Psychologists around the nation are receiving faxed “Comparative Billing Reports” (CBR’s) from a company called eglobalTech, a company contracting with the Centers for Medicare and Medicaid Services (CMS). The stated intent of these reports is to provide education to psychologists (and other providers such as dermatologists, psychiatrists, social workers, etc.) regarding how their Medicare billing practices compare to state and national peers in the same specialty area.
The only psychologists receiving these reports at this time are those with at least two comparison areas that are much higher than their peers. If you have not received one, here is one that was sent out recently by APAPO:
Date: September 25, 2018
To: SPTA and Division Federal Advocacy Coordinators, and APAGS Coordinators
From: Doug Walter, J.D., Associate Executive Director for Government Relations,
American Psychological Association Practice Organization
Cc: Jared L. Skillings, PhD, ABPP, Chief of Professional Practice
SPTA Directors of Professional Affairs
SPTA Executive Directors
APAPO Board of Directors
Re: Medicare’s Comparative Billing Reports
We want to alert psychologists that they may receive a letter about their Medicare billing patterns from a company called eGlobalTech. The Centers for Medicare and Medicaid Services (CMS) have contracted with eGlobalTech to produce and distribute information about Medicare billing in the form of Comparative Billing Reports (CBRs). CBRs compare the billing practices of providers within the same state and nationwide based upon the common services they furnish.
Furnished as part of Medicare’s Education and Outreach program, CBRs educate providers about Medicare’s coverage, coding, and billing rules and act as a self-audit tool for providers. CBRs have long been available to providers on request but in recent years CMS has been proactively distributing this information to individual providers. CBRs have been sent to a wide variety of health care professionals over at least the past 6 years, including Dermatology, Psychiatry, Optometry, Social Work, Podiatry, and others.
CBRs highlight billing patterns that differ from those of similar providers within the state and nationwide. As explained in the letter from eGlobalTech, the CBR looks at billing data for psychotherapy, psychological and neuropsychological testing, and health and behavior assessment and intervention services. The CBR looks at three main criteria: the average number of minutes per psychotherapy visit, the average number of visits per beneficiary per year, and the average allowed charges per beneficiary.
Each of these 3 criteria are reviewed at both the state and nationwide level, resulting in 6 points of comparison. Psychologists receive the CBR if their billing patterns are significantly higher on 2 or more of the 6 comparison points.
The CBRs are intended to be educational so that providers can see how their billing differs from others providing similar services. Just because your billing is different than average does not per se mean it is inaccurate. In response to inquiries eGlobalTech has acknowledged that billing patterns may differ for a variety of reasons that are not apparent by just looking at the data. For example, a psychologist who concentrates on treating the elderly is going to have more Medicare beneficiary visits than a psychologist who treats patients across the age span.
Psychologists receiving a CBR are not required to do anything in response but are advised to read the report carefully. Additional information about the CBR for psychology is available at https://www.cbrinfo.net/cbr201808.html. By going to this site psychologists can sign up for a webinar by eGlobalTech on October 17, 2018, 3 to 4 pm Eastern time, to learn more and submit questions. If you cannot participate in the webinar a transcript will be available online within 5 business days.
This is being shared here for your information. Another helpful resource comes through Propublica Treatment Tracker at https://projects.propublica.org/treatment/doctor. Once you arrive at the website, put your name and city in the provided inquiry slot and you will see data on your own practice for 2015. I found it helpful to see how my data compared to peers.
We don’t know what the implications of these data/reports might be in the future, however since Medicare is always working toward reducing cost it is suspected that this information will be used to bring outliers, especially those who are using higher levels of Medicare resources than their peers, in line with the average. At this time it is recommended that providers use these reports and resources to evaluate their practices and determine if they are providing the highest quality, cost conscious care possible. It is also recommended that you communicate with your peers to identify standards of practice in your unique clinical specialty. Take Webinars that are being presented on these and related topics, then adjust your practice accordingly. Remember to document any efforts you make to improve your practices.
Dori Ann Bischmann, PhD
Federal Advocacy Coordinator-Wisconsin
WPA and APA