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Mental and Behavioral Health

Calling on all psychologists to comment on Physician Fee Schedule proposed rule

APA Services has launched a grassroots campaign inviting psychologists to help enhance access to and improve equity in mental and behavioral health services for Medicare beneficiaries.

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American Psychological Association. (2023, August 8). Calling on all psychologists to comment on Physician Fee Schedule proposed rule. https://www.apaservices.org/advocacy/news/physician-fee-schedule-proposed-rule

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On July 13, 2023, the Centers for Medicare and Medicaid Services (CMS) published its annual Physician Fee Schedule (PFS)opens in new window proposed rule, which describes several proposals affecting coverage and reimbursement for mental and behavioral health services. APA Services is calling on all of its members and all allies of psychology to submit a comment through this action centeropens in new window by September 11, 2023, to help ensure that favorable proposals become law.

Even if clinicians do not treat Medicare-covered patients, Medicare policy has a considerable influence over how mental and behavioral health services are covered and reimbursed in other programs, such as private insurance and Medicaid, and tends to set a baseline for how new and emerging forms of treatment are covered.

Last year, APA Services launched a grassroots campaign inviting members to weigh in on this important rule, and ultimately half of the total comments submitted were from psychologists. Consequentially, there are several proposals in this proposed year’s rule that were specifically requested by psychologists. These include:

  • increased work values for psychotherapy codes
  • continued reimbursement at the higher, non-facility rate, for telemental health services furnished to patients in their homes
  • reimbursement of group caregiver training in evidence-based behavioral management techniques 
  • new codes for psychotherapy for crisis services furnished outside of an office or facility with increased reimbursement

Other policies, however, require some changes to be more inclusive of services provided by psychologists—such as psychological testing services and health behavior services—to support the total mental and behavioral health needs of their patients, making it essential that psychologists participate in this year’s campaign. In addition to the grassroots campaign, APA Services will also submit its own comments on behalf of the organization. You can learn more about the FY24 PFS proposed rule by reviewing the article "Big wins for psychology in Centers for Medicare and Medicaid Services 2024 Physician Fee Schedule Proposed Ruleopens in new window." 

For more information, contact Andrew Strickland.