2004 Fee Schedule Challenged ASHA Urges Increases in Medicare Fees in Proposed Schedule Policy Analysis
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Policy Analysis  |   October 01, 2003
2004 Fee Schedule Challenged
Author Notes
  • Mark Kander, is ASHA’s director of health care regulatory analysis. Contact him by e-mail at mkander@asha.org.
    Mark Kander, is ASHA’s director of health care regulatory analysis. Contact him by e-mail at mkander@asha.org.×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   October 01, 2003
2004 Fee Schedule Challenged
The ASHA Leader, October 2003, Vol. 8, 1-28. doi:10.1044/leader.PA.08192003.1
The ASHA Leader, October 2003, Vol. 8, 1-28. doi:10.1044/leader.PA.08192003.1
On Aug. 15, the Centers for Medicare and Medicaid Services (CMS) published proposed 2004 outpatient Medicare fees that appear to include good news—two substantial increases. The proposed 50% increase in the relative value for the modified barium swallow study (MBS) and a 17% increase for the clinical dysphagia evaluation, however, do not compensate for the drastic reductions that occurred in 2003. The proposed increase would yield a 2004 MBS rate of approximately $69, which is 46% less than the 2002 fee.
Last year, CMS did not allow ASHA to respond to proposed 2003 rates for the clinical dysphagia evaluation and MBS because the Current Procedural Terminology (CPT) codes (92610 and 92611) were new and appeared only in the final Medicare Physician Fee Schedule. Nevertheless, the ASHA Health Care Economics Committee held a conference call with CMS officials shortly after the release of the 2003 fee schedule and met with them in April 2003. The committee stressed in the meetings the negative impact caused by the 2003 fee decreases and urged CMS to recognize that speech-language pathologists’ work must be reflected beyond time alone.
In a formal response to the 2004 proposed fees, ASHA recommended the consideration of factors for the dysphagia assessment procedures normally limited to the physician work component in the determination of relative value units. Such factors are technical skill, judgment, knowledge, and mental and physical stress. CMS staff indicated a possibility that these factors could be used as a basis for increases during the final relative value determination process. As an alternative, ASHA suggested placing these procedures in the non-physician work pool for which the new codes now qualify. The two dysphagia codes in the non-physician work pool could each be based on the 1998 Medicare Physician Fee Schedule fee for dysphagia evaluation which, until 2001, consisted of one code to represent the clinical evaluation as well as the MBS.
Speech-Language Pathology Evaluation and Treatment (CPT 92506 and 92507)
CMS proposed a 40% increase in the relative value of the speech and language evaluation. However, the treatment session experienced a proposed 28% reduction. ASHA requested a revision to the treatment rate through the substitution of a 70-year-old male stroke case as the typical case, instead of the 3-year-old child designated as typical for the time surveys completed by ASHA and the American Academy of Otolaryngology-Head and Neck Surgery. This substitution of the “typical case” represents a face-to-face session that is much longer than the 30-minute session associated with a young child, which translates into a higher fee.
Qualifications of Clinicians Who Work for Physicians
In the proposed Medicare Physician Fee Schedule, CMS also requested public comments on the possible establishment of a national standard for the professional qualifications of clinicians who provide services incident to a physician’s service. ASHA agreed that the current qualifications established in regulations for institutional settings—and considered appropriate by CMS for physician offices—are the education and experience equivalent to the requirements for ASHA certification. A person in the process of completing the supervised experience requirement (e.g., the clinical fellow) also meets the current regulatory qualifications. ASHA expressed a strong recommendation that the quality of rehabilitation services in physician offices be protected by the adoption of this standard. This is because, under current Medicare law, those who provide speech-language pathology services, physical therapy, and occupational therapy as physician employees or contractors are exempt from state licensure requirements. ASHA cited other federal laws and regulations that encourage the adoption of private qualification standards.
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FROM THIS ISSUE
October 2003
Volume 8, Issue 19