CMS Final Rule 2024

[WisNeuro]

Calendar Year (CY) 2024 Medicare Physician Fee Schedule Final Rule | CMS

On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that announces finalized policy changes for Medicare payments under the Physician Fee Schedule (PFS), and other Medicare Part B issues, effective on or after January 1, 2024.

www.cms.gov

Looks like psychotherapy did well, but CMS gave a big F*ck You to seniors and others who need neuropsych testing by lowering the RVU conversion factor by 3.4% and leaving those RVUs untouched. Looks like the trend of less time towards clinical work and more time towards more lucrative assessment pursuits will continue, at the expense of necessary patient care. If you're wondering why it takes so long to get that referral for testing, look no further.

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[Sanman]

The last few years really has me questioning whether I would want to do much/any testing in private practice given the startup costs and reimbursement decreases. At least I can bill for caregiver training now.

 

[WisNeuro]

The last few years really has me questioning whether I would want to do much/any testing in private practice given the startup costs and reimbursement decreases. At least I can bill for caregiver training now.

It can still be lucrative for purely clinical, but that "worth it" bar keeps dropping every year of cuts due to inflation plus actual reimbursement cuts. It's why I only see 1-2 clinical patients a week. Non-clinical work is very plentiful for me right now, so it's getting harder and harder to justify spending as much time on clinical services.

 

[PsyDr]

Back of napkin math: with this pseudo “inflation”, the pay cut represents a ~12% loss.

 

[WisNeuro]

Back of napkin math: with this pseudo “inflation”, the pay cut represents a ~12% loss.

Meanwhile, I raised my forensic rates about 15% for 2024. You can imagine which appointments I will prioritize.

 

[medium rare]

I typically raise my fees every 2-3 years regardless of the economy. I’ve found private practice to be rather immune to larger economic factors - at least in my experience and that of several of my colleagues.

The last two major economic downturns (2009-2010 and 2020-2021) saw the demand for my services skyrocket and finances were not negatively impacted; in fact, the opposite was true. These days, I find my fee schedule helps to maintain treatment-motivated patients.

 

[WisNeuro]

I typically raise my fees every 2-3 years regardless of the economy. I’ve found private practice to be rather immune to larger economic factors - at least in my experience and that of several of my colleagues.

The last two major economic downturns (2009-2010 and 2020-2021) saw the demand for my services skyrocket and finances were not negatively impacted; in fact, the opposite was true. These days, I find my fee schedule helps to maintain treatment-motivated patients.

I've found that the majority of fixed income seniors are generally willing to wait 9+ months for a neuropsych eval paid for by Medicare, rather than pay out of pocket.

 

[PsyDr]

It’s not like we are in the “everything’s going great” business. When times are bad, we’re open for business.

 

[Sanman]

I've found that the majority of fixed income seniors are generally willing to wait 9+ months for a neuropsych eval paid for by Medicare, rather than pay out of pocket.

I am finding it very hard to see any justification for a lot of geriatric practice on the smaller scale other than to fill unpopular spots in the day.

 

[WisNeuro]

I am finding it very hard to see any justification for a lot of geriatric practice on the smaller scale other than to fill unpopular spots in the day.

I still do the evals because I enjoy them, and they're helpful. But, I have been decreasing the amount of time I spend doing these considerably through the years. So, my waitlist on the clinical side is getting lengthy.

 

[AcronymAllergy]

I still do the evals because I enjoy them, and they're helpful. But, I have been decreasing the amount of time I spend doing these considerably through the years. So, my waitlist on the clinical side is getting lengthy.

Same here, which is unfortunate.

 

[smalltownpsych]

I typically raise my fees every 2-3 years regardless of the economy. I’ve found private practice to be rather immune to larger economic factors - at least in my experience and that of several of my colleagues.

The last two major economic downturns (2009-2010 and 2020-2021) saw the demand for my services skyrocket and finances were not negatively impacted; in fact, the opposite was true. These days, I find my fee schedule helps to maintain treatment-motivated patients.

Lots and lots of money in medication. Whole different animal from insurance based assessment. I charge $2500 for an assessment that includes IQ and a personality assessment. I think it breaks out to be better than my 200 an hour goal I have which is the main reason I even take these on. I get very few takers because most people would rather wait for months for insurance to pay. I don’t know what insurance would pay someone to do the same thing. I charge 800 for ADHD eval and have had numerous calls but no takers over the last couple of years.

 

[cara susanna]

Were RVUs also lowered for non-neuoropsych testing? Like, the psychological testing codes?

 

[WisNeuro]

Were RVUs also lowered for non-neuoropsych testing? Like, the psychological testing codes?

Technically, the RVUs stayed the same, but they lowered the conversion factor, which pragmatically lowers reimbursement for any code that did not have its RVU adjusted upwards. It is my understanding that psych assessment codes were also unchanged, which means a double digit % decrease in reimbursement.

 

[PsyDr]

update:

"
CMS adopted several proposals that increase access to mental and behavioral health services furnished by psychologists. These include:

1. More appropriately valuing psychologists’ services. CMS will increase the work values used in calculating payments for both psychotherapy and health behavior assessment and intervention (HBAI) services by 19% over a four-year period and expressed interest in reviewing its methodology for estimating practice expenses for behavioral health services. APA will continue to advocate for increased work values for psychological and neuropsychological testing services.
2. Enabling ongoing access to behavioral health services furnished via telehealth. In 2024, CMS will continue reimbursing claims for telehealth services provided to patients in the patient’s home at the higher non-facility rate. Recognizing that mental health providers who furnish telehealth services to patients in their homes still bear the cost of maintaining private offices is critical to the future of telehealth coverage. CMS will continue to allow for psychological and neuropsychological testing services to be delivered via telehealth through the end of 2024.
3. Supporting population health-based approaches to treatment. CMS finalized coding and payment for a new code called “Social Determinants of Health Risk Assessment,” which serves as a review of a patient’s social risk factors that may influence diagnosis and treatment. Additionally, they finalized coding and payment for a related code for Principal Illness Navigation (PIN) for services that help patients, and their families navigate treatment for high-risk medical and behavioral health conditions. Originally, CMS proposed to limit these codes to evaluation and management (E&M) services, but thanks to your advocacy, CMS will allow these codes to be performed by a licensed psychologist and billed alongside behavioral health visits.
4. Enabling access to evidence-based behavior management training for caregivers. CMS agreed with your comments, acknowledged the critical role that caregivers have in a patient's overall care, and finalized its adoption of an active payment status for CPT codes 96202 and 96203: Multiple-family group behavior management/modification training for guardians/caregivers of patients with a mental or physical health diagnosis."

 

[texanpsychdoc]

I dont take insurance based testing referrals because I make more per hour doing therapy than I would doing testing.

 

[AcronymAllergy]

Yes, it's getting more difficult for psychologists/neuropsychologists to have 100% clinical assessment-based practices and make a reasonable living if doing their own testing. It's a bit more viable with psychometrists.