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A new rule proposed by the Centers for Medicare and Medicaid Services (CMS) (PDF, 56MB) would threaten vital psychotherapy, testing and integrated care for older Americans and people with disabilities by cutting the fees of psychologists who work with them.

Under this rule—known as the 2020 Medicare Physician Fee Schedule Proposed Rule—psychologists who treat Medicare patients would lose 7% of their reimbursements in 2021 making it very difficult for them to continue to treat seniors and other vulnerable populations

APA Opposes These Proposed Cuts in the Strongest Possible Terms

Vulnerable Americans need your help. Submit a digital comment to CMS by Sept. 27.

COMMENT NOW

Comment on the 2020 Medicare Physician Fee Schedule Proposed Rule by clicking on the “Comment Now" button.


To have an impact, it is critical for CMS to receive a very large number of digital comments, both from psychologists and from those who value the services psychologists provide.

If you do not want to write your own comment, feel free to cut and paste the comment below:

Sample Comment

I am writing to comment on the CMS proposed Medicare Physician Fee Schedule for 2020, and its effect on patients. The proposed decrease could undermine the care psychologists provide to America's senior citizens and people with disabilities.

In the strongest terms possible, I urge you to exclude psychologists from the 7% payment reduction in 2021.

Thank you for considering my views on these issues.

Sincerely,
XXXX

 

This proposed rule change is a particularly serious threat to the field of psychology and to access to care. Private insurance often follows Medicare's lead when updating payment rates and policies. In other words, this proposal may affect all health-service psychologists and undermine the care of older adults and people with disabilities.

For more detail on APA's position, read the letter APA sent to CMS (PDF, 164KB).

Below are sample comments psychologists can use in their comments to CMS:

Sample comment for practicing psychologists

As a psychologist who provides clinical services to patients, I am writing to comment on the CMS proposed Medicare Physician Fee Schedule for 2020, and its effect on both psychologists like me and on my patients. 

I understand that psychologists are facing a 7% payment decrease in 2021 so that higher payments can be made for E/M services. This would be a devastating loss, because as you know, psychologists have already faced more than a decade of reimbursement cuts for their services. Most importantly, this additional decrease comes at a time when psychological services play a critical role in the lives of America's senior citizens, as our elderly population continues to grow. 

At the same time, I am very pleased to see that psychologists who provide Health Behavior Assessment and Intervention (H&B) services will see increases due to a new coding structure and higher values in 2020. Physical health conditions are taking a heavy toll on Medicare beneficiaries, and we know from research that increasing access to psychological and behavioral health services will improve patient outcomes and reduce overall spending. 

In the strongest terms possible, I urge you to (a) exclude psychologists from the 7% payment reduction in 2021, and (b) adopt the proposed revisions and value increases for the H&B codes.

Thank you for considering my views on these issues.

Sincerely,
Dr. XXXX

Personalized comment for practicing psychologists

As a psychologist who provides clinical services to patients, I am writing to comment on the CMS proposed Medicare Physician Fee Schedule for 2020, and its effect on both psychologists like me and on my patients.   [Include short description of your practice with Medicare patients, such as “I am a psychologist practicing in Iowa, and I see Medicare patients every week who need psychotherapy services for depression. I am one of the only providers of these services in my area.”]

I understand that psychologists are facing a 7% payment decrease in 2021 so that higher payments can be made for E/M services. This would be a devastating loss, because as you know, psychologists have already faced more than a decade of reimbursement cuts for their services.  Most importantly, this additional decrease comes at a time when psychological services play a critical role in the lives of America's senior citizens, as our elderly population continues to grow. [Include personal examples of your work, such as “I provide neuropsychological testing for older adults to determine if they have dementia. This fee reduction will cause me to reduce the number of Medicare patients I see or focus my practice on patients with commercial insurance.”]  

At the same time, I am very pleased to see that psychologists who provide Health Behavior Assessment and Intervention (H&B) services will see increases due to a new coding structure and higher values in 2020. Physical health conditions are taking a heavy toll on Medicare beneficiaries, and we know from research that increasing access to psychological and behavioral health services will improve patient outcomes and reduce overall spending. [Consider including personal examples of your work, such as “I am a health psychologist and work with patients who have diabetes to improve their compliance with taking medications, monitoring blood sugar, and improving healthy eating. I have seen how this improves their health and quality of life.”]  

In the strongest terms possible, I urge you to (a) exclude psychologists from the 7% payment reduction in 2021, and (b) adopt the proposed revisions and value increases for the H&B codes.

Thank you for considering my views on these issues.

Sincerely,
Dr. XXXX

Date created: September 2019