2003 Fee Schedule Brings Gain—and Pain The 2003 Medicare Physician Fee Schedule brings mixed results for audiologists and speech-language pathologists who bill Medicare for reimbursement for their services. In all, the two professions gained 14 new procedure codes. But while reimbursement rates for most audiology procedures will remain the same or increase, the rates for the ... Bottom Line
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Bottom Line  |   February 01, 2003
2003 Fee Schedule Brings Gain—and Pain
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Hearing Disorders / Hearing Aids, Cochlear Implants & Assistive Technology / Swallowing, Dysphagia & Feeding Disorders / Practice Management / Professional Issues & Training / Regulatory, Legislative & Advocacy / ASHA News & Member Stories / Bottom Line
Bottom Line   |   February 01, 2003
2003 Fee Schedule Brings Gain—and Pain
The ASHA Leader, February 2003, Vol. 8, 2-19. doi:10.1044/leader.BML2.08022003.2
The ASHA Leader, February 2003, Vol. 8, 2-19. doi:10.1044/leader.BML2.08022003.2
The 2003 Medicare Physician Fee Schedule brings mixed results for audiologists and speech-language pathologists who bill Medicare for reimbursement for their services. In all, the two professions gained 14 new procedure codes. But while reimbursement rates for most audiology procedures will remain the same or increase, the rates for the speech-language pathology procedures of dysphagia clinical and modified barium swallow assessments will drop.
“This severe reduction in rates for the two dysphagia procedures was a decision made by the Centers for Medicare and Medicaid Services, and we were not advised of the decision until we saw the fee schedule,” said Nancy Swigert, chair of ASHA’s Health Care Economics Committee (HCEC).
These two procedures had been described by temporary G-codes, and the HCEC presented data to the American Medical Association (AMA) CPT panel to have them converted to CPT codes, Swigert explained.
“Because no ‘physician work’ is involved in either procedure, practice expense data is all that can be presented,” Swigert said. “We do not think the very low rates are justified, considering the practice expense data presented to the AMA. However, CMS makes the ultimate decision about reimbursement rates and, in this case, has determined rates that do not adequately reflect the work involved in these procedures.”
ASHA recently concluded a 19-page preliminary analysis of the 2003 Medicare Physician Fee Schedule, which was published on Dec. 31, 2002. The analysis provides an overview of new developments in the fee schedules and comments on relevant revisions, along with tables of updated relative values and geographic indices and payment amounts for all procedures relevant to the professions. The document can be downloaded from ASHA’s Web site. As an exclusive member benefit, complete fee schedules will be developed separately for both audiology and speech-language pathology and made available on ASHA’s Web site in the near future.
Because of the delay in publishing the final Medicare Fee Schedule, the new rates do not take effect until March 1, providing Medicare intermediaries time to implement the new payment policies. Providers will be reimbursed under the 2002 payment rate and should hold all claim submissions for new CPT codes until March 1.
For the second year in a row, providers will see a drop in the conversion factor, which adjusts the base formula for all Medicare services. The conversion factor is based on a mandated formula. Because Congress failed to address this issue prior to the end of its session, CMS was compelled to institute the negative update. The conversion factor formula has been severely criticized by the Medicare Payment Advisory Commission, and ASHA will continue to collaborate with the AMA to remedy the 4.4% decrease.
Despite the decrease in the conversion factor, audiologists will find that reimbursement rates for most procedures will remain stable or increase, thanks to new practice expense costs submitted by ASHA through the CPT processes of the AMA.
The following are key changes for audiologists and SLPs:
  • Cochlear implants. The fee schedule includes four new CPT codes for cochlear implant programming procedures. Beginning in March, audiologists can perform these procedures without physician supervision in medical centers or private practice. These diagnostic services will not count against the $1,500 caps for outpatient therapy services that may be implemented later this year.

  • Aural Rehabilitation. As a consequence of the new diagnostic cochlear implant programming codes, Medicare will no longer recognize the CPT code for aural rehabilitation (92510). SLPs will be able to bill Medicare for 92507, a procedure that encompasses aural rehabilitation. Private payers can elect to designate CPT 92510 for aural rehabilitation following cochlear implantation. In 2003, ASHA’s HCEC will address the need for separate audiologic rehabilitation procedures. In addition, ASHA is advancing federal legislation to have Medicare cover audiologic rehabilitation services by audiologists.

  • Cerumen Removal. CMS created a new code for use when a contracted or employed audiologist who bills under the physician’s Medicare provider number performs audiologic testing on the same day that the physician removes impacted cerumen. This G-code should not be used when the audiologist removes cerumen, because CMS considers cerumen removal to be part of diagnostic testing and not paid separately.

  • Fiberoptic Endoscopic Evaluation Services (FEES). SLPs will be able to use several new codes for FEES that were developed by ASHA and the American Academy of Otolaryngology–Head and Neck Surgery. Physicians who do not perform the FEES can only bill the patient when providing an office visit, and should not bill as the supervisor of another professional performing and reviewing the initial FEES. According to CMS, if a nonphysician has the credentials and experience to perform this testing, then that professional should also interpret the findings.

  • Voice Prosthetic Devices and Non-Speech-Generating Devices. Two temporary G-codes for voice prosthesis (G0200 and G0201) were removed by CMS. In the interim, CMS recommends that SLPs use CPT 92506 for a voice prosthetic evaluation and CPT 92507 for modification/training in the use of voice prosthetics until a more accurate code is identified. The ASHA HCEC is working to recommend new procedures related to evaluation and treatment for patients with voice prosthetics. Codes related to non-speech-generating devices (CPT 92605–92606) are not reimbursable under Medicare but can still be used by private payers.

Swigert reported that a conference call will be held with CMS officials to determine the rationale that was used in setting the low rates for the dysphagia codes. “Unfortunately, once these reimbursement rates are set, they cannot be changed during this calendar year,” she said.
In addition to addressing the rates for these two dysphagia codes, ASHA is working closely with the AMA and other health-related professions to remedy the conversion factor.
“We continue to advocate for independent provider status for speech-language pathologists and audiologists in Medicare law,” Swigert said. “Until that is accomplished, the ‘work’ of our professions cannot be recognized in the formula for determining reimbursement rates. Diligent and persistent advocacy efforts by many ASHA members will be needed to accomplish this goal.”
For more information on the 2003 Medicare Fee Schedule, download ASHA’s preliminary analysis at ASHA’s Web site or download the Federal Register notice at http://edocket.access.gpo.gov/2002/pdf/02-32503.pdf [PDF, 1.6MB]. For questions, contact Ingrida Lusis through the Action Center at 800-498-2071, ext. 4482, or by e-mail at ilusis@asha.org; or Mark Kander at ext. 4139 or mkander@asha.org.
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February 2003
Volume 8, Issue 2