Help APA prevent payment cuts to psychologists’ services

Psychologists have until October 5, 2020 to share concerns with the federal government to help prevent drastic payment cuts to psychologists’ services.

If approved, these payment cuts—which are included in the proposed 2021 Medicare physician fee schedule—would affect critical services provided to older adults and people with disabilities.

So far, 4,700 psychologists from across the country have submitted comments on the proposed rule to the Centers for Medicare and Medicaid Services (CMS). Many of them included personal stories about the challenges that psychologists face treating Medicare beneficiaries and how the projected payment losses could make it impossible to continue being a Medicare provider.

We encourage psychologists to submit comments via APA’s special comment submission systemopens in new window. This will help APA track the number of comments made and strengthen psychology’s advocacy position. When submitting a comment, emphasize these key points:

• Asking CMS to work with Congress to waive budget neutrality and avoid reducing provider payments in 2021
• Adjusting work values for psychotherapy, health behavior assessment and intervention, and psychological and neuropsychological testing services to maintain relativity with the increased values for evaluation and management (E/M) services
• Removing the originating site and geographic location requirements from telehealth
• Allowing beneficiaries to continue receiving mental and behavioral health services using audio-only telephones
• Allowing psychologists to practice to the full extent of their state licensure

In addition to those points, APA is making several other recommendations to CMS.

APA supports the creation of new codes to allow nonphysician practitioners (NPPs) who cannot report E/M services to use digital technology to assess and manage their patients’ health. Through communication technology-based services, psychologists will be able to report virtual check-ins with their patients, a critical option during the current public health emergency.

APA is also asking CMS to refrain from allowing NPPs such as nurse practitioners and physician assistants to supervise psychological and neuropsychological testing. There is not enough information on their scope of practice and qualifications to supervise psychological and neuropsychological testing. There is also a lack of information on the training and scope of practice of the types of auxiliary staff who would be administering the tests.

APA supports the proposal by CMS to allow “incident-to” services to be furnished via telehealth when the billing professional is using real-time, interactive audio, and visual telecommunications to provide direct supervision.

Along with asking CMS to continue allowing patients to use audio-only telephones for mental and behavioral health services, APA is requesting that the agency require a modifier to distinguish audio-only services from those furnished with audio and visual telehealth technology.

Regarding audio-only assessments, APA is asking CMS to continue allowing biopsychosocial assessments to be furnished via audio-only telephones so that older adults and Medicare beneficiaries with disabilities can access these services from the privacy of their home.

In response to a request for input by CMS, APA is asking for the following changes to telehealth:

• Make the codes for Group Psychotherapy (90853), the add-on for the Neurobehavioral Status Exam (96121), and Psychological and Neuropsychological Testing evaluation services (96130–96133) permanent additions to telehealth.
• Add the codes for Psychological and Neuropsychological administration services (96136–96139) as interim (category 3) telehealth services.
• Add the codes for Adaptive Behavior (0362T, 0373T, and 97151–97158) and Developmental Testing (96112–96113) as interim (category 3) telehealth services.

Lastly, APA is requesting that CMS add the codes for Psychological and Neuropsychological Testing (96116, 96121, 96130–96133, and 96136–96139) to the specifications for quality measure #374—Closing the Referral Loop. This revision will expand the number of quality measures available to psychologists under the Merit-based Incentive Payment System (MIPS) and increase their chances of successfully reporting in MIPS.

Submit your comments using APA’s comment submission systemopens in new window before October 5, 2020.