CMS Releases Proposed 2015 Rules Medicare tweaks reimbursement rates and quality reporting, and recommends dropping coverage of osseointegrated implants. Policy Analysis
Policy Analysis  |   September 01, 2014
CMS Releases Proposed 2015 Rules
Author Notes
  • Neela Swanson is ASHA director of health care coding policy.
    Neela Swanson is ASHA director of health care coding policy.×
  • Lisa Satterfield, MS, CCC-A, is ASHA director of health care regulatory advocacy.
    Lisa Satterfield, MS, CCC-A, is ASHA director of health care regulatory advocacy.×
Article Information
Hearing Aids, Cochlear Implants & Assistive Technology / Practice Management / Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   September 01, 2014
CMS Releases Proposed 2015 Rules
The ASHA Leader, September 2014, Vol. 19, 28-29. doi:10.1044/leader.PA1.19092014.28
The ASHA Leader, September 2014, Vol. 19, 28-29. doi:10.1044/leader.PA1.19092014.28
Proposed changes to Medicare policy for 2015 would affect reimbursement and rules for outpatient services, home health care, hospital admissions and osseointegrated implants.
The proposals, released by the Centers for Medicare and Medicaid Services in July, are followed by a 60-day comment period. Final rules, which take effect Jan. 1, 2015, will be published in late fall.
Medicare Physician Fee Schedule
The MPFS proposed rule includes projected updates to Medicare Part B reimbursement rates, changes to the Physician Quality Reporting System and increased scrutiny on potentially misvalued services.
Proposed fee changes. Legislation passed earlier this year protects reimbursement rates through March 31, 2015, at which point a mandatory reduction of more than 20 percent could go into effect. It is anticipated, however, that Congress will craft new legislation to prevent this reduction, as it has in the past.
Even without the possible April 1, 2015, mandatory cut, CMS predicts the total impact of proposed fee changes for audiology and speech-language pathology services to be a cumulative 1 percent decrease. The decrease comes from adjustments to factors that contribute to the value of certain procedures. All value adjustments are not final until published in the final rule in November.
Potentially misvalued codes. CMS is required to periodically identify, review and adjust for potentially misvalued procedure codes in the MPFS. For 2015, CMS has identified 65 potentially misvalued codes, including an audiology code—92557 (Comprehensive audiometry)—and a speech-language pathology code—31579 (Laryngoscopy with stroboscopy). ASHA will work with other specialty society stakeholders and the American Medical Association Relative Value Update Committee—which will review the codes—during the review process.
Quality reporting initiatives. The Physician Quality Reporting System continues to be penalty-based for private-practice audiologists and speech-language pathologists. The process for reporting in 2015 is essentially the same as in 2014: audiologists and SLPs must report the documentation of medication in the medical record for a minimum of 50 percent of their Medicare patient office visits or incur a 2 percent reduction in their 2017 Medicare reimbursements.
CMS also has proposed deleting the final audiology measure—referral for otologic evaluation for patients with chronic or acute dizziness—citing medical referral as a common practice.
In 2015, PQRS will expand for all providers to include the value-based payment modifier, which adjusts reimbursement—from negative 4 percent to 4 percent—based on providers’ PQRS reporting and cost efficiency. Audiologists and SLPs should familiarize themselves with the PQRS reporting requirements to prepare for 2015 rules. More information about how the value-based payment modifier will affect audiologists and SLPs will appear in the October 2014 Leader.
Home Health Prospective Payment System
The system proposes to increase reimbursement for a standard 60-day episode to $2,922.76, up from $2,869.27 in 2014. The per-visit payment for episodes with four or fewer total visits for SLPs is $151.85, up from $143.88.
The most significant proposal changes the therapy reassessment timeframe from the current “close to 13th and 19th visits” to at least once every 14 calendar days. In comments to CMS, ASHA supports the intent to simplify the reassessment process, but indicated that every 14 days is too frequent to document change in progress.
Hospital Outpatient Prospective Payment System
This bundled payment program includes audiology services. The proposed rate increase for hospital outpatient services is up 2.1 percent from 2014, with a conversion factor of $74.176. Proposed changes to the cochlear implant bundled payment include mandated claim reporting of the cost of the device, even though it is not paid separately, to allow rate-setting based on claims data. Additional proposed changes include the combination of lower-reimbursement bundles—such as audiology services—with another service unless it is performed independently.
Osseointegrated implants
CMS proposes reclassifying osseointegrated implants from their current category—prosthetic devices—to hearing aids. Because Medicare does not cover hearing aids under the regular Medicare benefit, the proposal effectively eliminates Medicare coverage of osseointegrated implants. CMS proposed this change after receiving requests to cover nonimplanted, bone-conduction hearing aid devices for single-sided deafness. CMS subsequently determined that all air- or bone-conduction hearing devices—whether external, internal or implanted—do not replace all or parts of internal body organs and, therefore, are not prosthetics.
ASHA commented that the osseointegrated implant does replace the components of the middle ear in cases of aural atresia, middle-ear malformations, and/or ossicular malformations; chronic otitis media not amenable to successful treatment; chronic tympanic membrane perforation not amenable to treatment; or combinations of these disorders.
In addition, ASHA reached out to other audiology and hearing-related organizations to coordinate a response to this proposal. Representatives from ASHA, American Academy of Otolaryngology-Head and Neck Surgery, American Academy of Audiology, Academy of Doctors of Audiology, American Cochlear Implant Alliance, Alexander Graham Bell Association for the Deaf and Hard of Hearing, Hearing Industries Association, and Hearing Loss Association of America met to work on ensuring that Medicare beneficiaries receive the devices they need. The result was a meeting with CMS officials and multiple comments from the participating organizations and other joint coalitions that clearly outline the need for continued coverage and a policy to determine candidacy. If CMS accepts the coverage determination policy, the organizations will continue to work together and with CMS to establish appropriate coverage within the scope of the law.

Get Set to Comply With ICD-10 by Oct. 1, 2015

Oct. 1, 2015, is the new deadline for transitioning to ICD-10, the 10th revision of the International Classification of Diseases, the U.S. Department of Health and Human Services announced in July.

The long-awaited transition from ICD-9, originally scheduled to take place this year, was postponed in March in last-minute legislation that averted steep cuts to 2014 Medicare reimbursement rates. The change allows providers, insurance companies and others in the health care industry time to ramp up their operations to ensure their systems and business processes are ready.

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September 2014
Volume 19, Issue 9