APA Practice Information Alert

November 26, 2018

Medicare 2019 Fee Schedule Final Rule (Part 3)

This is the third and last Information Alert on the 2019 Medicare fee schedule. This latest Alert focuses on what psychologists need to know about the Merit-based Incentive Payment System (MIPS).

Changes to Medicare’s Quality Payment Program in 2019 were included in the final rule on the Medicare fee schedule. As expected, CMS adopted its proposal to add practicing psychologists to MIPS in 2019 with payment adjustments taking effect in 2021. Effective January 1st, psychologists will join physicians and other healthcare providers defined as eligible clinicians (ECs) in the MIPS reporting program.

The APA Practice Organization anticipates that many psychologists in Medicare will be exempt from MIPS reporting under the low volume threshold (LVT). Only those who exceed all three criteria under the LVT are required to report under MIPS. For 2019 psychologists will be exempt if in 2018 they:

  • Treated 200 or fewer Medicare beneficiaries;
  • Billed Medicare for $90,000 or less in allowed charges; or
  • Provided 200 or fewer covered professional services.

In addition, any EC who first enrolled in Medicare in 2018 is automatically exempt from MIPS reporting in 2019. ECs who participate in Advanced Alternative Payment Models may also be exempt.

CMS is also implementing its proposal to allow MIPS ECs who meet some but not all the criteria under the LVT to “opt-in” to MIPS reporting. Psychologists who elect to exercise this option should understand that once the decision to opt-in is made it is irrevocable for the reporting year.

ECs in MIPS who are part of group practices (i.e., two or more providers billing under the same tax identification number) can choose whether to participate in MIPS as individual providers or as part of the group. Many may find that they would be required to report under MIPS if treated as a group but exempt under the LVT on an individual basis. Psychologists in this situation will need to decide if the practice wishes to report under MIPS as a group and possibly earn bonuses in 2021 or have each psychologist identify as an individual EC and possibly be exempt MIPS reporting.

For psychologists who surpass the LVT and must report under MIPS, the potential payment adjustments in 2021 will range from a bonus of 7% to a penalty of -7%. MIPS is designed so that most ECs will be considered average and thus have a payment adjustment of 0%. Psychologists reporting as individuals may report quality measures through claims along with other methods such as a MIPS registry, a qualified clinical data registry (like the APA’s Mental and Behavioral Health Registry), through electronic health records and the CMS web interface. Group reporting cannot be done through claims.

MIPS has four categories: quality, promoting interoperability, advancing care initiatives, and cost. For 2019 psychologists and the other non-physicians newly added to MIPS will only be responsible for reporting quality measures and advancing care initiatives. Cost data is taken from claims by CMS and does not require reporting. Because psychologists and certain other non-physicians were not included in the meaningful use incentives designed to promote the adoption of electronic health records, they will not be required to report under the promoting operability category in 2019. For purposes of the overall MIPS score CMS will weigh the promoting operability category to zero.

For 2019 the MIPS categories will be added together to give each EC a final score as follows:


Promoting Interoperability 


Improvement Activities

45% of MIPS final score

 25% (0% for psychologists and certain others in 2019)



The 2019 performance year will run from January 1, 2019 to December 31, 2019. All data must be submitted to CMS by March 31, 2020. CMS will provide reporting ECs with feedback in July 2020 and will apply payment adjustments based on MIPS reporting to each claim starting on January 1, 2021.

The Mental and Behavioral Health Registry (MBHR) was created by APA to help psychologists and other professionals collect data on patient outcomes and participate in quality reporting programs. The MBHR has been approved by CMS for MIPS reporting and is currently the only qualified clinical data registry that includes measures on anxiety. More information about the MBHR is available at: https://www.apapracticecentral.org/reimbursement/health-registry/index.

Psychologists with questions about the 2019 Medicare fee schedule changes are welcome to contact the Government Relations Office by telephone (202-336-5889) or by email (pracgovt@apa.org).

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