CMS Cuts

[WisNeuro]

So, CMS is looking to cut most of our codes by 11%. We are currently in the open comment period for this, and are falling behind nationally on goals for number of people commenting. This most likely directly affects all of you, or will eventually (students, interns, postdocs), so please take the couple minutes to use the link and leave a comment about these cuts and your opposition. APA provides a cut and paste template, but please personalize it to your specific situation.

Act now to safeguard psychological and behavioral health services

You can help prevent proposed Medicare cuts to reimbursement and coverage of psychological services for older adults and people with disabilities.

www.apaservices.org

PLEASE do this before October 5th, when the comment period ends.

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[PsyDr]

So, CMS is looking to cut most of our codes by 11%. We are currently in the open comment period for this, and are falling behind nationally on goals for number of people commenting. This most likely directly affects all of you, or will eventually (students, interns, postdocs), so please take the couple minutes to use the link and leave a comment about these cuts and your opposition. APA provides a cut and paste template, but please personalize it to your specific situation.

Act now to safeguard psychological and behavioral health services

You can help prevent proposed Medicare cuts to reimbursement and coverage of psychological services for older adults and people with disabilities.

www.apaservices.org

PLEASE do this before October 5th, when the comment period ends.

Done!

 

[DynamicDidactic]

Scope of Practice
I have significant concerns regarding the CMS proposal to allow the supervision of psychological and neuropsychological testing by non-physician providers (e.g., nurse practitioners, physician assistants). This expansion should not be allowed without knowing what tests are being given, which auxiliary staff they are supervising, and whether such individuals are appropriately trained to administer psychological and neuropsychological training.

I strongly recommend that CMS allow psychologists to practice to the full extent of their licensure and scope, as the agency has done for other types of clinicians this year. Specifically, CMS should eliminate unnecessary physician supervision requirements for all psychologists in all settings and allow psychologists with prescriptive authority in their state to bill for evaluation and management services, just as they do for private insurance and Medicaid for psychotropic mediation management. Lastly, CMS should allow for reimbursement of services psychologists routinely provide but cannot bill because of the placement of the codes in the CPT manual or outdated CMS regulation, for example smoking cessation codes (99406 & 99407) and intensive behavioral obesity treatment (G0447 & G0473)."

So much stuff lumped together here.

Is CMS wanting PAs and ANPs to supervise psychological testing? Who would they be supervising, other PAs and nurses or psychology trainees? That sounds loony.

Not sure how I feel about RxP.

So, CMS doesn't want psychologists to be reimbursed for smoking cessation or obesity treatment?

 

[WisNeuro]

So much stuff lumped together here.

Is CMS wanting PAs and ANPs to supervise psychological testing? Who would they be supervising, other PAs and nurses or psychology trainees? That sounds loony.

Not sure how I feel about RxP.

So, CMS doesn't want psychologists to be reimbursed for smoking cessation or obesity treatment?

I'll take these in turn.

Yes, CMS proposals would allow PA and NPs to supervise practitioners doing psych testing codes. As of now, these codes are not unique to psychologists.

The RxP stuff only mentions that in states where it is a law. Otherwise it is referencing the CMS physician designation, which people misunderstand often.

And yes, as of now, no one is really getting reimbursed by those codes, we would like them to be reimbursable, pragmatically.

Also, it's lumped in there together because CMS makes a boatload of changes, these just happen to be the ones that directly affect us collected together.

 

[AcronymAllergy]

You can pick and choose which pre-fab statements from APA you might want to insert (I did), if you want to edit them (I also did), and if there's anything unique to you that you'd want to add. That seemed to work well for me.

 

[WisNeuro]

You can pick and choose which pre-fab statements from APA you might want to insert (I did), if you want to edit them (I also did), and if there's anything unique to you that you'd want to add. That seemed to work well for me.

Exactly, I personalized it for my specific situation and work.

 

[Justanothergrad]

done

 

[Sanman]

Yeah, I sent in my comments a week or two ago. It was quite depressing.

 

[WisNeuro]

Thanks all, let's keep up the good work!

 

[thebalmofhurtminds]

APA also has options to send templated (personalized, if you'd like) e-mails to your state representatives as well. If anyone is looking for additional options.

 

[SportsNeuroPsych]

Done - also shared with other colleagues. Aside from the proposed cuts, this whole thing about PAs and NPs supervising our work is infuriating.

 

[R. Matey]

Done!

 

[ExecutiveDysfunction]

The RxP stuff only mentions that in states where it is a law. Otherwise it is referencing the CMS physician designation, which people misunderstand often.

Super early-career psychologist here.

If you have the time, I’d love to hear more about the physician designation. I read a little of it on the psychiatry board, but still don’t fully understand the argument for it.

 

[PsyDr]

Super early-career psychologist here.

If you have the time, I’d love to hear more about the physician designation. I read a little of it on the psychiatry board, but still don’t fully understand the argument for it.

Simple:

1) Would you like to be able to bill Medicare without having a referral or supervision:

Yes OR No?

2) If YES, would you care if CMS called you “Princess Vonwolfenstein” in their internal paperwork?

If they did, would any reasonable person think you are actually entitled to the benefits of being a princess?

3) Now change the word “princess ” to “physician” in #2. Change anything?


More detailed:

1) CMS = Medicare central office. Federal, so it’s changed by laws, not policy.

2) Most private insurances sorta follow CMS’ lead (e.g., Medicare says they can pay differently for inpatient vs outpatient work, so BCBS says so too).

3) Like any insurance company, CMS has all sorts of weird rules. When you sign up as a CMS provider, you agree to abide by their rules.

4) CMS’ rules define how providers can bill for their services.

5) In those internal rules, CMS uses the term “physician” in a SUPER weird way.

6) In CMS, the term “physician” has nothing to do with a providers profession, specialty, setting, license, etc. It ONLY means “person who can just send us a bill.”. MDs, DOs, DMDs, DCs, and ODs are “physicians” in CMS. Nothing else. Yes, that means that MBBSes are not physicians according to CMS.

7) CMS uses a specific billing form.

8) On that billing form, you have to choose if you are or are not a “physician”. If you check this, you still have to tell them if you are a chiropractor or an optometrist

9) If you check that you are not a “physician”, CMS asks “what physician is supervising you or referring the patient to you”. You have to document this.

10) Imagine if you’re in a traditional psychotherapy based PP. Patient calls you, they comes in, he/she has Medicare. CMS now requires that you try to contact the patient’s physician, and document if you get in touch or not. Or you have to call the physicians office and say, “hey, send me a referral so I can see this patient”. PCP doesn’t need the extra paperwork and/or potential liability. You don’t need it. It is nonsense.

Now ask why anyone would want to block this?

 

[ExecutiveDysfunction]

Simple:

1) Would you like to be able to bill Medicare without having a referral or supervision:

Yes OR No?

2) If YES, would you care if CMS called you “Princess Vonwolfenstein” in their internal paperwork?

If they did, would any reasonable person think you are actually entitled to the benefits of being a princess?

3) Now change “princess ” to “physician” in #2.


More detailed:

1) CMS = Medicare central office. Federal.

2) Most private insurances sorta follow CMS’ lead (e.g., Medicare says they can pay differently for inpatient vs outpatient work, so BCBS says so too).

3) Like any insurance company, CMS has all sorts of weird rules. When you sign up as a CMS provider, you agree to abide by their rules.

4) CMS’ rules define how providers can bill for their services.

5) In those intenralrules CMS uses the term “physician” in a SUPER weird way.

6) In CMS, the term “physician” has nothing to do with a providers profession, specialty, setting, license, etc. It ONLY means “person who can just send us a bill.”. MDs, DOs, DMDs, DCs, and ODs are “physicians” in CMS. Nothing else. Yes, that means that MBBSes are not physicians according to CMs.

7) CMS uses a specific billing form.

8) On that billing form, you have to choose if you are or are not a “physician”.

9) If you check that you are not a physician, CMS asks “what physician is supervising you or referring the patient to you”. You have to document this.

10) Imagine if you’re in a traditional psychotherapy based PP. Patient calls you, they comes in, he/she has Medicare. CMS now requires that you try to contact the patient’s physician, and document if you get in touch or not. Or you have to call the physicians office and say, “hey, send me a referral so I can see this patient”. PCP doesn’t need the extra paperwork and/or potential liability. You don’t need it. It is nonsense.

I guess I realize I’ve never seen a Medicare pt for neuropsych that wasn’t referred by a physician, so I never realized. Thanks for the explanation !

 

[WisNeuro]

Now ask why anyone would want to block this?

Because certain organizations like to waste money on stupid turf wars that don't change anything, while they continually lose ground to PAs and NPs?

 

[PsychPhDone]

I'm in VA and thus sheltered from some of this stuff in terms of billing. I use 90832-37 the vast majority of the time, sometimes health and behavior codes. Please help me understand how life could be different if I use E/M codes - would it be more relevant if I spent time talking about med compliance? Which codes that psychology uses are getting cuts - testing?

 

[WisNeuro]

I'm in VA and thus sheltered from some of this stuff in terms of billing. I use 90832-37 the vast majority of the time, sometimes health and behavior codes. Please help me understand how life could be different if I use E/M codes - would it be more relevant if I spent time talking about med compliance? Which codes that psychology uses are getting cuts - testing?

This won't matter much to VA psychologists, in the short-term, anyway. Your billing is merely a way to track productivity for the most part, it's all monopoly money for you.

They're essentially cutting most MH codes that are not E/M based. They are then proposing to raise some (therapy, psych eval), but not enough to offset losses. This still matters to VA psychologists for a couple of reasons. 1) If/when you leave the VA, because most of us do, you'll be faced with billing issues. 2) If psychologists salaries decline enough, the VA can technically re-characterize psychologists in the GS system to be commensurate with community providers.

 

[Sanman]

I'm in VA and thus sheltered from some of this stuff in terms of billing. I use 90832-37 the vast majority of the time, sometimes health and behavior codes. Please help me understand how life could be different if I use E/M codes - would it be more relevant if I spent time talking about med compliance? Which codes that psychology uses are getting cuts - testing?

This article has some good examples of when E/M codes might come in handy.

Medicare acknowledgement of psychologists' evaluation/management services

 

[Ollie123]

Done. Flood their inbaskets and get your colleagues to do so too!

 

[PsychPhDone]

This won't matter much to VA psychologists, in the short-term, anyway. Your billing is merely a way to track productivity for the most part, it's all monopoly money for you.

They're essentially cutting most MH codes that are not E/M based. They are then proposing to raise some (therapy, psych eval), but not enough to offset losses. This still matters to VA psychologists for a couple of reasons. 1) If/when you leave the VA, because most of us do, you'll be faced with billing issues. 2) If psychologists salaries decline enough, the VA can technically re-characterize psychologists in the GS system to be commensurate with community providers.

Thanks. I certainly care about my colleagues in PP so I'm just trying to understand more about which codes get used in other settings.

 

[CheetahGirl]

Done. Personalized the text they provided with my concerns re: COVID-19 and our Global Pandemic.

 

[WisNeuro]

Thanks. I certainly care about my colleagues in PP so I'm just trying to understand more about which codes get used in other settings.

Theoretically, we should be using the same codes for the same services, VA or outside of VA. Y'all in the VA just don't have to worry about which insurers only pay for 45 minute sessions vs who will pay for 60. Or when you use 90791 vs 96116, etc. We just have to work with coders to clarify things and documentation, vs. no one really getting feedback if they used the wrong code or documented something incorrectly in most VA settings.

 

[BorderlineQueen]

Because certain organizations like to waste money on stupid turf wars that don't change anything, while they continually lose ground to PAs and NPs?

Very true just recently California passed a bill allowing NPs to practice unsupervised.