On November 27, 2013, the Centers for Medicare & Medicaid Services (CMS) released the final Medicare Physician Fee Schedule (MPFS) and associated rules [PDF] for 2014. The document includes regulations and rates for implementation on January 1, 2014, for audiologists and speech-language pathologists providing services to Medicare Part B beneficiaries under the MPFS. Key policies addressed in the final rule include the Physician Quality Reporting System and the therapy cap.
CMS established a conversion factor (CF) of $27.2006, which represents a 20.1% decrease from the current conversion factor and would affect all payments under the MPFS. Although the reduction is mandatory, please note that Congress has taken action to prevent similar reductions almost every year since the initiation of a statutory formula known as "the Sustainable Growth Rate."
Multiple Procedure Payment Reduction (MPPR) Policy
CMS has not adopted any new MPPR policies for 2014. Under MPPR, per-code reimbursement is decreased when multiple codes are performed for a single beneficiary in the same day. See ASHA's website for more information on the application of MPPR.
New Speech-Language Pathology Evaluation Codes
Effective January 1, 2014, there are four new speech-language pathology evaluation codes related to fluency, speech sound production, language, and voice and resonance. These codes replace CPT 92506 (Evaluation of speech, language, voice, communication, and/or auditory processing) and have been included in the 2014 MPFS. They are:
- 92521 Evaluation of speech fluency (e.g., stuttering, cluttering)
- 92522 Evaluation of speech sound production (e.g., articulation, phonological process, apraxia, dysarthria);
- 92523 Evaluation of speech sound production (e.g., articulation, phonological process, apraxia, dysarthria); with evaluation of language comprehension and expression (e.g., receptive and expressive language)
- 92524 Behavioral and qualitative analysis of voice and resonance
CMS has added these new codes to the "always therapy" list, meaning that they are services that are only paid by Medicare when provided under a therapy plan of care. As such, the new codes are also subject to the therapy cap and MPPR.
The final rule reiterated that the current exceptions process for the therapy cap will expire on December 31, 2013, absent Congressional action. For 2014, CMS has calculated that the therapy cap will increase from $1,900 to $1,920, and the therapy cap provisions have been extended to Critical Access Hospitals (CAHs) independent of any legislative extension to outpatient hospital departments.
Go to ASHA's Take Action site to tell your members of Congress to allow the exceptions process to continue in 2014 and to exempt outpatient hospital departments from the provisions of the therapy cap.
Physician Quality Reporting System
Reporting for audiology and speech-language pathology through the Physician Quality Reporting System (PQRS) remains required in 2014 to avoid the penalty assessed on 2016 claims for audiologists and speech-language pathologists in private or group practices. The final rule eliminated several measures, resulting in two general claims-based-only measures for speech-language pathologists in 2014. Audiologists are limited to three measures: one audiology specific and two general measures. In order to avoid the penalty in 2016, audiologists and speech-language pathologists will need to report one or two measures throughout the year for 50% of the eligible patient visits.
Further analysis is still necessary and will be available on ASHA's Billing & Reimbursement website, in future ASHA Leader articles, and through ASHA Headlines. Questions may be directed to [email protected].