2008 Medicare Fee Schedule Proposed Professional Work Values Added for Audiologists, and 90-Day Recertification for SLPs Policy Analysis
Policy Analysis  |   August 01, 2007
2008 Medicare Fee Schedule Proposed
Author Notes
  • 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
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   August 01, 2007
2008 Medicare Fee Schedule Proposed
The ASHA Leader, August 2007, Vol. 12, 1-7. doi:10.1044/leader.PA.12102007.1
The ASHA Leader, August 2007, Vol. 12, 1-7. doi:10.1044/leader.PA.12102007.1
The Centers for Medicare and Medicaid Services (CMS) proposed a 2008 Medicare Physician Fee Schedule (MPFS) in July that categorizes audiology services as professional—rather than technical—for purposes of calculating reimbursement rates, and increases the recertification period for speech-language pathology services from 30 to 90 days.
CMS is accepting comments on the proposed rule until Aug. 31, and ASHA is carefully evaluating the proposals and will submit extensive comments. Any changes in the fee schedule would be effective with services rendered on or after Jan. 1, 2008.
Professional Work for Audiologists
Under the proposal, audiology services would be valued through the professional work component of the fee schedule and no longer through the practice expense component. This change is comparable to the manner in which the services of psychologists, optometrists, physical therapists, occupational therapists, and other non-physician practitioners are valued.
The change would apply only to eight audiology codes in 2008—four audiology evaluation codes (comprehensive hearing testing, acoustic reflex threshold testing, reflex decay testing, and visual reinforcement audiometry) and the four cochlear implant programming codes. Other audiology codes will likely be evaluated for professional work value in the future.
The audiology community sought this change because CMS was proposing substantial changes to the method of calculating practice expense values for services without a professional work value. The elimination of the method would have had negative consequences for most audiology services. After considerable discussions, CMS ultimately expressed its willingness to have the American Medical Association’s Relative Value Scale Update Committee (RUC) review the time and complexity of audiology services compared with physician and other professional services and assign a professional work value for audiology services.
To assist the RUC in this effort, ASHA and the American Academy of Audiology (AAA) conducted a large-scale online survey of audiologists to determine the time and professional skill involved in the procedures. In addition, the American Academy of Otolaryngology–Head and Neck Surgery (AAO-HNS) conducted a separate survey of its members who bill for audiology services. Both sets of data were presented to the RUC at its April 2007 meeting in Chicago.
The RUC bases its recommendations on a “typical” patient, and it relied heavily on the AAO-HNS data in making its recommendation to CMS because physicians, rather than independently practicing audiologists, bill a substantial majority of audiology services to Medicare.
ASHA’s initial analysis of the proposed rule suggests that the changes are positive for 2008 as compared with 2007 values. However, the new data are being phased in over the next three years and the proposed values assigned to these codes appear to be unfavorable in years after 2008. ASHA, working with AAA, will advocate for audiologists through its comments on the proposed rule and in further discussions with CMS to minimize any adverse effects.
Recertification Period for SLPs
CMS also proposed lengthening the recertification period for speech-language pathology services to 90 days from the current 30 days. While CMS specifies that providers “review and certify the initial plan of care as soon as possible,” the certification would apply “for an episode length based on the patient’s needs, not to exceed 90 days, and would be recertified every 90 days thereafter.”
The proposed change affecting SLPs protects a patient’s access to needed treatment when the certifying physician or non-physician provider (NPP) is unavailable at the 30-day interval. The proposal also reduces the administrative burden on providers, suppliers, physicians, NPPs, and Medicare contractors by reducing the frequency of necessary paperwork, and provides an appropriate timeline for monitoring the need for continued treatment.
ASHA’s comprehensive analysis of the entire proposed MPFS will be sent to members soon. The proposed rule [PDF, 1.9MB] was published in the July 12 Federal Register.
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August 2007
Volume 12, Issue 10