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The California Medical Association joined the American Medical Association and 30 other health care organizations to oppose the “Medicare Mental Health Access Act” (HR 884/S 2772), which would change the definition of “physician” under the Medicare program to include clinical psychologists.

This proposal jeopardizes the safety of patients in the Medicare program and would create silos in the delivery of appropriate mental and physical health care. Moreover, this legislation runs counter to efforts to coordinate and integrate the delivery of care to patients with mental illnesses and co- occurring health conditions.

Currently, the Centers for Medicare and Medicaid Services (CMS) in its Medicare Policy Benefit Manual, defines “physicians” as providers who medically diagnose patients, prescribe and manage medication, and supervise other medical staff. This would allow clinical psychologists to be regarded as physicians and treat patients without supervision throughout in-patient settings, including partial hospitalization settings.

Expanding the term “physician” to include clinical psychologists under the Medicare Program would improperly expand psychologists' scope of practice, and would have far reaching and negative impacts on patients seeking psychiatric care.

Physicians complete four years of medical school plus three to seven years of residency, including 10,000-16,000 hours of clinical training. While psychologists are an essential part of a physician-led patient care team, they lack the requisite medical education, medication management training, and clinical training that is critical in determining differential diagnosis.

“Psychologists are not trained to treat acute mental illness requiring medication management or co-occurring physical illnesses,” the letter said. “Given the complexity of this patient population, it is essential that we retain collaborative guardrails that require psychologists to consult physicians who have the education and training to effectively manage the entire treatment plan, including both physical and mental health services.”

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