The Centers for Medicare and Medicaid Services (CMS) finalized a rule change that will allow clinical psychologists to supervise technicians and other staff members who conduct psychological or neuropsychological testing. Previously, only physicians could supervise such individuals. Medicare defines a clinical psychologist as a doctoral-level practitioner recognized by Medicare as qualified to provide both therapeutic and diagnostic services.
The revised federal regulation, which was approved as part of the final rule on the 2005 Medicare fee schedule in November, became effective on Jan. 1. It provides psychologists the same level of supervision privileges as physicians: Both groups can generally direct and manage technicians but do not have to be present during testing.
"Previously, a psychologist could not supervise someone giving a psychological or neuropsychological test," says Diane Pedulla, JD, the APA Practice Directorate's regulatory affairs director. "The expansion of the rule puts psychologists on equal status with physicians in regards to testing."
The changes are the result of over two years of advocacy by the APA Practice Organization (APAPO)--which tackled the issue in response to psychologists' requests. CMS cited APAPO's reasoning when it released the proposed change for public comment in August. Psychologists' training in assessment and psychometric testing uniquely qualifies them, it said, to direct test selection and interpret test data. CMS also noted that the change would reduce the wait times many people in rural areas face when they need testing.
Nevertheless, the change does not affect other CMS requirements, notes Pedulla. Separate rules governing what is known as "incident to" billing state in part that, in order to seek reimbursement for technicians' services, psychologists and physicians must directly supervise the staff members involved. That means, says Pedulla, that they must be in the office suite and immediately available when technicians or other staff members conduct the testing. Additional requirements might apply under Medicare carriers' local policies.
--D. SMITH BAILEY
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