2012 Revisions to Medicare Fee Schedule Proposed The proposed 2012 Medicare Physician Fee Schedule (MPFS) includes annual changes to valuations for audiology and speech-language pathology procedures, implements certain provisions of the Affordable Care Act and the Medicare Improvements for Patients and Providers Act of 2008, and discusses Physician Quality Reporting System issues related directly to speech-language pathology ... Bottom Line
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Bottom Line  |   September 01, 2011
2012 Revisions to Medicare Fee Schedule Proposed
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.×
  • Kate Romanow, JD, director of health care regulatory advocacy, can be reached at kromanow@asha.org
    Kate Romanow, JD, director of health care regulatory advocacy, can be reached at kromanow@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
Hearing Disorders / Practice Management / Bottom Line
Bottom Line   |   September 01, 2011
2012 Revisions to Medicare Fee Schedule Proposed
The ASHA Leader, September 2011, Vol. 16, 7. doi:10.1044/leader.BML2.16092011.7
The ASHA Leader, September 2011, Vol. 16, 7. doi:10.1044/leader.BML2.16092011.7
The proposed 2012 Medicare Physician Fee Schedule (MPFS) includes annual changes to valuations for audiology and speech-language pathology procedures, implements certain provisions of the Affordable Care Act and the Medicare Improvements for Patients and Providers Act of 2008, and discusses Physician Quality Reporting System issues related directly to speech-language pathology and audiology services.
The Centers for Medicare and Medicaid Services (CMS) posted the proposed rule on July 1, 2011; it was published in the Federal Register on July 19. The MPFS includes fees for audiology and speech-language pathology services.
CMS continues to take steps to ensure that MPFS fees reflect efficiencies that occur when services are furnished by a professional to a single beneficiary on the same day. This approach, known as the Multiple Procedure Payment Reduction (MPPR) Policy, affected several speech-language pathology procedures in 2011 (see The ASHA Leader, Dec. 21, 2010). CMS is inviting comment on applying the MPPR to all diagnostic tests, including audiology testing. CMS believes this approach would recognize the efficiencies in labor, supplies, and equipment realized when more than one diagnostic test is performed on the same patient during a single encounter.
Add-on codes (for services always provided in conjunction with another service) that have been valued accordingly could be excluded. Medicare has opposed the concept of paying more than once for the same history-taking or test interpretation for quite some time; this issue led to the institution of new “bundled” audiology codes (such as 92540, a basic vestibular evaluation that combines four vestibular tests). CMS has not included this change in the 2012 proposal, but is inviting comments on the concept.
Physician Quality Reporting System
CMS proposes to continue the current audiology and speech-language pathology Physician Quality Reporting System (PQRS) measures through 2012 and to add one new audiology measure. The three current audiology measures are referral for otologic evaluation for patients with congenital or traumatic deformity of the ear; history of active drainage from the ear within the previous 90 days; and a history of sudden or rapidly progressive hearing loss. The proposed audiology measure for 2012 is referral for otology evaluation for patients with acute or chronic dizziness. The eight speech-language pathology measures are functional communication measures for spoken language comprehension, attention, memory, motor speech, reading, spoken language expression, writing, and swallowing.
In 2011, the incentive payment for satisfactory reporting on measures is 1% of all allowable Medicare charges for that reporting period. The proposed rule sets an incentive payment of 0.5% for 2012–2014. Starting in 2015, eligible professionals who do not satisfactorily report on quality measures will be subject to a penalty (reduction in payments of 1.5% in 2015, and 2% in 2016 and each subsequent year).
Providers may report measures every six or 12 months. The proposal eliminates the six-month option.
Speech-language pathologists and audiologists interested in participating in PQRS can find further information at ASHA’s PQRS webpage (audiologists) and ASHA’s research webpage (SLPs).
Practice Expense Value Reductions
The MPFS incorporates the resource-based relative value scale (RBRVS). The scale divides each procedure into three components: the professional component or physician work, the technical component or practice expense (PE), and the malpractice component. PE comprises equipment, supplies, indirect expenses, and support-staff time.
For 2012, CMS is continuing the four-year phase-in of PE value reductions that began in 2010. The changes reflect survey data on average practice expenses of each specialty. Audiologists participated in the surveys, conducted in 2007–2008; at the time, however, SLPs were not eligible to bill Medicare directly and were not surveyed. As a “proxy” for practice-cost data for SLPs, CMS uses data on the costs of operating a physical therapy practice.
The changes in the practice expense formula primarily affect the calculation of indirect practice costs (office overhead, billing, rent, utilities, etc.). For 2012, practice expense values will be based on 25% of prior data and 75% of new survey data. This new system has negative effects on audiology and speech-language pathology, mostly because the costs of operating an audiology or speech-language pathology practice are substantially less than those of physicians. ASHA is analyzing the effect of the two PE calculation approaches and will send comment to CMS.
Group Treatment
Although ASHA has submitted survey data to show that group size for typical speech-language group treatment is two to three participants, CMS again proposes to adjust the PE for group treatment of speech, language, voice, communication, and/or auditory processing disorders. Current rules require calculation of the relative value of group speech-language treatment (CPT 92508) based on four participants. However, CMS is proposing to adjust the times for service based on six participants. Nine other procedures (e.g., group psychotherapy, group therapeutic procedures, medical nutrition group, and diabetes management training group) also would be subject to this restriction.
Overall Effects
The most critical issue for ASHA members is the effect of the proposed rule on payments to audiologists and SLPs in 2012. Congress has not yet resolved the issue of the formula that determines the annual MPFS update. Under current law and formula, across-the-board reductions of about 29% are indicated for all MPFS services. However, most observers including ASHA leadership are confident that the Congress will again act to prevent the implementation of these massive reductions in payment for all services. Table 1 [PDF] illustrates estimated 2012 rates for several CPT codes; these rates, which are based on the current 2011 formula (and not on the proposed 2012 schedule that is 29% lower) reflect the previously described change in relative values for practice expense.
ASHA leadership and staff are continuing to analyze this 600-plus page rule and will develop comments to CMS to try to minimize any adverse effect of the rule on ASHA members. The analysis will appear in a future issue of the Leader.
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September 2011
Volume 16, Issue 9