In February, APA Services shared written comments with the Centers for Medicare and Medicaid Services (CMS) to lay the groundwork for advancing policies to aid psychologists within the Medicare fee schedule. CMS updates Medicare coverage and payment policies each year, and these policies have a huge influence on psychologists’ practice, both for those who participate as Medicare providers and through the fee schedule’s influence on Medicare Advantage, Medicaid, and private sector coverage and payment practices.
The association recommended an array of changes across services, code values, and coverage policies within the fee schedule. The letters noted that in addition to treating mental health and substance use disorders, behavioral health services play a crucial role in managing chronic diseases by addressing psychological factors that impact physical health. Improving outcomes for Americans with chronic diseases is a key priority of the new administration.
APA Services urged CMS to:
- address disparities in valuations between psychological and neuropsychological testing services and psychotherapy services,
- establish a national payment rate for FDA-approved devices eligible and expand the list of such devices approved for Medicare payment,
- adjust the method used for reimbursing for practice expenses for office-based services,
- strengthen stakeholder engagement opportunities for fee schedule methodology changes and fee schedule payment calculations, and
- foster greater adoption of behavioral health integration services as part of future primary care payment models.
The association also urged consideration of changes in Medicare’s Quality Payment Program (QPP), designed to improve the quality and safety of care and reduce administrative burdens on clinicians. Our comments recommended approval of new process measures within the Medicare Qualified Clinical Data Registry (QCDR) program, adopting a 5-year timeline for adoption of QCDR measure to allow sufficient time for provider implementation of measures, and to move forward with the adoption of a new Merit-based Incentive Payment System (MIPS) Value Pathway measure on promotion of optimal neuropsychology consultation.
These letters are part of APA Advocacy’s broader strategy of increasing engagement with CMS staff, including incoming political appointees and career staff, combined with legislative advocacy with Congress both on psychology-specific priorities and in coalition with other organizations. APA Services has also been working alongside other provider groups to push Congress to address the continuing slide in Medicare payment updates, and we appreciate the efforts of APA members in contacting their members of Congress this year on this issue.
For more information, contact Scott Barstow and Stephen Gillaspy.