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ACT NOW TO SAFEGUARD PSYCHOLOGICAL AND BEHAVIORAL HEALTH SERVICES
You can help prevent proposed Medicare cuts to reimbursement and coverage of psychological services for older adults and people with disabilities.
The Centers for Medicare and Medicaid Services (CMS) proposed rule on the 2021 Medicare physician fee schedule includes changes in payment policy that will directly affect psychologists and their patients. Because Medicare’s payment policies often serve as the benchmark for private insurance and other programs, APA urges all psychologists, not just those taking part in Medicare, to submit comments.
CMS is proposing reducing payments to all providers – physicians and psychologists - by 10.6%.
Psychologists can voice their concerns to CMS over how this financial loss will affect their ability to treat Medicare patients, by submitting comments to CMS.
The comment period is open now through October 5 at 5:00 pm.
Using the sample comment language provided, we encourage you to personalize comments on how these proposed cuts will affect Medicare patients:
- Include one or two opening sentences to identify yourself as a psychologist, and including the name of your state.
- Personalize your comments and include examples from your own work, when possible. Describing how CMS policies will affect your patients will make your comments more effective.
Sample comment language (you can cut and paste from this point):
"I am a psychologist who provides clinical services to Medicare beneficiaries. Due to the COVID-19 public health emergency, I have had to make significant changes to my practice to ensure the safety and continued care of my patients. I greatly appreciate CMS expansion of telehealth and audio services during the pandemic. It’s enabled my patients’ ability to continue receiving treatment at a time when in-person visits present a health risk across the country. I hope CMS will permanently remove originating site requirements and continues audio only services for Psychotherapy and Health Behavior Assessment and Intervention (HBAI) services.
Telehealth
I am asking CMS to permanently add Group Psychotherapy (90853) and the add-on code tor the Neurobehavioral Status Examination (96121) to Medicare’s telehealth list. I also request that the codes for Psychological and Neuropsychological Testing evaluation (96130-96133) be moved from interim to permanent on the telehealth list. Lastly, I support adding the codes for Psychological and Neuropsychological Testing administration services (96136 – 96139), Developmental Testing (96112 & 96113) and the Adaptive Behavior & Treatment Codes (97151 – 97158, 0362T & 0373T) on an interim basis.
Payment Cuts
I urge CMS to work with Congress to avoid the losses all clinicians will incur if the proposed 10.6% reduction in the conversion factor goes into effect. Having payments cut by so much will make it difficult, if not impossible, for me to continue to be a Medicare provider.
CPT Code Adjustments
CMS is proposing higher adjustments for the Psychiatric Diagnostic Interview and several of the Psychotherapy codes to maintain relativity with the increases for the outpatient evaluation and management codes. I appreciate this increase, but it is not enough. Upward relativity adjustments are needed for all Psychotherapy, Psychological and Neuropsychological Testing, and HBAI codes. I strongly recommend that CMS accept the relativity code adjustments that the American Psychological Association has proposed.
Scope of Practice
I have significant concerns regarding the CMS proposal to allow the supervision of psychological and neuropsychological testing by non-physician providers (e.g., nurse practitioners, physician assistants). This expansion should not be allowed without knowing what tests are being given, which auxiliary staff they are supervising, and whether such individuals are appropriately trained to administer psychological and neuropsychological training.
I strongly recommend that CMS allow psychologists to practice to the full extent of their licensure and scope, as the agency has done for other types of clinicians this year. Specifically, CMS should eliminate unnecessary physician supervision requirements for all psychologists in all settings and allow psychologists with prescriptive authority in their state to bill for evaluation and management services, just as they do for private insurance and Medicaid for psychotropic mediation management. Lastly, CMS should allow for reimbursement of services psychologists routinely provide but cannot bill because of the placement of the codes in the CPT manual or outdated CMS regulation, for example smoking cessation codes (99406 & 99407) and intensive behavioral obesity treatment (G0447 & G0473)."
With your help, together we will have a greater impact!