2009 Medicare Fee Schedule Brings Losses, Gains Steep reductions in fees for some dysphagia assessment procedures are among the changes in the 2009 Medicare Physician Fee Schedule for Part B services issued by the Centers for Medicare and Medicaid Services (CMS) on Oct. 30. Changes in fees will vary for procedures done by audiologists and speech-language pathologists. ... Policy Analysis
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Policy Analysis  |   December 01, 2008
2009 Medicare Fee Schedule Brings Losses, Gains
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.×
  • Steven C. White, PhD, CCC-A, director of health care economics and advocacy, can be reached at swhite@asha.org.
    Steven C. White, PhD, CCC-A, director of health care economics and advocacy, can be reached at swhite@asha.org.×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   December 01, 2008
2009 Medicare Fee Schedule Brings Losses, Gains
The ASHA Leader, December 2008, Vol. 13, 1-7. doi:10.1044/leader.PA.13172008.1
The ASHA Leader, December 2008, Vol. 13, 1-7. doi:10.1044/leader.PA.13172008.1
Steep reductions in fees for some dysphagia assessment procedures are among the changes in the 2009 Medicare Physician Fee Schedule for Part B services issued by the Centers for Medicare and Medicaid Services (CMS) on Oct. 30.
Changes in fees will vary for procedures done by audiologists and speech-language pathologists. Fees for many speech-language pathology procedures will not be reduced and fees for some audiological procedures will increase.
The mixed effects stem from the mandate that CMS remain “budget-neutral” if total spending increases or decreases by more than $20 million. CMS did so by reducing the conversion factor—one of three components of every fee—instead of work values. The conversion factor for 2009 represents a 5.3% reduction from the 2008 rate after including a 1.1% inflationary update.
The new conversion factor is favorable to specialties in which work values represent the major share of payments. For some audiology and speech-language pathology codes in which practice expense represents most of the payment, the fees have decreased.
The complete fee schedule analysis is available on ASHA’s Web site. Regulations governing speech-language pathology private practice also were released with the fee schedule (see Table 1 [PDF]).
Speech-Language Pathology Adjustments
Fees will remain stable for procedures with professional components [or “physician work” relative value units (RVUs)] of approximately 25% or more of the total value (e.g., speech-language pathology evaluation and treatment). These fees will remain stable because a separate increase applies to the entire physician work component.
Unfortunately, dysphagia clinical and fluoroscopic swallowing evaluations (92610 and 92611) have no value in the professional component, resulting in a fee reduction of approximately 20%. Dysphagia treatment incurs a 5% reduction; fees for evaluation of auditory rehabilitation status increase 12%, and laryngeal function study fees increase by 9%. Fees for all other speech-language pathology procedures fees received minor increases or decreases.
ASHA recommended that CMS freeze the swallowing evaluation procedures at 2008 levels because of the expected 2009 reduction to zero work values. The association argued that speech-language pathology private-practice status would result in revised fees with the development of work components in RVUs scheduled for 2009. CMS, however, maintained the reduction. ASHA will submit comments on the final rule criticizing the severe cuts in dysphagia clinical and fluoroscopic swallowing evaluations and requesting revision in the values.
Table 1 [PDF] lists procedures with substantial fee changes.
Audiology Adjustments
ASHA successfully advocated in 2007 through its Health Care Economics Committee for Medicare to value certain services rendered by audiologists as professional rather than technical. ASHA, the American Academy of Audiology, and the American Academy of Otolaryngology–Head and Neck Surgery surveyed work RVUs for various procedures in 2007 and 2008. Fees for two procedures with newly assigned RVUs—central auditory function (60 minutes) and each additional 15 minutes—increase by 30% to 40% in 2009.
In Table 2 [PDF], five procedures with newly assigned work RVUs increase substantially: central auditory function (60 minutes) and each additional 15 minutes; evaluation of auditory rehab status (60 minutes) and each additional 15 minutes; and tinnitus assessment. Some fee procedure reductions greater than 15% result from elimination of the zero work pool and removal of direct practice expenses through 2010. These are also listed.
Rehabilitation Agency Policy Changes
Establishment of Medicare certification for rehabilitation agencies will be less important because SLPs become eligible for Medicare private practice status in mid-2009. However, a rehabilitation agency will remain a viable alternative for SLPs in states that do not allow establishment of a group practice that also delivers physical therapy and occupational therapy.
Several revisions to rehabilitation agency regulations take effect Jan. 1, 2009:
  • On-call physician for emergencies is no longer required.

  • Social worker, psychologist, or vocational counselor is no longer required.

  • “Extension locations” are now defined in regulations instead of only in the State Operations Manual. No limits regarding mileage or travel time from the primary location are specified; the agency must demonstrate that it is close enough to the extension location to provide supervision of staff.

  • Thirty-day physician certification/recertification is the single change that does not reduce required services. In 2008, CMS revised the physician certification and recertification period for outpatient rehabilitation services from 30 days to up to 90 days if the plan of care covered that duration. For rehabilitation agencies, CMS is reverting to the 30-day period, which complies with conditions of participation that require physician review at least every 90 days.

Additional Changes
Orders or referrals by physicians, nurse practitioners, or physician assistants must now be retained for seven years from the date of last service, not date of payment. Offsite or electronic storage is allowed if the records are readily accessible.
The therapy cap remains in effect but the exceptions process has been extended through 2009 by the Medicare Improvements for Patients and Providers Act. The new cap amount is $1,840 for combined services of SLPs and physical therapists. The cap does not apply to services provided in hospitals.
A PQRI (Physician Quality Reporting Initiative) bonus of approximately 2% is available to private-practice SLPs and audiologists who submit quality indicator information. CMS was scheduled to announce in November 2008 the measures that will be recognized for 2009. ASHA is involved with the PQRI development process and will provide a detailed analysis of the requirements when they are issued.
There are no new developments regarding audiology or speech-language pathology telepractice services. SLPs’ fees for these services cannot be considered until Medicare law is amended to permit payment for services at a remote site.
For further information, contact reimbursement@asha.org.
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December 2008
Volume 13, Issue 17