360 Degree Advocacy Team: National Government Services
The concept of 360 degree advocacy is to get national organizations, national content experts, state level leadership, and state level advocates together on a coordinated team for high impact, advocacy. In October of 2013, National Government Services (NGS) took over as the Medicare Administrative Contractor for two previous regional contractors, NHIC in the northeast and WPS in the midwest.
With this change, the old Local Coverage Determination (LCD) for Psychology and Neuropsychology, which were favorable, were replaced by new LCDs which restrict access to much needed psychotherapy and neuropsychology services. A 360 Degree advocacy team was launched to address this problem. The team covered both new NGS regions, and included SPTA leadership from 10 states as well as national content experts.
The 360 Degree Advocacy Team submitted a request to place the LCDs in draft status, opening them up to changes and comments from the general public. The request letter included specific changes the team was seeking to the LCD language.
NGS 360 Degree Advocacy Team
IOPC Dr. Karen Postal , Dr. Michelle Braun
APAPO Legal expert: Diane Pedulla, JD
National Experts: Dr. Neil Pliskin, Dr. Karen Wills, Dr. David Tupper
NGS J-K region (Eastern):
CT Dr. Barbara Bunk, President, Traci Cipriano, DPA,Tricia Prebe Executive Director
ME Sheila Cornerford, Executive Director; Dr. Jeff Matragna, President
NY Dr. Eric Neblung, President NYSPA, Dr. Jerry Grodin, DPA; NYSAN: Dr. Ed Barnowski, president, Dr. Chris Morrison, president elect
VT Dr. Rick Barnett, president, Dr. Milton Marasch, Insurance Committee Chair, Dr. Judith Markey, President-elect
MA MPA: Dr. Mabel Lam, President. Mass Neuropsych Society: Dr. Michelle Imber, president elect, Dr. Roger Cohen, PAC and BOD member; Massachusetts Neuropsychological Society Dr. Maggie Lanca, President.
RI Dr. Lisa Rocchio, President; Jack Hutson, Executive Director
NH Dr. Sheila Gardner; Kate Saylor, Executive Director
NGS J-6 Region (Midwestern):
WI Sara Bowen, WPA ED, Dr. John Weaver, WPA President, Dr. Gregory Jurenec, WPA Advocacy Chair
Dr. Dori Bischmann, WPA Federal Advocacy Coordinator:
IL Dr. Terrance Koller, IPA ED
MN Rhea Sullivan - MPA ED
In response to this highly coordinated, "shock and awe" advocacy effort, NGS revised their LCD, making almost every change that was requested including:
• Any ICD code that demonstrates medical necessity is now ok for neuropsychological testing
• Language clarifying that it is ok to bill for feedback sessions
• There was a clarification that it is ok to bill for integrating emotional measures into neuropsychological testing
• Clarification that psychological assessment for depression for patients entering nursing homes when medically indicated is allowed
• Language clarifying that supportive documentation is needed only when testing surpasses 8 hours (in response to a "4-6 hours is typical for testing" original guideline)
The team continues to work with the medical directors of NGS for further revisions. Having buy in and coordinated advocacy from every state psychological association and regional neuropsychological association in the NGS regions made a tremendous impact.