CMS Adds Psychologists to the Merit-based Incentive Payment System

The Centers for Medicare and Medicaid Services’ (CMS) final rule on the 2019 physician fee schedule included changes to Medicare’s Quality Payment Program. As expected, CMS added practicing psychologists to the Merit-based Incentive Payment System (MIPS) in 2019, which means psychologists’ reimbursements for Medicare services may be adjusted based on their performance in four different categories. Payment adjustments for this year of reporting will take effect in 2021.

If you’re a psychologist providing treatment to Medicare patients, here are the top things to know about how your reimbursement may be impacted by MIPS.

You may be exempt from MIPS reporting.

Even though psychologists in Medicare are now eligible to participate in MIPS reporting, APA anticipates that many psychologists will be exempt under the low-volume threshold (LVT). This year, psychologists will be exempt from MIPS if in 2018 they:

• treated 200 or fewer Medicare Part-B beneficiaries;
• billed Medicare Part-B for $90,000 or less in allowed charges; or
• provided 200 or fewer covered professional services.

In addition, if 2018 was your first year as a Medicare provider then you are automatically exempt from MIPS reporting in 2019. Clinicians who participate in Advanced Alternative Payment Models may also be exempt.

MIPS has four performance categories. Psychologists only report two.

MIPS has four performance categories. Psychologists only report two. For 2019, psychologists and the other non-physicians newly added to MIPS will only report in two performance categories: quality measures and improvement activities. Because psychologists and certain other non-physicians were not included in the legislation creating an incentive program designed to promote the adoption of electronic health records, psychologists will not be required to report in the promoting interoperability category in 2019. Additionally, all clinicians are not required to submit data for the cost category.

You can use APA’s qualified clinical data registry to report MIPS data.

In 2017, APA launched the Mental and Behavioral Health Registry (MBHR), a qualified clinical data registry (QCDR) approved by CMS for MIPS reporting. APA created this registry to help psychologists and other behavioral health professionals collect data on patient outcomes and report quality measures for MIPS and other quality-payment programs. The MBHR is currently the only registry that includes measures on anxiety, sleep quality and social role functioning.

Psychologists reporting as individuals may also report quality measures through claims, electronic health records, a MIPS registry, a non-APA QCDR and the CMS web interface. 

Group reporting cannot be done through claims.

Bonus payments for MIPS clinicians could be as much as 7 percent.

The potential payment adjustments in 2021 for providers participating in MIPS will range from a bonus of 7 percent to a penalty of -7 percent. MIPS is designed so that most clinicians will be considered average and thus have a payment adjustment of 0 percent.

Group practices can report as a group or as individual providers.

Psychologists in this situation will need to decide if their group practice (i.e., two or more providers billing under the same tax identification number) wishes to report under MIPS as a group and possibly earn bonuses together in 2021 or have each psychologist identify as an individual provider. Individual providers may be exempt from MIPS reporting if the fall under the low volume threshold.

Exempt psychologists can “opt in” to MIPS.

Eligible clinicians who would be exempt under the low-volume threshold can “opt-in” to MIPS reporting if they surpass one or two of the LVT criteria. However, once the decision to opt-in is made it is irrevocable for the reporting year.

Important Dates

• Jan. 1, 2019 - Dec. 31, 2019: MIPS 2019 Performance Year.
• March 31, 2020: Deadline to submit all 2019 performance data from to CMS.
• July 2020: CMS gives MIPS performance feedback to eligible clinicians.
• Jan. 2, 2021: Payment bonuses and penalties, based on 2019 MIPS reporting, are applied to each new Medicare claim.

More information about APA’s Mental and Behavioral Health Registry is available on the APA Services, Inc. website.

Psychologists with questions about the 2019 Medicare fee schedule changes are welcome to contact the Government Relations Office by telephone (202-336-5889) or by email (pracgovt@apa.org).

Published Jan. 10, 2019