The 2019 Medicare Physician Fee Schedule Final Rule was published at the Federal Register this week, and includes major changes in how psychological testing codes will be handled, changes
that Dr. Tony Puente, Past-President of the American Psychological Association, says are “…the biggest paradigm shift since the development of testing.” Puente presented at the annual  conference of the National Association of Neuropsychology last month held in New Orleans.

Dr. Kim Van Geffen, Director and Chair of Professional Affairs for the Louisiana Psychological
Association, explained that these changes are important for psychologists to understand.  “Beginning on January 1, 2019,” she said, “psychologists who bill insurance companies will be required to use a new set of CPT codes for billing psychological and neuropsychological testing,”
Van Geffen said.

“These codes, which were developed with input from the American Psychological Association,  ill greatly change the way assessments are billed,” Van Geffen said. “The new codes will include base codes and ‘add on’ codes and will distinguish technical work, such as administration and
scoring of tests, from professional work, such as integration and interpretation of evaluation data, clinical decision making and treatment planning. Both types of services will be billed with different codes.”

The CMS final rule updates payment policies, payment rates, and other provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after Jan. 1, 2019, noted CMS. In addition to policies affecting the calculation of payment rates, this final rule finalizes a number of documentation, coding, and payment changes to reduce administrative burden and
improve payment accuracy for office/outpatient evaluation and management (E/M) visits over
several years, according to the announcement.

CMS officials also said that through an interim final rule with comment period, CMS is implementing a provision from the Substance Use-Disorder Prevention that Promotes Opioid
Recovery and Treatment (SUPPORT) for Patients and Communities Act that expands access to telehealth services furnished for purposes of treatment of a substance use disorder or a co-occurring mental health disorder for services furnished on or after July 1, 2019. CMS will accept comments on the interim final rule until December 31, 2018.

All releases about the Rule can be reviewed as CMS.gov.

In a series of recent announcements over the last months, Doug Walter, JD, Associate Executive Director for Government Relations, American Psychological Association Practice Organization, alerted psychologists that the Centers for Medicare and Medicaid Services (CMS) released its proposed changes on the 2019 Fee Schedule.

CMS had targeted the codes for revisions and asked the American Medical Association’s CTP® and RUC (Relative Value Update) Committees to restructure and revalue the testing codes. Doug
Walter, JD, Associate Executive Director for Government Relations, American Psychological Association Practice Organization, alerted psychologists to the proposed changes.

CMS had targeted the services because the claims had exceeded $10 million, up to $42 million in 2016, according to Puente. CMS considered the services to be overvalued and targeted them for revision and review.

Walter said APA’s Practice Organization staff had met repeatedly with CMS throughout the year to ask the agency not to make substantial cuts in testing service payments. “We are gratified that CMS listened, and rejected the significant reductions in payments that had been under consideration…” They prevented  4% cuts that would have come when psychologists collect their own test data, APA officials said.

Van Geffen will be conducting on-line training for LPA members and other psychologists in the next few weeks, she said. “These new testing codes represent significant changes in the way in
which psychologists code their testing services. Dr. Tony Puente, former APA President, refers to them as a ‘paradigm shift.'”

“Under the current Medicare regulations,” Van Geffen said, “psychologists are viewed as ‘technicians’ which means that our services are not financially valued for the cognitive work
which we do as a part of our assessments. The new codes represent a move toward
psychologists being paid for cognitive work.”

Although the codes will be somewhat complicated to learn initially, they will ultimately be a
valuable change in the reimbursement landscape,” Dr. Van Geffen explained.

In the most recent announcement, Walter wrote, “Based on a close examination of the proposal we project that the Medicare payment for a six-hour battery of psychological tests would increase 6.3%. The Medicare payment for a neuropsychological test conducted with the assistance of a technician would increase 6.8%, while the payment for a neuropsychological test
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%