Psychiatr News October 19, 2007
Volume 42, Number 20, page 24
© 2007 American Psychiatric Association
APA Urges Government to Revamp Medicare Payment System
Mark Moran
APA tells the government it must reimburse physicians for the time they
spend dealing with administrative demands imposed by federal programs.
APA has submitted comments to the Centers for Medicare and Medicaid
Services (CMS) in response to the proposed rule outlining changes in the 2008
Medicare physician fee schedule (see Medicare Fees Headed for Huge Cuts). The
rule was published in the Federal Register on July 12. Among the comments
related to physician payment are the following:
- Budget Neutrality and Work Adjuster
For the second year in a row, CMS is applying a "budget neutrality
adjuster" to work values in the fee schedule formula.
"APA agrees with the view of the American Medical Association (AMA)
Specialty Society Relative Value Update Committee that CMS should apply any
necessary adjustments to the conversion factor rather than to physician work
relative value units (RVUs)," wrote APA Medical Director James H. Scully
Jr., M.D., in comments to CMS. "We also agree with the AMA's statement
that CMS must work with Congress to avert Medicare fee-for-service physician
pay cuts by enacting positive physician payment updates that accurately
reflect increases in medical practice costs, as indicated by the Medicare
Economic Index. In addition, over the long term, CMS must work with Congress
to repeal the sustainable growth rate and replace it with a system that keeps
pace with increases in medical practice costs."
- Neuropsychological Testing as a Telehealth Service
In the proposed rule, CMS intends to include neurobehavioral status
examinations as a category 1, Medicare-covered telehealth service, but does
not include neuropsychological testing in that category.
Among the reasons CMS cites are that neuropsychological testing
"requires administration by a trained professional and involves a unique
interactive dynamic between the physician, practitioner, and/or technician who
administers the test and the patient."
But Scully countered in his comments that "it is unclear why an
off-site patient could not have these testing dynamics easily reproduced, such
as being blind-folded or having numbers assigned to fingers, with the help of
someone on site with them, while the testing is done via telecommunications.
These testing functions are already largely computerized, so the differences
between on-site and off-site testing should be minimal and not prohibitive of
Medicare coverage."
CMS also expressed doubts about "whether a patient with suspected or
confirmed brain damage or mental illness such as schizophrenia can be taught
how to use a computer by a practitioner who is in a remote location.
Therefore, [CMS also requests] specific comments as to whether a
neuropsychological patient could be instructed and supervised adequately to
take the Wisconsin Card Sorting Test through an interactive audio and video
telecommunications system."
In his comments, Scully noted that cognition and other basic brain
processes of neuropsychiatric patients vary broadly across a spectrum, as
evidenced in the diverse expression of symptoms in such disorders as
schizophrenia, Alzheimer's dementia, major depression, and mental
retardation.
"Neuropsychological testing may be more challenging for some patients
than others, but that would be true whether this is done face to face or by
telecommunications," he wrote. "Patients who require immediate
help in person can arrange to have someone, such as a nurse or medical
technician, to assist them at their location during the teletesting. Medicare
coverage should be available for those patients who can accomplish
neuropsychological testing via telecommunications."
- Reimbursement for Administrative Mandates
"Medicare needs to reimburse psychiatrists and other physicians for
the substantial time that they will continue to expend to deal with a panoply
of demands imposed by federal programs, including Medicare Part D,"
Scully wrote. "This is especially important, considering the projections
for ensuing years of net diminution in physician reimbursements under
Medicare. We are concerned that inequitable reimbursements will create a
disincentive to continue treating patients under federal programs. We continue
to encourage CMS to work toward inclusion of this time outlay in reimbursement
schemes.
"Results of a national study by the American Psychiatric Institute
for Research and Education (APIRE) on the Medicare Part D program's effects on
patients and psychiatrists were recently published," Scully added.
"Part of the findings concerned administrative requirements of the Part
D program for psychiatrists and their staff. This provides a snapshot of just
one element of one federal program that has substantially increased the level
of uncompensated administrative time for psychiatrists. Psychiatrists reported
that they or their staff spent on average 45.6 minutes on administrative
issues related to prescription drug plan coverage (including filling out
paperwork and Internet, telephone, or other time with patients, prescription
drug plans, pharmacies, or the Centers for Medicare and Medicaid Services) for
every hour of direct patient care provided since January 1, 2006."
The full text of APA's comments are posted at
<www.psych.org/members/advocacy_policy/reg_comments/regulatory_comments.cfm>.
Related Article:
-
Medicare Fees Headed for Huge Cuts
- Mark Moran
Psychiatr News 2007 42: 1-24.
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