NAN Advocates for Neuropsychology in Comments on the 2027 Medicare Physician Fee Schedule
The National Academy of Neuropsychology (NAN) recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed CY 2027 Medicare Physician Fee Schedule (PFS). The purpose of these comments was to ensure that CMS understands the critical role neuropsychologists play in diagnosing, treating, and supporting patients with cognitive, behavioral, and neurological conditions and to highlight areas where Medicare policies could unintentionally limit access to neuropsychological services.
VIEW NAN’S COMMENTS
NAN's comments focused on three key areas:
Supporting Long-Term Medicare Payment Stability
NAN expressed concern about the proposed reduction in Medicare physician payment resulting from lower 2027 conversion factors. While recognizing that many of the payment changes are driven by statutory requirements outside CMS's direct control, NAN emphasized that repeated payment reductions create challenges for neuropsychologists and other providers facing rising practice costs.
Highlighting Neuropsychology's Role in Brain Health and Dementia Prevention
CMS requested input on potential Medicare coverage of intensive lifestyle interventions aimed at slowing the progression of Alzheimer's disease and related dementias. NAN emphasized the growing evidence supporting interventions and highlighted the unique expertise of clinical neuropsychologists in diagnosing mild cognitive impairment and dementia, evaluating brain health, and helping patients adopt evidence-based strategies that may support cognitive functioning and quality of life.
Protecting Neuropsychologists Within Medicare Quality Programs
NAN also commented on CMS's proposal to eventually eliminate traditional Merit-based Incentive Payment System (MIPS) reporting after PY 2028. NAN cautioned that neuropsychologists currently have limited viable alternatives once traditional reporting sunsets because there are few neuropsychology-specific quality measures, no broadly available Advanced Alternative Payment Models (APMs) designed for neuropsychology, and little experience with the newly created Neuropsychology MIPS Value Pathway (MVP). NAN urged CMS to delay the sunset of traditional MIPS until appropriate reporting pathways and specialty-specific measures are fully established.
NAN also encouraged CMS to work with neuropsychology organizations to develop quality measures that better reflect the care neuropsychologists provide, including cognitive assessment, dementia evaluation, patient safety, functional assessment, behavioral health, care coordination, and communication with patients and caregivers. Without measures that capture these services, neuropsychologists risk being evaluated using metrics that do not reflect the quality and value of neuropsychological care.
Looking Ahead
Through these comments, NAN sought to ensure that Medicare policies recognize the important contributions of neuropsychologists to brain health, cognitive assessment, dementia care, and interdisciplinary treatment planning. NAN will continue working with CMS and policymakers to promote payment policies, quality measures, and care models that preserve patient access to high-quality neuropsychological services.