Medicare Penalties Catch Uninformed Psychologists Off Guard

By Paula E. Hartman-Stein, Ph.D.
March 31, 2015

Medicare penalties catch uninformed psychologists off guardDespite repeated announcements and warnings from the Center for Medicare and Medicaid (CMS) of the financial consequences to providers who do not participate in Physician Quality Reporting System (PQRS) in 2013, some psychologists are angry, confused and shocked after receiving letters announcing an across-the-board penalty of 1.5 percent in 2015.

During an informal poll conducted during the February meeting of the Cleveland Psychological Association (CPA), about half had received notices of penalties. Thirty percent reported not knowing what PQRS is. Psychologists have been eligible to obtain small bonuses for PQRS participation from 2008 to 2014. Detailed information about how to participate is contained on the government website,

According to CPA President Nancy Duff-Boehm, Ph.D., “Education from the Center for Medicare and Medicaid Services (CMS) is buried in a sea of information about labs and flu shots. It is very tempting for me to ignore my messages from CMS because so few pertain to my practice. Professional organizations should be doing a lot more to inform and educate their members.”

Peter Kanaris, Ph.D., APA Council Representative for New York, said, “I have been astounded by the number of experienced psychologists who have been unaware of PQRS, paying little attention to the changes going on in healthcare and remaining in their silos until immediately affected …. PQRS is not simple. It requires time and study.”

The New Jersey Psychological Association (NJPA) has been proactive in providing resources and education for its members. Without endorsing any specific courses, Jane Selzer, executive director of NJPA, negotiated discounts for the members in 2014 to purchase privately produced webinars on PQRS basics for psychology. NJPA has also been dispelling misinformation appearing on a listserv about PQRS, encouraging members to contact the APA Practice Organization or the CMS helpdesk for assistance.

Beginning in January all Medicare providers who failed to satisfactorily report one process measure on one patient in 2013 began to receive a 1.5 percent payment reduction on their Medicare patients throughout 2015. In an article published in CPA’s February newsletter, DuffBoehm called the 2013 requirement, “a toe-dabble meant to desensitize providers to the idea that the system is too overwhelming to broach.

The actions recommended in some measures were so obviously correct, I felt foolish not doing them and was glad to be reminded to do them. One example last year was to assess depressed patients for suicidality and another required us to ask patients upon assessment whether or not they use tobacco, and if so, advise them to quit and offer help to do so.”

In early February, Pat Bach, Psy.D., president of Psychologists in Long-term Care, organized a national conversation hour with three panelists, Amy Rosett, Ph.D., private practitioner in Los Angeles who teaches seminars on PQRS, Dori Bischmann, Ph.D., APA representative to the Physician Consortium for Performance Improvement (PCPI) and me. “Medicare is moving away from paying providers a fee based on the time spent with patients. The idea is to focus on the quality, the ‘Q’ in PQRS,” Rosett said.

She said, “People tend to overthink PQRS and make it more complicated. Many of the measures are required only once per reporting period or per calendar year. If using claims-based reporting in 2015, there are only six measures and some can literally take 10 seconds.” In 2015 there are 240 PQRS process measures, 47 less than in 2014. Because fewer than nine measures are available for psychologists based on allowed current procedural terminology (CPT) codes, data from the claim forms will be analyzed by a process known as the MAV (Measure-Applicability Validation) that determines whether additional measures could be reported.

Panelists agreed the validation process should not prove problematic if the reporting of six measures is done on at least 50 percent of eligible patients. Rosett said if the validation process indicates other measures were available, psychologists have the right to appeal.

Psychologists are eligible to report on more than six measures if they participate through a registry. “Currently claims-based reporting is most popular,” said Bischmann. “CMS’s goal is to phase out claims-based reporting. The big push right now is registry reporting.”

A downside of registry reporting is cost. APA has linked up with PQRSPRO HealthMonix registry that gives psychologists who are APA members a discounted rate of $199 per year per provider, a $100 savings. Paulo Andre, M.D., developer of another CMS vetted registry, MDInteractive, said he will charge the same $199 rate for 2015 for any psychologists. Another option is to use the Dementia Measures group if a psychologist has 20 patients with a dementia diagnosis, and at least 11 are Medicare Part B fee for service patients.

“For 64 patients with 230 sessions, it took me 11 hours to report my data,” said Bischmann, who used a registry for the first time in 2014. “For 2015 as soon as the registry is updated, I will be reporting it little by little.”

Some clinicians think they can wait until the end of the calendar year to do the screens and follow up plans with their patients. Bischmann said the measures are to be conducted at the time of the clinical service. The data can be submitted to the registry at one time.

Charlie Cooper, Ph.D., director of professional affairs for the North Carolina Psychological Association, did a cost analysis on registry reporting. In a phone interview, he said, “A psychologist would need to do $9,950 of Medicare billing per year in order to break even with the cost of a registry. If a provider is using the claims-based method with 100 percent effectiveness, then the registry is an unnecessary cost. Providers should work individual analyses to reflect their own circumstances.”

The future of PQRS

According to Bischmann, “The PQRS process is going to change and evolve. It is a relatively new strategy in terms of measuring quality with a lot of work ahead to develop meaningful measures. CMS is moving toward reimbursing in a way that financially rewards providers who show evidence of higher quality and lower cost.” She urges psychologists to participate, be involved and be part of the learning curve to be better positioned when the quality initiatives are more evolved and mandated. “Quality measures are here to stay.”

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