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As Joint Committee Struggles, CMS Releases 2012 Fee Schedule

U.S. CapitolAs you know, the APA Practice Organization has been hard at work on Capitol Hill to avert steep cuts to Medicare reimbursement for psychologists. The Joint Select Committee on Deficit Reduction, which faces a November 23 deadline to identify at least $1.2 trillion in debt savings, has clearly indicated that the future of Medicare is on the table.

There is much at stake for psychologists, including cuts resulting from the triple threat of the Sustainable Growth Rate, or SGR (previously estimated at 29.5% for 2012), expiration of the psychotherapy payment restoration (5% for 2012) and an additional 2% beginning in 2013 if the panel fails to reach a deal. APAPO has been hard at work on the legislative front, mobilizing more than 15,000 constituent messages through the Legislative Action Center, coordinating meetings of key contact psychologists with members of the Joint Committee in district and in DC and providing testimony to the House Ways and Means Committee.

While most eyes in Washington have been closely watching the Joint Committee, APAPO has also been awaiting the recent release of the Centers for Medicare and Medicaid Services (CMS) final rule on the 2012 Medicare Fee Schedule. The rule indicates several payment changes that are expected to impact reimbursement for psychological services.

Sustainable Growth Rate
CMS has recalculated the scheduled SGR cut’s estimated impact, reducing the projection to 27.4% (as opposed to 29.5%). Congress has blocked the SGR cut 12 times since 2001, and APAPO continues work with our allies among patients and providers to urge legislators to permanently replace the flawed formula and prevent the resulting reductions for 2012.

Practice Expense
In 2009 CMS announced changes beginning in 2010 to Medicare’s payments for the practice expense portion of numerous services including those commonly billed by psychologists. Members of more than fifty physician and non-physician organizations participated in a survey of the indirect costs associated with providing certain services, after which CMS began a four-year phase in of revised values. As a result, reimbursement for a few services commonly billed by psychologists have gone up, including psychological and neuropsychological testing by computer, while values for most other such services have gone down, including diagnostic interviews, psychotherapy and other forms of psychological and neuropsychological testing.

The rule projects a 3% overall reduction in reimbursement for psychological services in 2012, followed by a final 2% reduction when the phase-in completes in 2013. This reduction is not subject to change by Congress and would not be eliminated by any congressional action on the SGR or an extension of the psychotherapy payment restoration.

After reviewing the psychoanalysis code (90845) in September, the American Medical Association (AMA)/Specialty Society Relative Value Update Committee (RUC) recommended that the code’s work value be increased from 1.79 to 2.10. This change in the work value represents on average about $10 more for a single psychoanalysis session.

CMS, however, declined to adopt this recommendation for 2012 and is maintaining the code’s current value while other codes in the psychotherapy family are under review by the AMA’s CPT Editorial Panel. The federal agency stated that it wants to consider the value for the psychoanalysis code relative to any revised psychotherapy codes once their work values also have been reviewed by the RUC. CMS anticipates reviewing the psychotherapy family of codes, including psychoanalysis, for any changes in work values for 2013.

Physician Quality Reporting System
Since 2007, Medicare has offered incentive payments to eligible professionals, including psychologists, who report data on designated outpatient service measures as part of a program known as the Physician Quality Reporting System. The 2012 final Medicare fee schedule rule contains several changes pertaining to the PQRS:

    • CMS is eliminating the 6-month reporting period for individual measures reported through claims or a registry based on the rationale that data from a 12-month reporting period is more meaningful to patient experience and care. The 6-month reporting period will still be allowed for measures groups that are reported through a registry.
    • A new measures group for dementia has been created that can only be reported through a registry due to the way in which the measures must be analyzed.
    • The incentive payment for eligible professionals who successfully report on PQRS measures in 2012 will be 0.5% of all allowed Medicare charges.
    • The measures most commonly reported by psychologists will continue to be part of the PQRS in 2012. These measures are:
      • # 9 – Major Depressive Disorder: Antidepressant Medication During Acute Phase for Patients with MDD
      • #106 – Major Depressive Disorder: Diagnostic Evaluation
      • #107 – Major Depressive Disorder: Suicide Risk Assessment
      • #128 – Preventive Care and Screening: Body Mass Index Screening and Follow-Up
      • #130 – Documentation of Current Medications in the Medical Record
      • #131 – Pain Assessment Prior to Initiation of Patient Therapy and Follow-Up
      • #134 – Screening for Clinical Depression and Follow-Up Plan
      • #173 – Preventive Care and Screening: Unhealthy Alcohol Use – Screening
      • #181 – Elder Maltreatment Screen and Follow-Up Plan
      • #226 – Measure pair: a. Tobacco Use Assessment, b. Tobacco Cessation Intervention

As you know, Medicare reimbursement remains a top priority of the APA Practice Organization. As challenges and opportunities arise, APAPO will continue to press at both the legislative and regulatory levels for the professional interests of psychologists. We have much work left to ensure psychology has a fighting chance to avert the SGR cut, extend the psychotherapy payment restoration through 2012 and prevent other reductions in psychologist reimbursement. We will keep you posted as your grassroots assistance is needed. Thanks for your ongoing support.

Jeff Cook, J.D.
Director of Field & State Operations
American Psychological Association Practice Organization
750 First Street, NE Washington, DC 20002
(202) 336-5875 (Office)
(202) 336-5797 (Fax) (click to verify and reveal email)

Republished with permission: APAPO

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