On November 2, 2016 the Centers for Medicare and Medicaid Services (CMS) released the final rule on the 2017 Medicare physician fee schedule. In addition to providing information on 2017 payment changes the final rule also discusses key decisions by the agency regarding coverage for new services and other issues raised in the proposed rule.
Thanks to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), psychologists treating Medicare beneficiaries no longer risk facing huge reductions in payment each year. MACRA repealed the troublesome Sustainable Growth Rate from the payment formula and instituted specified percent changes for 2015 and beyond. For 2017 the update will be a positive 0.5% before other adjustments are applied.
For psychologists, it is these other adjustments that will have the greatest impact on their final payments in 2017. All providers continue to lose 2% each year under sequestration, the automatic budget cuts put in place by Congress since 2013. In addition, psychologists who did not successfully report measures under the Physician Quality Reporting System (PQRS) in 2015 will lose an additional 2% on all of their Medicare charges. Consequently, psychologists who are subject to both of these adjustments will see a reduction of 3.5% in 2017. Those who successfully reported under PQRS in 2015 will see a 1.5% reduction.
CMS projects there will be no impact on psychologists’ payments due to relative value changes to work, practice expense, or malpractice expense for the codes psychologists typically bill.
Other key elements in the final rule
As it did last year CMS declined to add the psychological and neuropsychological testing codes to its list of telehealth services. CMS’s rationale is that successful completion of the tests requires the psychologist to closely observe the patient’s response, something that cannot be done through telehealth in their current opinion.
New Codes for Behavioral Health Integration
CMS has added several new codes to the 2017 fee schedule to capture services under the Psychiatric Collaborative Care Model (CoCM) in which a primary care team consisting of a primary care provider and a care manager work in collaboration with a psychiatric consultant, such as a psychiatrist. These codes are temporary and will be replaced in 2018 by codes created through the American Medical Association’s Current Procedural Terminology (CPT).
Psychologists cannot bill the codes created for this model (G0502, -03, and -04) because the services involve evaluation and management (E/M) but they can provide behavioral care management services. CMS has made some changes to what was in the proposed rule so now the behavioral care manager does not have to be an employee of the primary care provider and may furnish services remotely.
In addition to codes for the Psychiatric CoCM, CMS is also adding a code, G0507, for other BHI (behavioral health integration) models of care. Unfortunately for psychologists the agency is limiting direct billing of this code to physicians and other health care professionals who can provide the BHI initiating visit, something CMS maintains is not within a psychologist’s scope of practice. While CMS expresses interest in adding more codes for services by psychologists and social workers any new codes would have to be under a different construct because of BHI’s link to E/M services.
CMS’s long-standing prohibition against psychologists billing for E/M services continues to thwart psychologists’ efforts to fully participate in behavioral health integration.
Assessment and Care Planning for Patients with Cognitive Impairment
CMS has also created a new temporary code, G0505, to capture services by a physician or other healthcare professional such as a nurse practitioner or physician assistant, to assess and create a care plan for beneficiaries with cognitive impairment. Although CMS acknowledged the work of psychologists and neuropsychologists in treating beneficiaries with cognitive impairment the agency views G0505 as a service that must be performed by the billing practitioner subject to established E/M guidelines.
The code did not do a great job of differentiating between brief screenings and comprehensive testing to enable the presence and staging of dementia. CMS states that in the final rule’s preamble, this code describes a distinct service that may be reasonable and necessary to diagnose and treat the beneficiary’s illness.