2012 May Bring Reductions in Medicare Rates Expected changes in Medicare reimbursement rates will reduce payment for most audiology and speech-language pathology procedures, according to an ASHA analysis of the proposed 2012 Medicare Physician Fee Schedule (MPFS). Proposed changes, released July 1 (see The ASHA Leader, Aug. 2, 2011), include a 29% reduction in the conversion factor ... Bottom Line
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Bottom Line  |   September 01, 2011
2012 May Bring Reductions in Medicare Rates
Author Notes
  • Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org
    Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org×
Article Information
Hearing Disorders / Practice Management / Bottom Line
Bottom Line   |   September 01, 2011
2012 May Bring Reductions in Medicare Rates
The ASHA Leader, September 2011, Vol. 16, 4. doi:10.1044/leader.BML2.16112011.4
The ASHA Leader, September 2011, Vol. 16, 4. doi:10.1044/leader.BML2.16112011.4
Expected changes in Medicare reimbursement rates will reduce payment for most audiology and speech-language pathology procedures, according to an ASHA analysis of the proposed 2012 Medicare Physician Fee Schedule (MPFS). Proposed changes, released July 1 (see The ASHA Leader, Aug. 2, 2011), include a 29% reduction in the conversion factor used to compute fees; even if the conversion factor remains at or near the 2011 level, as most industry experts expect, reimbursement rates will fall.
Audiology
The decrease in audiology rates is the result of changes in the practice expense formula. (Rates for each procedure code are based on three components: professional expense or “work,” technical or practice expense, and malpractice expense.) Changes in the allocation of indirect costs—a four-year process that will be fully implemented in 2013—have resulted in the proposed reimbursement reduction in some high-volume audiology procedures, such as comprehensive hearing test and tympanometry.
Significant increases in rates are shown in the chart below for sinusoidal rotational testing and auditory evoked potentials (comprehensive). The main reason for these increases seems to be that these procedures, more than most other audiology codes, are more likely to be billed by physicians, rather than audiologists. The practice expense changes that adversely affected audiologists were beneficial to some physician specialties.
Speech-Language Pathology
The most significant rate reductions for speech-language procedures are a result of some codes being assigned professional work in recent years; any resulting duplicative practice expenses must be phased out. These changes affect several Current Procedural Terminology™ (CPT, ©American Medical Association) swallowing codes (92526, 92610, and 92611) and speech-generating device evaluation and treatment codes (92607, 92608 and 92609).
Conversion Factor
Congress has not yet resolved the issue of the formula that determines the annual conversion factor that affects all MPFS codes. Under current law and formula, that factor will cut all rates by 29% from 2011 rates. Congress has, for the past several years, passed legislation delaying or preventing that formula from taking effect, and Congress is expected to act similarly on the 2012 rule and prevent the implementation of these massive reductions in payment.
The two accompanying charts (audiology [PDF] and speech-language pathology [PDF]) illustrate estimated 2012 rates for several high-volume CPT codes. These rates are calculated using the current 2011 conversion factor (not on the unlikely proposed factor that is 29% lower) but reflect the 2012 practice expense changes. A full list of all audiology and SLP proposed fees appears in a sidebar online [PDF].
ASHA is analyzing carefully the data underlying the proposed reductions to audiology and speech-language pathology codes to detect any calculation or other errors and to note any errors in the association’s comments on the rule. Absent errors, however, the proposed reductions are inflexible, determined by formulas established by regulation. ASHA also will convey the negative effects of significant rate reductions on service accessibility: for example, smaller practices that are sensitive to fee changes may elect to stop treating Medicare patients.
Providers Must Revalidate Medicare Enrollment

Audiologists and speech-language pathologists who enrolled as Medicare providers prior to March 25, 2011, must revalidate their enrollment under new requirements of the Affordable Care Act.

The Centers for Medicare and Medicaid Services (CMS) added new screening criteria to the Medicare enrollment process in March 2011 as part of its effort to reduce fraud, waste, and abuse. CMS places providers in one of three screening categories—limited, moderate, or high—each representing a level of risk to the Medicare program. The Medicare Administrative Contractor (MAC) processing the enrollment application uses the provider’s category to determine the degree of screening to be performed.

From now until March 2013, MACs will send revalidation notices to individual providers,who then have 60 days from the date of the letter to submit enrollment forms. Failure to submit the enrollment forms may result in deactivation of Medicare billing privileges. The easiest and quickest way to revalidate enrollment information is through the Internet-based PECOS (Provider Enrollment, Chain, and Ownership System).

For more information about revalidation, visit CMS’s website [PDF] or contact Mark Kander, director of health care regulatory analysis, at mkander@asha.org.

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September 2011
Volume 16, Issue 11