The Centers for Medicare & Medicaid
Services (CMS) posted the proposed 2015
Medicare Physician Fee Schedule (MPFS) [PDF] and associated rules for Medicare
Part B services on July 3, 2014, and will publish it in the July 11, 2014,
Federal Register. The proposal includes changes to reimbursement rates
and the Physician Quality Reporting System (PQRS).
Reporting System (PQRS)
CMS continues to implement the rules established
in 2014, which require private practice audiologists and speech-language
pathologists to report the documentation of medications in the chart for 50% of
the Medicare beneficiary patient visits in order to avoid the 2% penalty in
2017. However, CMS is recommending removal of the quality measure used by
audiologists to report referrals to a physician for patients diagnosed with
benign paroxysmal positional vertigo (BPPV) or dizziness. The CMS rationale for
removal of this measure is that medical referral is a "common practice in order
to provide effective treatment for patients."
For more information
regarding PQRS, visit the
ASHA PQRS webpage.
Therapy Cap Exceptions Process and Manual Medical Review
CMS will continue to administer the outpatient therapy
cap exceptions process (using the KX modifier) and manual medical review at the
$3,700 threshold for physical therapy and speech-language pathology services
combined, which were extended through March 31, 2015, by the Protecting Access
to Medicare Act of 2014, including for hospital outpatient departments.
More information on the therapy
cap exceptions process and manual medical review is available on ASHA's
billing and reimbursement webpages.
Proposed Fee Changes
A conversion factor (CF) is used to calculate the MPFS reimbursement rates. The
Protecting Access to Medicare Act of 2014 will prevent a drastic reduction in
the CF between January 1, 2015, and March 31, 2015. CMS estimates that the CF
for this period will be $35.7997, a reduction of less than 1% of the 2014 CF.
However, CMS has projected a conversion factor for the remainder of 2015 that is
20.9% lower than the current conversion factor. Although this reduction is
mandatory because of a statutory formula known as the sustainable growth rate
(SGR), it is anticipated that Congress will enact legislation to prevent this
reduction as it has done almost every year since the SGR was implemented.
ASHA will be submitting comments, due September 2, 2014, to CMS. The final
rules for 2015 are expected to be published by November 2014.
Each year CMS releases proposed rules and rates for the
following year with a 60-day comment period. Audiology and speech-language
pathology services under Medicare Part B (outpatient) have reimbursement rates
established by the MPFS. Speech-language pathology services provided in hospital
outpatient settings are also based on the MPFS, while audiology outpatient
hospital services are paid under the Hospital Outpatient Prospective Payment
System. ASHA continues to work with CMS officials and will submit comments-on
behalf of audiologists and speech-language pathologists-that reflect ASHA member
Please see the September 1, 2014, issue of The ASHA Leader for additional details. The current fee schedule and
related information for audiologists and SLPs can be found on ASHA's
Medicare Fee Schedule webpage.
For more information on the proposed
rule, contact Lisa Satterfield, ASHA's director of health care regulatory
advocacy, at firstname.lastname@example.org or
Neela Swanson, ASHA's director of health care coding policy, at email@example.com.