No Surprises in 2018 Proposed Medicare Outpatient Rules Fees for audiologists and SLPs remain stable, but look for a new cognitive function intervention code. Policy Analysis
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Policy Analysis  |   September 01, 2017
No Surprises in 2018 Proposed Medicare Outpatient Rules
Author Notes
  • Neela Swanson is director of ASHA health care coding policy. nswanson@asha.org
    Neela Swanson is director of ASHA health care coding policy. nswanson@asha.org×
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Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   September 01, 2017
No Surprises in 2018 Proposed Medicare Outpatient Rules
The ASHA Leader, September 2017, Vol. 22, 24-25. doi:10.1044/leader.PA.22092017.24
The ASHA Leader, September 2017, Vol. 22, 24-25. doi:10.1044/leader.PA.22092017.24
A new cognitive treatment code is included in proposed 2018 regulations for outpatient services provided to Medicare beneficiaries.
The Centers for Medicare and Medicaid Services (CMS) issued two proposed rules—the Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (OPPS). Medicare Part B outpatient audiology and speech-language pathology services fall under MPFS; most speech-language pathology services provided in hospital outpatient settings are also MPFS-based, whereas audiology outpatient hospital services are paid under the OPPS.
Although 2018 regulations propose no major changes in payments or quality reporting for audiologists or SLPs, there are some proposed fee changes and reductions in quality reporting penalties.
MPFS
Proposed rate changes
By law, the 2018 MPFS must include an overall 0.5-percent rate increase. However, reimbursement for some individual audiology and speech-language codes may change by a different amount because of changes to their assigned values. CMS predicts an overall 1-percent decrease to audiology reimbursement and no impact to speech-language services. ASHA will analyze changes in payment to individual procedure codes and other potential reasons for rate reductions and provide comments to CMS as appropriate.
No additional proposals related to the value of audiology services were included for 2018. However, speech-language pathologists should be aware of a potential change to reporting and payment for cognitive treatment services.
Cognitive function intervention coding and payment
ASHA and the American Psychological Association proposed—and the American Medical Association approved—a new Current Procedural Terminology (CPT® American Medical Association) code for cognitive function intervention (untimed). The proposed rule discusses the code, which would become effective Jan. 1, 2018, replacing current CPT code 97532 (development of cognitive skills), a timed code. The new code is defined as:
“Therapeutic interventions that focus on cognitive function (e.g., attention, memory, reasoning, executive function, problem solving, and/or pragmatic functioning) and compensatory strategies to manage the performance of an activity (e.g., managing time or schedules, initiating, organizing and sequencing tasks), direct (one-on-one) patient contact.”
The new code may be reported only once per day, and may not be billed in conjunction with individual adaptive behavior treatment codes (0364T, 0365T, 0368T, 0369T).
CMS has concerns about the code because of its untimed nature, and may propose an alternate code. Several providers—including SLPs, occupational therapists and psychologists—bill the current timed code in different amounts, and the change to an untimed code may affect overall costs for cognitive function intervention. CMS is actively seeking commentary on the new code and its impact on payment for cognitive treatment services, and ASHA will work with CMS and other stakeholders in its response.
CMS will provide more information on the new code for cognitive function intervention when the 2018 CPT code set is released by the American Medical Association (AMA).

By law, the 2018 MPFS must include an overall 0.5-percent rate increase. However, reimbursement for some individual audiology and speech-language codes may change by a different amount because of changes to their assigned values.

Patient relationship categories
CMS is seeking input on its new patient relationship categories and Level II Health Care Common Procedure Coding System (HCPCS) modifiers. This system—which adds a new level of reporting—defines the relationship of providers with each patient under their care and reflects the frequency of care. Physicians and some other health care providers must report the modifiers on Medicare claims submitted in 2018. ASHA anticipates that audiologists and SLPs will be required to report patient relationship categories as early as 2019, and will provide comments to CMS on the issue.
Quality initiatives
The proposed rule reduces penalties related to the value-based payment modifier (VBPM), which adjusts payment to individual providers based on the quality of their care. Although legislation exempts audiologists and SLPs from potential VBPM penalties in 2018 (based on their 2016 quality reporting), they are affected by the Physician Quality Reporting System (PQRS), which applies penalties in 2018 for unsuccessful reporting in 2016. The proposal reduces penalties for unsuccessful PQRS reporting from a maximum of 4 percent of total payment to a maximum of 2 percent of total payment. 2018 is the last year for PQRS-based payment adjustments.
Therapy caps and manual medical review
The rule does not address the exceptions process beyond the $1,980 annual cap or the manual medical review process for services exceeding the $3,700 threshold for combined physical therapy and speech-language pathology services, as those processes expire Dec. 31. ASHA expects to work with Congress to address the therapy cap before the current exceptions and manual medical review processes expire.

ASHA expects to work with Congress to address the therapy cap before the current exceptions and manual medical review process expires.

Outpatient Prospective Payment System (OPPS)
CMS proposes to increase OPPS rates by 1.75 percent, and estimates an overall 2-percent payment increase in 2018.
The proposal includes a key issue for audiology services: policies that determine whether specific audiology services are reimbursed when provided on the same day as other services in the hospital outpatient setting. Some audiology services are considered “ancillary” when provided on the same day and in the same facility as “primary” services (which could include, for example, a lab test). The proposal makes no changes to these policies, but ASHA continues to express concern.
The rule also includes changes to Ambulatory Payment Classifications that may affect payment for some audiology services, as well as a decrease in payment rates for certain off-campus, provider-based departments. ASHA will analyze these changes and provide comment to CMS on areas that directly affect audiologists.
ASHA Medicare Fee Resources

ASHA’s website lists the current Medicare fee schedule and hospital outpatient prospective payment system payments rates for audiologists and SLPs, as well as related information. That page will be updated when the final rule is released, typically in November.

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September 2017
Volume 22, Issue 9