In 2023, successful psychology organization advocacy for much-needed increases in the WORK component of the Relative Value Units (RVU) of key behavioral health services (HCPCS psychotherapy codes 90832, 90834, 90837, Health Behavior Assessment and Intervention [HBAI] services, crisis, family, and group therapy services) resulted in CMS’s adoption of an increase of 19.1% in the work RVU, phased in over four years. 2025 will be the second year of four of the phased-in increase.
I estimated the practical implications of this increase for reimbursement through 2027, using 2023 as the baseline year for RVUs for these services. Here’s what this looks like.
The first assumption probably is modestly to strongly likely to be correct. Even with other minor RVU component changes, the overall direction and amount of change would closely match these estimates.
The second assumption probably overestimates the overall direction and amount of change. This is because the CF has now been reduced five years in a row. Further reductions would seem likely, or a flatlined CF at best. I suppose there’s a possibility Congress could finally figure this out and make what would amount to larger scale, systemic, fixes to pricing in Medicare, which would imply overall greater costs. As I say, I’d estimate such changes to be unlikely, but readers may of course have different views.
Two points may be worth noting. First, a 19.1% increase over four years in one of the components of the RVU may sound like a lot, and probably is in the context of other such changes usually adopted for behavioral health and other services. However, such a change does not translate directly to a proportional increase in reimbursement.
For example, the NPA for HCPCS 90837 (60 minute psychotherapy) in the baseline year 2023 was $147.07. The 2027 projected value with the Work RVU phase-in is $165.51. That’s 12.5% over the 2023 value, an increase many may find meaningful, but below the 19.1% increase suggested by the phased-in work RVU component.
That 12.5% increase in the reimbursed NPA is noteworthy for another reason, and points to another context in which the phased in RVU change should be understood. Over four years, that’s an increase of about 3.1% per year. What would be happening to the reimbursement amount if it were increasing annually by the rate of inflation? Here’s what that looks like.
In other words, the projected increases related to the Work RVU component yield values that run almost in parallel with what would happen were the reimbursement keeping up with inflation. The $165.51 projected 2027 value “beats” the inflation-adjusted value by $1.26, over four years.
Other services will show similar patterns of change estimated to occur through 2027.
Psychologists and others who provide these services should applaud our professional organizations for effective advocacy that achieved fairer estimates of the work required for psychotherapy and health behavior-related assessment and intervention. In the context of the complex pathway through the RVU Update Committee, CMS, and Congress, all fair adjusments to reimbursement are major accomplishments.
In the context of psychologists working hard to take care of the public while keeping their offices open, eking out a reasonable living, and looking toward the future, the challenges are fairly clear.