Psychologists have been eligible to participate in PQRS since its inception in 2007 but are not subject to the VM or meaningful use requirements.

In the May 12, 2016, issue of PracticeUpdate, the Practice Organization reported on the initial announcement of MIPS and how it will impact psychologists treating Medicare patients. After careful review of the CMS proposed rule on MIPS and APM, the Practice Organization submitted a comment letter to CMS addressing the challenges that psychologists will face under MIPS. Following are several key points from the Practice Organization letter to CMS:

  • Reverse the trend of lower reimbursement rates and pay psychologists appropriately for treating Medicare beneficiaries.
  • Do not trap psychologists in a system designed for primary care practices that does not fit their practices.
  • Design payment models that value psychologists’ services without being overly burdensome.
  • Establish an appropriate low volume threshold that better represents psychology practices. 
  • Work with the Practice Organization to design applicable measures specific for psychologists in advance of 2019 when psychologists will be added to MIPS.

The letter further addressed specifics regarding implementation of MIPS and reimbursement for services. The full Practice Organization comment letter to CMS is available online (PDF, 71KB).

The final rule from CMS on MIPS and APM is expected to be released during the fall of 2016. The Practice Organization will continue to keep members informed about related developments and other advocacy efforts involving psychologists’ participation in Medicare.

For questions on MIPS or Medicare, contact the Practice Organization Government Relations Staff.