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Reimbursement and scope of practice

Securing critical wins for psychology in final Medicare Physician Fee Schedule rule

APA Services leadership thanks participants in this year’s grassroots Physician Fee Schedule campaign and highlights gains obtained through their advocacy.

Date created: November 18, 2022 3 min read
Cite This Article
American Psychological Association. (2022, November 18). Securing critical wins for psychology in final Medicare Physician Fee Schedule rule. https://www.apaservices.org/advocacy/news/psychology-physician-fee-schedule

Man speaking with psychologist

On July 29, 2022, the Centers for Medicare and Medicaid Services (CMS) published its annual Physician Fee Schedule (PFS) proposed rule, which governs a number of proposals affecting coverage and reimbursement for behavioral health services in the next year. APA Services launched a campaign to enable APA members and advocates to provide comments on the proposed rule. Over 12,000 psychologists participated in the campaign, comprising over half of the total comments received by CMS.

On November 1, 2022, CMS issued a final PFS rule covering calendar year 2023. There were several successes for psychologists in this final rule, particularly in the areas of telehealth and integrated care. On November 17, 2022, Chief Advocacy Officer Katherine B. McGuire, MSc, and Chief of Professional Practice Jared Skillings, PhD, sent the following message to participants in the campaign:

We want to thank you again for participating in this year’s grassroots campaign around the annual Medicare Physician Fee Schedule proposed rule (PFS). Over 12,000 psychologists and students participated in the campaign this year, and thanks to your advocacy, the voice of psychologists throughout this process was amplified more than it has ever been. As a result, the Centers for Medicare and Medicaid Services (CMS) adopted a number of our proposals. These include:

  1. Enabling continued access to behavioral health services furnished via telehealth. CMS will maintain Medicare reimbursement rates for telehealth services at the higher “nonfacility” rate level, extend the flexibilities for telehealth an additional 151 days after the public health emergency ends, and continue coverage of audio-only telehealth. This is excellent news for psychologists providing telehealth services.
  2. Eliminating unnecessary administrative burdens for supervision. CMS adopted a proposal that allows psychologists to supervise the work of other mental and behavioral health professionals without requiring the supervising psychologist to be physically present when services are delivered (general supervision). This helps to position doctoral psychologists as leaders of health teams and use our expertise to supervise and help others.
  3. Increasing support for integrated care. CMS is finalizing a new code psychologists can use for behavioral health integration services in primary care practices. This will be important for psychologists providing services in primary care settings.

More details will be forthcoming on these issues. APA Services is also working with the broader health care community to address the impending payment cuts to all Medicare providers before the December 31, 2022, deadline. Much of the reduction is due to the year-end expiration of changes implemented under the Protecting Medicare and American Farmers from Sequester Cuts Act, the budget neutrality adjustment as required by law, and changes to the malpractice relative values. 

Again we thank you for lending your time and expertise to this important effort—just over half of all comments submitted on this year’s PFS were from psychologists. Without the broad turnout by psychologists and students, these excellent outcomes would not be possible.

As this successful campaign comes to a close, we are already looking to next year. We sincerely hope you will participate in next year’s campaign too, when CMS is likely to consider several proposals important to psychologists and their patients. These include Medicare coverage of psychologists working with unpaid caregivers and new coding mechanisms for coverage of services furnished via digital therapeutics devices and software.

We look forward to hearing from you all again in next year’s campaign.

For more information, contact Andrew Strickland. 

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