Psychologists providing testing services in Medicare have an opportunity to submit comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed 2019 Medicare Physician Fee Schedule.

The CMS proposed rule, released in July, details a new billing code structure as well as increased reimbursement rates for psychological testing. Feedback from practitioners is essential to preserving the higher than anticipated rates.

Comments are due Sept. 10. To submit a comment, please follow the link here and click the “Comment Now” button on the top right-hand corner of the screen. The Practice Organization will also submit a comment letter on the proposed rule.

Testing services receive better than expected payment

Here’s what to expect if CMS adopts the new reimbursement rates outlined in the proposed physician fee schedule:

  • The Medicare payment for a six-hour battery of psychological tests is projected to increase approximately 6 percent.
  • Payment for a six-hour neuropsychological test battery conducted with the assistance of a technician is also projected to increase 6 percent.
  • Payment for a six-hour neuropsychological test battery conducted by a neuropsychologist her/himself could decrease by about 3 percent.
  • The reimbursement rate for a one-hour neurobehavioral status exam is projected to increase by almost 2 percent, with reimbursements for a two-hour exam declining by about 5 percent. The reason for the projected decline in payment for the two-hour exam is that under the new coding structure a neurobehavioral status exam taking longer than one hour would require two billing codes, with the second code valued lower than the first.

The Practice Organization is still awaiting more information from CMS so that we can project payment rates for facility-based testing services.

CMS is expected to release the final rule on the physician fee schedule later this fall. Final reimbursement rates will take effect in January 2019.

Advocacy efforts prevent drastic cuts

The payment increases in the proposed rule represent a major victory for psychologists and the APA.

Billing codes for testing services were significantly revised by the American Medical Association Current Procedural Terminology® Editorial Panel and revalued by the Resource-Based Relative Value Update Committee. APA and Practice Organization staff learned that these revisions could have led to deep cuts in payment to psychologists and neuropsychologists.

Over the past year, the Practice Organization met repeatedly with CMS to convey the importance of testing services in caring for Medicare beneficiaries and to persuade the agency not to make potential double-digit cuts in testing service reimbursement rates for psychologists.

Because of this advocacy, CMS did not eliminate payments to practitioners who gather their own test data, and slightly increased reimbursement rates for testing services.

Questions and resources

Email the Government Relations Office if you have questions about the proposed rule and its implications.

Read “Up-to-Code,” the Practice Update column on billing and reimbursement.

Visit APA Practice Central for more information on Medicare, codes and billing.