DPA Update

1. CPT code change:  According to the APA Advocacy Office, beginning in 2023 the CPT codes for prolonged psychotherapy services will no longer be available for psychotherapy. These codes are getting deleted as of January 1. Historically, psychologists have used CPT 99354/99356 to represent services that lasted 90 minutes or longer. The new edition of the CPT manual is now out, and there is no instruction on how to report prolonged psychotherapy services. It appears that the ability to report additional codes for therapy sessions lasting 90 minutes or more is gone. We will send updates as they become available.

2. Centers for Medicare & Medicaid (CMS) adopted changes: CMS has adopted several changes proposed by APA Services Advocacy Office, including:

• Enabling continued access to behavioral health services furnished via telehealth. CMS will maintain Medicare reimbursement rates for telehealth services at the higher “non-facility” rate level, extend the flexibilities for telehealth an additional 151 days after the public health emergency ends, and continue coverage of audio-only telehealth.  
• Eliminating unnecessary administrative burdens for supervision. CMS adopted a proposal that allows psychologists to supervise the work of other mental and behavioral health professionals without requiring the supervising psychologist to be physically present when services are delivered (general supervision). This helps to position doctoral psychologists as leaders of health teams and use our expertise to supervise and help others.
• Increasing support for integrated care. CMS is finalizing a new code psychologists can use for behavioral health integration services in primary care practices.  

More details will be publicized as they’re available. APA Services is also working with the broader healthcare community to address the impending payment cuts to all Medicare providers before the December 31, 2022 deadline. 

3. No Surprises Act updates: 

As a reminder, the primary focus of the No Surprises Act is to protect patients from large, surprise bills resulting from emergency medical care, ambulance services, and certain services received from out-of-network providers at in-network facilities. Few psychologists provide these services yet have been required in 2022 to complete Good Faith Estimates (GFEs) for their uninsured clients and clients who had insurance but didn’t want to use it.

The forthcoming rule from CMS will add to GFE requirements, now including clients who intend to use their insurance to cover their therapy service. CMS has proposed that, for these patients, the provider will need to notify the patient’s insurer of the estimated charges (send the GFE to the insurer), then the insurer would send the patient an explanation of benefits based on the provider’s estimate. 

CMS had requested feedback to help the agency propose the detailed process for sending GFE information from providers to insurers. CMS seeks feedback on what obstacles and expenses providers would face if they had to use standardized technology when transferring the information to the insurers and what other options exist that could be less burdensome. APA has held several meetings to solicit feedback from psychologists around the country. They submitted the first level of feedback by November 15th, 2022. A second request for feedback for CMS will be forthcoming. Meanwhile, the APA Advocacy Office is putting together a response in coordination with the National Association of Social Workers and the American Psychiatric Association 

 If you have any questions, concerns, or comments about this summary or about other issues impacting your work as a psychologist in Kentucky, please contact Karen Graves, Ph.D. Director of Professional Affairs at [email protected]