On September 13, APA Services wrapped up its annual effort to ensure psychology’s voice is heard as the Centers for Medicare and Medicaid Services (CMS) considers proposed changes to the Medicare Physician Fee Schedule for 2022. The fee schedule is a proposed rule which would govern how Medicare services are reimbursed and how certain important services are delivered. This successful effort unified voices across the discipline of psychology, including practitioners, scientists, educators, and students, who joined together in submitting a record-breaking total of 9,814 comments to CMS.
Setting a new record with this second consecutive year of significant growth in participation, psychologists participated at higher rates than they did last year in 40 states, showing consensus on the nationwide importance of this proposal to the field of psychology and the population it serves. As a result of this increased participation, APA Services currently has a larger share of total comments submitted to CMS than it did last year. While the final national comment tally is still in flux, as of now APA comments represent 28% of all comments submitted, compared to last year’s 17% share.
The CMS Medicare fee schedule proposal includes provisions the association opposes and provisions the association is urging the agency to keep. Among provisions of concern, CMS is proposing a 3.89% reduction in the Medicare conversion factor used to calculate all of the program’s reimbursement rates. APA Services opposes this reduction because it would contribute to a roughly 7% decrease in rates paid to clinicians when combined with other reductions scheduled to take effect in 2022.
APA Services also recommended CMS continue reimbursing providers for telehealth and audio-only services at the same rates that have been in effect during the public health emergency declaration for COVID-19. During the pandemic, telehealth services are being reimbursed at the same rate as in-person services. For mental health, substance use, and health behavior providers, whose patients are the most frequent users of telehealth, it would be a costly reduction for telehealth and audio-only services to be paid at the lower rate paid for facility-based services as was done before COVID-19. That reimbursement loss would also discourage many providers from continuing to offer telehealth services, jeopardizing access to care for many.
The association also advocated for CMS to establish remote therapeutic monitoring (RTM) codes to allow psychologists and other nonphysician providers to bill for these services. Psychologists provide nonphysiological services through remote monitoring and should be allowed to bill Medicare for this work. APA Services recommended that the reimbursement rates for RTM services under new codes be set equal to reimbursement rates for remote physiological monitoring codes that are already in use.
The association expressed support for several provisions in the CMS proposal, including permanent adoption of service delivery flexibilities granted to providers during the pandemic. These include critical new policies on coverage of telehealth and audio-only services. APA Services’s detailed comments are available onlineopens in new window.
Now that the comment period has officially closed, CMS will review comments and adjust its proposal in response. It will then publish a final rule, likely in the late fall or early winter. Now, our advocacy staff will focus on gaining support from Congress on these and other Medicare policy changes needed to help improve access to psychologists’ services.
We once again thank the advocates who spoke from across the entire discipline of psychology to contribute to this record-breaking success. Together, we took a stand to tell the government and insurance companies that psychology matters and all the communities we serve matter.
For more information, contact Scott Barstow, MS.