2017 Medicare Physician Fee Schedule: Proposed rule and relevance to psychologists

The Centers for Medicare and Medicaid (CMS) has released its physician fee schedule for 2017. How might it affect practitioners?

On July 15, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule on the Medicare Physician Fee Schedule for 2017. In the proposed rule, CMS outlines the agency’s plans for integrated care, care coordination, cognitive services and telehealth services, among other topics.

With Congress eliminating the Sustainable Growth Rate in 2015 psychologists no longer face the risk of major cuts in reimbursement each year. Psychologists can, however, expect to see a slight decrease in payments due to the ongoing impact of sequestration.

Here are the key details of the rule:

  • Reimbursement of a new Behavioral Health Integration Model: CMS is proposing coverage of behavioral health integration services, including the creation of new payment codes for these services. The primary billing codes created for this rule, which CMS says are temporary until new Current Procedure Terminology (CPT®) codes are created, focus on one specific model of care led by psychiatrists. There is no comparable role for psychologists being discussed under this rule. However, CMS states that it expects to expand its recognition of other integrated care models once the new CPT codes are finalized.
  • Medicare Diabetes Prevention Model: CMS is proposing to expand the Diabetes Prevention Program (DPP) administered by the Centers for Disease Control and Prevention (CDC) into a new Medicare DPP. This program would be covered under Medicare Part B as preventative service. The APA Practice Organization supports this proposal, and is asking CMS to promote referrals to psychologists to help patients address the psychosocial components of their treatment for diabetes.
  • Cognitive Impairment Assessment and Care Planning: CMS is proposing a new reimbursement G-code, “GPPP6,” to provide separate payment for assessing and creating a care plan for beneficiaries with cognitive impairment. As with the codes for the proposed Behavioral Integration Model, CMS states that this code is only to be used until the release of the new CPT codes. The APA Practice Organization opposes this proposal because it does not adequately differentiate between brief screenings and comprehensive testing.
  • Medicare Telehealth Services: CMS decided against including psychological and neuropsychological testing to the list of reimbursable telehealth services. CMS is proposing to use the facility Practice Expense Relative Value Units when paying providers for telehealth services, which will result in lower fees for telehealth services. As an alternative the APA Practice Organization has asked CMS to make the patient’s home an originating site for telehealth.

In the proposed rule, CMS introduces new concepts but misses some opportunities to effectively recognize, reimburse and incentivize the delivery of behavioral health services by psychologists.

The APA Practice Organization submitted a comment letter to CMS addressing the rule’s limitations on Aug. 22. You can read the comment letter on the Legislative Action Center page.

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