Webinar 7/19: Medicare billing structure and process for testing services
News Date: Wednesday, July 18, 2018 - 17:45
Here is an informational update derived from an APAPO post on some important practice matters -
The Centers for Medicare and Medicaid Services (CMS) recently released its proposed rule on the 2019 Medicare Physician Fee Schedule. The proposal includes a significant reconfiguration in coding and billing for psychological and neuropsychological testing services, because the existing codes have presented challenges for not only psychologists and neuropsychologists but also for Medicare and third-party payers. In the current proposal, reimbursements under the new coding structure will vary; payments for some testing services should increase, but others could decline by 10% or more. APAPO is analyzing the proposed rule and will provide more detailed information in a future alert.
In 2013 and 2015 psychological and neuropsychological testing services were targeted by CMS as a potential way for the federal government to reduce health care costs. This required the services to be redefined and revalued through the highly confidential AMA Current Procedural Terminology (CPT®) and Resource Based Relative Value Update Committee (RUC) processes. The CPT and RUC advise CMS on how services are valued.
CMS is aligning psychologists' and neuropsychologists’ testing payment policies with those for other providers. According to the CMS proposal, "[t]his new coding effectively unbundles codes that currently report the full course of testing into separate codes for testing administration…and evaluation." By doing this, the new coding structure eliminates ongoing CMS and commercial payer concerns with payments for technician services under the current codes. In addition, the new structure eliminates duplicative payments for pre- and post-services for each hour of testing.
APA Practice Organization staff worked throughout the year, meeting repeatedly with CMS staff to advocate for the value of neuropsychological and psychological services. They prevented devastating reimbursement cuts which would have resulted from the potential elimination of payments to psychologists and neuropsychologists when they gather their own test data. This would have meant a 44% loss in payments for a typical testing battery.
In the proposed rule CMS acknowledged the value of psychological and neuropsychological testing services for Medicare beneficiaries. Consequently, CMS is proposing an increase in valuation (relative value units, or RVUs) for the professional services codes above the already-increased values that the RUC had recommended. Additionally, CMS restored payments for some testing overhead costs that were eliminated by the RUC, in order to “mitigate potentially destabilizing payment reductions for these services.”
The
proposed rule containing the testing code and other fee schedule changes for psychological services will be open for comment until September 10
th. The APAPO will soon be providing an additional information on all aspects of the proposed rule relevant to psychologists that may be helpful to consider in your thinking about this matter.
APAPO will host a webinar on the new billing structure and process for testing services next Thursday, July 19th at 11:30 a.m. Eastern. You can register at this link:
In San Francisco@ the APA Convention, they also will conduct a symposium on the new testing codes Saturday, August 11th from 2:00-3:50pm, in Moscone Center Room 207.
