By Government Relations staff
April 25, 2013–The APA Practice Organization (APAPO) was invited by the House Energy and Commerce and Ways and Means Committees to address questions related to a congressional proposal to repeal the Sustainable Growth Rate (SGR) formula. The proposal is a first step toward permanently reforming the Medicare payment model and suggests replacing the SGR with a performance-based system using quality of care measures.
Included as part of the 1997 Balanced Budget Act, the SGR formula limits the yearly increase in costs per Medicare beneficiary by tying it to national gross domestic product (GDP). Because implementing the SGR formula each year often requires drastic reimbursement rate cuts, Congress has acted 15 times to override the scheduled cuts. Most recently, a 26.5 percent payment cut was averted as part of the American Taxpayer Relief Act on Jan. 2, 2013.
On April 11, APAPO submitted a letter (PDF, 47KB) addressing several of the proposal’s questions on quality improvement and measurement, provider participation in new payment models and changes that could be made to current law regarding health care delivery for Medicare beneficiaries.
In response to a question concerning clinical practice improvements relevant to psychology, APAPO pointed out that developing measures to assess quality is challenging for mental health and that the proposal was unclear as to whether “quality” referred to measuring patient change or provider behavior. Currently most measures for mental health reflect changes in symptom status or disorder status but do not gauge the efficacy of the modality used in a particular intervention.
The letter also noted that in many cases, a realistic treatment goal may be continued maintenance of present functioning rather than actual improvement in symptoms, as some mental health problems are chronic. Measuring quality involving behavioral health treatment by psychologists may be easier as the goals are more objective and observable (for example, patient compliance with a medical treatment plan).
The proposal also discussed alternative payment model (APM) adoption, and posed questions about what will be necessary to encourage provider participation in new payment models. APAPO suggested that APMs will have to accurately value the skill, time and clinical decision making of the professional. They must also provide consistency so that providers have some idea what they will be paid from one year to the next. The models’ requirements must not be overly burdensome.
APAPO also suggested improvements to the current law that would enable psychologists to better care for their Medicare patients:
Amend the Medicare payment formula so that psychologists, as low-cost, low-technology providers, are not penalized by adjustments in practice expense that favor specialties with higher costs for equipment and supplies.
Grant psychologists access to the evaluation and management (E&M) codes, including the new codes for care coordination and transition care management to better reflect levels of complexity in care.
Add psychologists to the physician definition in Medicare to remove unnecessary physician supervision in programs such as partial hospitals.
Adopt the Behavioral Health Information Technology (BHIT) bill and make psychologists eligible for the same incentives as other providers.
Expand opportunities for psychologists to be part of integrated health care that addresses patients’ physical and behavioral health needs.
In closing, APAPO made some additional requests that would ensure the inclusion of psychologists going forward:
Including a psychologist on the Expert Panel discussed in the proposal.
Creating only one program for all providers; not separate but similar programs for physicians and non-physicians.
Changing language in the proposal to ensure that the Secretary of Health and Human Services will solicit input from, and consult on efficiency measures with, all specialty societies and not just physician organizations.