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Date:August 27, 2018To:SPTA and Division Federal Advocacy Coordinators, and APAGS CoordinatorsFrom:Doug Walter, J.D., Associate Executive Director for Government Relations, American Psychological Association Practice OrganizationCc:Jared L. Skillings, PhD, ABPP, Chief of Professional PracticeSPTA Directors of Professional AffairsSPTA Executive DirectorsCAPPAPAPO Board of DirectorsRe:Psychologists providing testing services in Medicare urged to provide comments to CMSThis action alert regards the Centers for Medicare and Medicaid Services (CMS) proposed rule on the 2019 Medicare Physician Fee Schedule for psychological and neuropsychological testing services. To preserve the higher than anticipated reimbursement, we are asking psychologists who provide testing services in Medicare to submit comments to CMS on the proposed rule. The Practice Organization will submit a comment letter to CMS on the proposed rule and is encouraging psychologists to submit their own comments. The public comment period closes on September 10th. To recap, the testing codes were significantly revised by the AMA Current Procedural Terminology (CPT?) and revalued by the Resource Based Relative Value Update Committees (RUC). The Practice Organization met repeatedly with CMS to convey the importance of testing services in caring for Medicare beneficiaries and to persuade the agency not to make double-digit cuts in testing service reimbursement rates. CMS heard us! They did not eliminate data-gathering payments, and slightly increased the work and practice-expense rate valuations for testing services. If adopted under the proposed rule, we project that the Medicare payment for a six-hour battery of psychological tests would increase 6.3%. Payment for a typical neuropsychological test battery conducted with the assistance of a technician would increase 6.8%, while the payment for a neuropsychological test battery 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 still awaiting more information from CMS so that we can project payment rates for facility-based testing services.Below is sample language for commenting to CMS. Feel free to copy the sample text below onto your letterhead. Please note the areas in the text to personalize your comments by describing your experience in providing psychological or neuropsychological testing and its importance to your patients. [SAMPLE COMMENT]As a psychologist who provides [psychological/neuropsychological] testing services to Medicare patients, I am writing to comment on your agency’s proposed Medicare Physician Fee Schedule for 2019, and its effect on both psychologists like me and on my patients.? [Include short description of your practice with Medicare patients, such as “I am a neuropsychologist practicing in Iowa, and I see Medicare patients almost every week who need testing services for dementia.? I am one of the only providers of these services in my area.”]It is my understanding that most psychologists will see payment increases for a battery of testing services, and I urge you to preserve these rates in the final rule.? This is important, because as you know, psychologists have faced more than a decade of reimbursement rate cuts for their services.?Most importantly, this is extremely timely given the critical role that these services will play as our elderly population continues to grow.This said, I understand that some psychologists will see slight decreases for neuropsychological testing services due to a new coding structure that aligns psychological and neuropsychological testing services with other testing services in the program.? While I am disappointed in this aspect, I am pleased that your agency increased testing reimbursement rates above levels recommended by the AMA Relative Value Scale Update Committee.? In the future, I urge you to work toward higher reimbursement rates for these services.Mental health and substance use disorders are taking a heavy toll on Medicare beneficiaries, and I believe that increasing access to psychological and behavioral health services will both improve outcomes and reduce overall spending.? [Include personal examples of your work.]Thank you for considering my views on this issue.Sincerely, To submit your comments please follow the link here and click the Comment Now button on the top right hand corner of the screen. On the next page please input your comment and fill out the required information. Make sure the box titled “I am submitting on behalf of a third party” is NOT checked. CMS is looking for input from providers and your individual voices carry as much weight as third-party comments. For more information, contact APA Practice Organization Government Relations Office at Pracgovt@ or (202) 336-5889. Visit APA Practice Organization on-line at Advocacy. ................
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