New Cognitive Treatment Code Takes Effect In 2018 outpatient reimbursement rules, Medicare creates its own cognitive treatment code and keeps reimbursement rates stable. Policy Analysis
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Policy Analysis  |   January 01, 2018
New Cognitive Treatment Code Takes Effect
Author Notes
  • Neela Swanson is ASHA’s director of health care coding policy. nswanson@asha.org
    Neela Swanson is ASHA’s director of health care coding policy. nswanson@asha.org×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   January 01, 2018
New Cognitive Treatment Code Takes Effect
The ASHA Leader, January 2018, Vol. 23, 24-26. doi:10.1044/leader.PA.23012018.24
The ASHA Leader, January 2018, Vol. 23, 24-26. doi:10.1044/leader.PA.23012018.24
Two Medicare rules implemented Jan. 1 affect reimbursement rates for audiologists and speech-language pathologists in outpatient settings and audiologists in hospital outpatient departments.
SLPs should also heed two new—but different—procedure codes for cognitive treatment and understand which insurers accept each code.
Medicare Physician Fee Schedule (MPFS)
Rules under the Medicare Physician Fee Schedule (MPFS) apply to all Part B (outpatient) speech-language pathology services. Outpatient audiology services are also paid under the MPFS, unless they are provided in a hospital outpatient setting.
Payment rates
Part B reimbursement is calculated using an annually revised conversion factor (CF). The 2018 CF of $35.9996—representing a slight increase from the 2017 CF of $35.8887—reflects a statutory update and other mandated adjustments that maintain budget neutrality. Medicare calculates a net 0-percent impact for audiology and speech-language pathology services from the CF and other adjustments, so audiologists and SLPs will experience only minor shifts in 2018 payment rates.

Medicare calculates a net 0-percent impact for audiology and speech-language pathology services, so audiologists and SLPs will experience only minor shifts in 2018 payment rates.

New code(s) for cognitive treatment
A new CPT (Common Procedural Terminology, © American Medical Association) code for cognitive treatment takes effect Jan. 1. CPT 97127 (cognitive function intervention, untimed) replaces CPT code 97532 (cognitive skills development, each 15 minutes).
However, the Centers for Medicare and Medicaid Services (CMS) has assigned the new code a status of “invalid,” meaning that it will not recognize CPT 97127 for Medicare payment. Instead, CMS created a G-code to report cognitive treatment services:
“G0515, development of cognitive skills to improve attention, memory, problem-solving (includes compensatory training), direct (one-on-one) patient contact, each 15 minutes.”
G0515 contains the same descriptor as the former CPT code 97532, and the payment rate is similar. Clinicians who provide cognitive treatment services to Medicare patients should bill G0515 in the same way they billed 97532.
Many other insurers may follow the CMS rule, or they may accept CPT 97127. SLPs who bill cognitive treatment services for patients with a non-Medicare payer (Medicaid, Medicare Advantage or Part C, or private health insurance) should check with each patient’s payer to verify which code—CPT 97127 or G0515—should be billed on the claim form. SLPs should also confirm that payment for CPT 97127 reflects a full session and not a 15-minute unit.
The change in code does not change Medicare policies regarding providing and paying for cognitive treatment. For example, as with former code 97532, SLPs should not bill G0515 on the same day as CPT 92507 (speech, language, voice, communication treatment). The National Correct Coding Initiative provides further detail on CMS rules related to same-day billing of CPT codes.
Therapy cap
The 2018 therapy cap for combined speech-language pathology services and physical therapy services is $2,010. The 2017 therapy cap exceptions process—along with the manual medical review process for services that exceed a $3,700 threshold—is set to expire on Jan. 1. ASHA is working with Congress to avoid implementation of the cap in 2018.
Physician Quality Reporting System (PQRS)
Audiologists and SLPs who didn’t meet 2016 PQRS reporting requirements will see a 2-percent reduction in their 2018 Medicare Part B reimbursements. Audiologists and SLPs who provide services to Part B beneficiaries have been required to report PQRS quality measures since 2007, with penalties for not meeting reporting requirements starting in 2015.
The PQRS program ended Jan. 1, 2017, so the 2018 PQRS penalties will be the last under this program.
Patient relationship categories and modifiers
In 2018, CMS is requiring physicians and some other health care providers filing claims to describe their relationship to each Medicare beneficiary they treat, as a way of collecting data on attribution of resources to clinicians and to inform future quality reporting and payment initiatives.
The five relationship categories are included as Level II HCPCS (Health Care Common Procedure Coding System) modifiers. Audiologists and SLPs are not required to report these modifiers in 2018, but ASHA anticipates that CMS will require their participation as early as 2019.
The modifiers are:
  • X1, Continuous/broad services

  • X2, Continuous/focused services

  • X3, Episodic/broad services

  • X4, Episodic/focused services

  • X5, Only as ordered by another clinician

Hospital Outpatient Prospective Payment System (OPPS)
Hospital outpatient-based audiology services are paid under the Hospital Outpatient Prospective Payment System (OPPS). Medicare estimates that providers paid under the OPPS will see an overall 1.4-percent increase in reimbursement in 2018.
Basic vestibular evaluation
ASHA submitted comments regarding CPT 92540 (basic vestibular evaluation), requesting a change from its current Ambulatory Payment Classification (APC). In 2017, the payment for 92540 was cut by more than 40 percent when CMS reclassified the code. CMS did not accept comments from ASHA and other stakeholders and, therefore, CPT 92540 remains in its current lower-paying classification.
Comprehensive audiometry
Medicare classifies CPT code 92557 (comprehensive audiometry) as an “ancillary” service under the OPPS, meaning that it is not separately paid when provided on the same day as other services. ASHA and other stakeholders have repeatedly requested the reclassification of 92557, so that CMS will pay for this key diagnostic test separately, regardless of other services provided to the patient on the same day. CMS did not accept the comments, and CPT code 92557 will remain classified as an “ancillary” service under OPPS.
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January 2018
Volume 23, Issue 1