Medicare Fee Schedule Has Good News for Psychiatry

Psychiatry appears to benefit in some significant ways in the 2018 proposed Medicare Physician Fee Schedule, released last month by the Centers for Medicare and Medicaid Services.

Highlights of the fee schedule include a proposal that, if approved, would substantially increase payments for conditions commonly treated by mental health professionals; adoption of new CPT codes for collaborative care services, as well as a proposal to pay for these services in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs); and a call to revise the Evaluation and Management Guidelines as a way to reduce administrative burdens to physicians.

APA staff will be reviewing the rule in detail and drafting comments with input from APA components and member experts sometime later this month. However, initial analysis indicates that the schedule includes several proposed changes that represent potential increases in reimbursement for psychiatrists and other mental health practitioners.

Here are the key proposals related to payments to psychiatrists:

• CMS proposes increasing indirect Practice Expense (PE) values for about 50 codes with very low direct PE. This proposal positively impacts services “primarily furnished by behavioral health professionals.” The incremental increase will be spread over four years and amounts to $40 million a year for all 50 services for four years. Mental health professionals collectively are projected to see an increase in allowed payments of over $1 million a year.

• CMS also proposes adding new codes under telehealth services: Crisis Codes (90839, 90840) and an Interactive Complexity add-on code (90785).

• CMS plans to adopt CPT codes for Collaborative Care Model (CoCM) services and Behavioral Health Integration (BHI) services (99xx5) to replace the current temporary codes (G0502, G0503, G0504, and G0507).

• CMS is proposing to allow FQHCs and RHCs to receive separate payment for CoCM and BHI services starting January 1, 2018.

• CMS proposes to include payment for the CoCM and BHI services in the definition of “primary care services” leading to assignment of beneficiaries to a Medicare Accountable Care Organization (ACO). This may help encourage ACOs to adopt CoCM.

• CMS has proposed the adoption of codes that describe the work involved in implanting or removing buprenorphine subdermal implants for treatment of patients with opioid or other substance use disorders. CMS is also interested in strategies to incentivize organizations and professionals “to provide screening, assessment, and evidence-based treatment for individuals with opioid use disorders and other substance use disorders.” This includes examples of potential reimbursement methodologies, systems integration, and care coordination among other things.

With regard to CoCM codes, CMS has indicated it will accept most of the valuation recommendations from the AMA/Specialty Society RVS Update Committee. Adoption of the recommended values means an increase in payment due to an increase in the practice expense component—approximately $18.00 and $2.50 more for the initial and subsequent months of care, respectively. 

APA was instrumental in developing both the CPT codes and the recommendations adopted by the RVS Update Committee.

Additionally, CMS has called for a multi-year process to review the documentation guidelines for evaluation and management services in an effort to reduce the administrative burden on practitioners. Specifically, they will be considering redesigning the requirements with greater importance on medical decision making. APA will be working with a small coalition of other physician organizations to better understand the impact of this potential change.

The final rule is expected to be issued in November. ■