2015 Medicare Physician Fee Schedule Proposed Rule Released
Thursday, August 7, 2014
Posted by: Amy Dietrich
On July 3, 2014 the Centers for Medicare and Medicaid Services (CMS) released the proposed rule (published in the July 11th Federal Register) on the 2015 Medicare fee schedule. APAPO anticipates submitting comments on the proposed rule on or before September 2nd. While APAPO and the APA Office of Healthcare Finance are still reviewing the proposed rule here are some of the key changes that could impact psychologists in 2015:
1. Projected Reimbursement Changes
Medicare’s reimbursement pool for psychological services is anticipated to drop on average by about 1% in 2015 due to adjustments in practice expense. Ninety percent of Medicare providers will see a +1% to -1% payment adjustment. Audiology, chiropractic, cardiac surgery, social work, and interventional radiology will also receive 1% less in 2015, while 24 specialties, including psychiatry, will remain flat at 0%. Independent laboratory services will receive the largest positive adjustment of 3%, while the biggest losses will be to radiation oncology (-4%) and radiation therapy centers (-8%).
As you know and with your help, APAPO with other Medicare providers successfully advocated to avert a substantial payment reduction associated with the sustainable growth rate (SGR) formula (see April 1, 2014 Information Alert). Under the Protecting Access to Medicare Act of 2014 (PAMA) the potential impact of the sustainable growth rate (SGR) will not take effect until April 1, 2015. PAMA ensures a 0% update for January 1, 2015 – March 31, 2015, but CMS is projecting a -20.9% reduction after that if Congress does not take action. APAPO will again seek your help to again avert the SGR payment reduction from taking place, and we continue our advocacy for a permanent repeal of the SGR.
2. Potential Codes for Review in 2015
CMS must periodically examine the work values for all codes to determine if they are “potentially misvalued.” When doing so CMS prioritizes high expenditure codes (costing Medicare $10 million or more annually) whose values have not been reviewed in over 5 years. Because of the length of time since their last reviews the codes may require changes in their work values and updates to the practice expense inputs.
In this proposed rule CMS identifies 65 codes as being potentially misvalued including 96101 (psychological testing by a professional) and 96118 (neuropsychological testing by a professional), both of which were last reviewed in 2005. APAPO will keep psychologists informed of future activity, if any, required by CMS of psychology involving these testing codes.
3. Additional Telehealth Services for Mental Health
CMS is proposing to add three psychiatric procedure codes to Medicare’s list of telehealth services: codes 90845 (psychoanalysis), 90846 (family psychotherapy without the patient), and 90847 (family psychotherapy with the patient). The agency stated in the proposed rule that these three services are similar to other psychiatric services that already qualify as telehealth.
CMS rejected the idea of adding psychological testing (96101 and 96102) and neuropsychological testing (96118 and 96119) to telehealth because these services require close observation of how a patient responds while undergoing testing.
Medicare’s specific telehealth requirements must be met in order to be reimbursed for telehealth services. Communication by telephone does not qualify as telehealth.
4. The Physician Quality Reporting System (PQRS)
CMS is proposing a number of changes to PQRS in 2015 but unlike in past years the agency is not seeking to eliminate the claims-based reporting mechanism. The agency is planning a number of changes, including adding new measures and removing others that may no longer be of use to PQRS. After completing its analysis of the proposed rule APAPO will have further information on the various proposed changes to PQRS.
5. Expansion of the Value-Based Payment Modifier
CMS is planning to exercise its authority to extend the use of the value-based payment modifier (VM) to services provided by non-physician eligible professionals including psychologists in 2017. Currently the VM is only applied to payments for physicians and physician groups. The VM provides for differential payment under the Medicare fee schedule to a provider or a group of providers based upon the quality of care furnished compared to cost during a performance period. APAPO will provide more explanation of the VM and its potential impact on psychologists in Medicare in future communications.
APAPO and the APA Office of Healthcare Finance will continue to keep members up-to-date as the proposed rule is fully reviewed. An additional information alert will be sent with the APAPO comment letter once all comments have been submitted to CMS.
Jennifer F. Kelly, PhD, ABPP
Federal Advocacy Coordinator
Georgia Psychological Association