Updated information from our July 13th notice on the new psychological and neuropsychological testing services codes and their proposed reimbursement rates, and the major impacts for psychologists of the 2019 Medicare fee schedule proposed by the Centers for Medicare and Medicaid Services (CMS). CMS is projecting that on average psychologists will have a 2% increase in Medicare payments for the aggregate of all services, including psychological and neuropsychological testing, psychotherapy, and Health & Behavior codes.
New Psychological and Neuropsychological Testing Codes
Psychologists will report new psychological and neuropsychological testing codes beginning January 1, 2019. CMS targeted these codes for revision and tasked the AMA Current Procedural Terminology (CPT®) and Resource Based Relative Value Update Committees (RUC) with restructuring and revaluing the codes. Based on the new structure adopted by the CPT and RUC committees, we were concerned that CMS would consider eliminating payments to psychologists and neuropsychologists for gathering their own data, which would have dramatically reduced reimbursements for psychological and neuropsychological testing services. We were also concerned that CMS might reduce the value of work assigned to testing services below those recommended by the RUC.
APA’s Practice Organization staff met repeatedly with CMS throughout the year to ask the agency not to make substantial cuts in testing service payments, and to convey the importance of testing services in caring for Medicare beneficiaries. We are gratified that CMS listened, and rejected the significant reductions in payments that had been under consideration.
In the proposed rule, however, CMS did not eliminate data-gathering payments, and slightly increased the work and practice expense rate valuations for testing services above the RUC recommendations. Based on a close examination of the proposal we project that the Medicare payment for a six-hour battery of psychological tests would increase 6.3%. The Medicare payment for a neuropsychological test conducted with the assistance of a technician would increase 6.8%, while the payment for a neuropsychological test conducted by a neuropsychologist her/himself would decrease by just over 3%. The reimbursement rate for a one-hour neuropsychological status exam would increase almost 2%, with reimbursements for a two-hour exam declining 5.3%. The reason for the decline in the two-hour exam is that under the new coding structure a neurobehavioral status exam taking longer than one hour will require two billing codes, with the code for the second and subsequent hours valued lower than the first. We are awaiting more information from CMS so that we can project payment rates for facility-based testing services.
We will be asking psychologists to provide comments to CMS on the proposed rule, specifically in an effort to preserve the higher than anticipated reimbursement for testing services. We will be sending out an action alert including suggested comments in the coming weeks. The proposed rule on the fee schedule is open for comment until September 10th.
APA hosted an hour-long webinar on the new testing code structure on Thursday, July 19th, which can be viewed at https://attendee.gotowebinar.c om/register/453011913926002918 7 (registration required). We will also conduct a symposium on the new testing codes at the APA Convention in San Francisco, on Saturday, August 11th from 2:00-3:50pm, in Moscone Center Room 207.
Psychotherapy Codes Receive a Modest Increase
For psychotherapy and health and behavior services the proposed rule shows very slight increases in non-facility practice expense (overhead) and malpractice expense. Payments for psychotherapy services would rise by 2% or slightly more, with payments for health and behavior services also receiving a slight increase.
Medicare Incentive-based Payment System (MIPS)
The proposed rule adds clinical psychologists to the list of eligible clinicians (ECs) for the Merit-based Incentive-based Payment System (MIPS) under Medicare’s Quality Payment Program starting on January 1, 2019. This means that psychologists reporting under MIPS would submit data in 2019 but would not experience a Medicare payment adjustment based on their reporting until 2021. By 2021 the payment adjustment for MIPS reporting will be at neutral or plus or minus 7 percent, depending upon whether an EC’s reporting is above or below average. We are requesting further information from CMS on how these provider comparisons will be made.
Psychologists should know that ECs who treat 200 or fewer Medicare beneficiaries, provide 200 or fewer covered professional services or bill Medicare for $90,000 or less will be exempt from reporting under the MIPS low volume threshold (LVT). We expect that many, if not most, psychologists will end up being exempt under the LVT.
Another change proposed by CMS for 2019 is to allow ECs to elect to report under MIPS if they are exempt under one or two but not all three prongs of the LVT criteria. Psychologists who meet one or two elements of the LVT criteria may wish to consider opting in to MIPS to pursue bonus payments. Psychologists who either do not fall under the LVT or who wish to exercise the option to report under MIPS should consider reporting through the Mental Health Behavioral Registry (MBHR), the first qualified clinical data registry designed by psychologists for mental and behavioral health professionals. For more information on the MBHR go to http://www.apapracticecentral. org/reimbursement/health-regis try/index.aspx.