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APAPO Responds to the 2015 Physician Fee Schedule Proposed Rule

Tuesday, September 02, 2014   (0 Comments)
Posted by: Amy Dietrich

This week the American Psychological Association Practice Organization (APAPO) submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s proposed rule on the 2015 Medicare physician fee schedule.

In APAPO’s latest effort to fight for psychology’s interests against the ongoing challenges facing Medicare reimbursement, the comment letter focuses on the need to ensure fair reimbursement for and equitable treatment of psychologists in Medicare. The letter from Katherine Nordal Ph.D., Executive Director for Professional Practice, highlights key areas in the proposed rule that will impact the future participation of psychologists in the program. These key areas include:

  •  A 1% projected reimbursement loss due to practice expense changes. CMS is projecting a 1% decrease in allowed charges for clinical psychologists in 2015, with all of the loss being attributed to changes in the relative value units (RVUs) for practice expense. APAPO states that this latest cutback will drive more psychologists to opt out the Medicare program.
  • Modifying the process for establishing code values. Currently the CPT and RUC process coding cycle is divided into a few review phases. The coding cycle is comprised of committee reviews, recommendation submission, submission review, and code value generation, including a series of CPT and RUC meetings. The proposed rule is working to streamline the workflow between the CPT and RUC process to make all reviews and evaluations efficient and allow adequate review time for code evaluation. APAPO supports re-timing for the CPT (coding) and RUC (reimbursement) processes. In a joint statement submitted along with 70 other specialty societies, APAPO encourages CMS to start a new timing with the 2017 cycle to allow petitioners full participation in the process.
  • Reviewing select testing codes. CMS proposes to include CPT codes 96101 and 96118 on its list of 65 potentially misvalued codes. These codes each have over $10 million in Medicare allowed charges, one of the metrics that CMS uses to identify services that may be incorrectly priced (either too low or too high). APAPO informed CMS that it intends to bring the two codes first to CPT and then to RUC for review.
  • Additional telehealth services. APAPO commends CMS for adding codes 90845 (psychoanalysis), 90846 (family psychotherapy without the patient), and 90847 (family psychotherapy with the patient) to the list of recognized telehealth services.The addition of these mental health services to Medicare’s telehealth program will help address critical needs for beneficiaries who have difficulty accessing mental health treatment.
  • The Physician Quality Reporting System (PQRS)
    o   Claims-based reporting: APAPO applauds CMS for not proposing any further changes to the claims-based reporting method in 2015.
    o   Cross-cutting measures: APAPO questions the need for requiring that eligible professionals (EPs) who have a face-to-face encounter with a patient must include two cross-cutting measures in their PQRS reporting. This could be difficult for specialties providing a limited number of services, such as mental health providers.
    o   New measures: APAPO supports adding three new measures relevant to mental health providers but asks CMS to make a critical change. The new measures are:
  • Adherence to Antipsychotic Medications for Individuals with Schizophrenia
  • Adherence to Mood Stabilizers for Individuals with Bipolar I Disorder
  • Follow-Up after Hospitalization for Mental Illness

Critical Change: Only one of the three measures, Adherence to Mood Stabilizers for Individuals with Bipolar I Disorder, is designated for use with claims-based reporting. APAPO is asking CMS to revise its proposal so that all three of these new mental health measures can be reported through claims as well as through registries.

  • The Value-Based Payment Modifier. CMS is proposing to apply a value-based payment modifier (VM) when determining payments for all physicians and non-physician EPs, including those in solo and small group practices (under 10), in 2017. CMS will first apply the VM to physicians in large groups of 100 or more EPs in 2015. In 2016 the VM applies to physicians in groups of 10 or more EPs.APAPO agrees that physicians and non-physicians should be treated equally under the VM and supports having no downward adjustments in 2017 for solo and small group practitioners who will have the VM applied to their payments for the first time.

APAPO did express concern over how CMS will determine VM adjustments based on quality and cost measures for solo and small group practitioners who furnish only a limited number of services and have few PQRS measures to choose from. APAPO will continue to monitor how CMS implements the VM and how the agency will calculate cost composite scores and determine future VM adjustments for solo and small group practitioners.

The full comment letter submitted to CMS is available on the legislative advocacy center. You can locate that page at

Medicare reimbursement remains a top priority of the APA Practice Organization. As challenges and opportunities arise, APAPO will continue to address these issues on the legislative and regulatory levels for the professional interests of psychologists.

The final rule is expected to be released in early November. APAPO will continue to keep members informed about our advocacy efforts to protect psychologists’ reimbursement and related developments throughout the remainder of 2014. 

Jennifer F. Kelly, PhD, ABPP
Federal Advocacy Coordinator

Georgia Psychological Association