The Centers for Medicare & Medicaid Services (CMS) released the 2018 Proposed Rules for the Medicare Physician Fee Schedule [PDF] and Hospital Outpatient Prospective Payment System [PDF] on July 13, 2017. Following is a summary of key issues for audiologists and speech-language pathologists.
Medicare Physician Fee Schedule (MPFS)
Proposed Fee Changes
CMS uses a conversion factor (CF) to calculate the MPFS reimbursement rates. For 2018, CMS estimates that the CF will be $35.9903, representing a 0.5% payment update legislated by the Medicare Access and CHIP Reauthorization Act (MACRA) as well as other mandated adjustments.
The proposed rule also includes commentary regarding a new Current Procedural Terminology (CPT®) code for cognitive function intervention—effective January 1, 2018—and seeks input regarding the impact of the new code on payment for cognitive treatment services before implementing its use under the MPFS. ASHA will work directly with CMS and other stakeholders to address the issues raised in the commentary. Further information on the new code for cognitive function intervention will be made available when the 2018 CPT code set is released by the American Medical Association (AMA)
No additional proposals related to the value of audiology-related services were included for 2018.
CMS proposes measures to reduce the quality reporting burden on providers in an attempt to limit the negative impact of potential 2018 payment adjustments for quality reporting. CMS has reduced the required number of measures reported in 2016 for the 2018 payment adjustment from nine to six. This change will not impact payment adjustments for audiologists or speech-language pathologists as neither profession was eligible to report more than six measures in 2016.
CMS also proposes to reduce penalties related to the value-based payment modifier (VBPM), which adjusts fee schedule payment based on the quality of care furnished as compared to cost efficiency. Although previous legislation exempted audiologists and speech-language pathologists from potential VBPM penalties in 2018 based on 2016 quality reporting, this proposal ensures that potential unsuccessful Physician Quality Reporting System (PQRS) penalties for clinicians for 2016 claims will not exceed 2% in 2018.
Patient Relationship Categories
CMS has developed and is seeking input on patient relationship categories and Level II Health Care Common Procedure Coding System (HCPCS) modifiers that define the relationship of the qualified health care professional with each patient under their care and the frequency of care provided. The modifiers will be reported on Medicare claims submitted by physicians and applicable practitioners, however, audiologists and speech-language pathologists will not be required to use the patient relationship modifiers in 2018.
ASHA anticipates reporting of the patient relationship categories could be required of audiologists and speech-language pathologists as early as 2019, and as such, will provide comments regarding appropriate implementation of the modifiers in 2018 and beyond.
Medicare Therapy Cap Exceptions Process and Manual Medical Review
The proposed rule provides no additional information on the outpatient therapy cap exceptions process and the manual medical review process at the $3,700 threshold for physical therapy and speech-language pathology services combined, as they will expire on December 31, 2017. ASHA expects to work with Congress to address the therapy cap before the current exceptions and manual medical review process expires at the end of the year.
More information on the therapy cap exceptions process and manual medical review is available on ASHA's billing and reimbursement webpages.
Other issues of interest addressed in the MPFS proposed rule include payment rates for certain categories of hospital off-campus provider-based departments, telehealth services, and the Medicare shared savings program.
Hospital Outpatient Prospective Payment System (HOPPS)
Proposed Payment Update
CMS proposes to increase OPPS rates by 1.75 % and estimates an overall impact of 2.0% payment increase for hospitals paid under the OPPS in 2018.
A key issue related to audiology services in the 2018 proposed rule is classification changes that determine whether services are payed for separately when provided on the same day as other services. Additionally, changes to Ambulatory Payment Classifications (APCs) may result in adjusted payment rates for certain audiology services. ASHA will conduct a careful analysis of these changes and provide comment on areas that directly affect audiologists.
Each year, CMS releases proposed rules and rates for outpatient services for the following year, with a 60-day comment period. Audiology and speech-language pathology services under Medicare Part B have reimbursement rates established by the MPFS. Most speech-language pathology services provided in hospital outpatient settings are also based on the MPFS, whereas audiology outpatient hospital services are paid under the OPPS. ASHA continues to work with CMS officials and will submit comments—on behalf of audiologists and speech-language pathologists—that reflect ASHA member concerns.
Comments on the proposed rules are due September 11, 2017, and final rules will be issued around November 1. The provisions of the final rules will be applicable to services provided in 2018 (January 1–December 31).
Please see the September 1, 2017, issue of The ASHA Leader for additional details. The current outpatient payment rates and related information for audiologists and SLPs are available on ASHA's Outpatient Medicare Physician Fee Schedule webpage.
For more information on the proposed rules, contact Tim Nanof, ASHA's director of health care policy and advocacy, at firstname.lastname@example.org, or Neela Swanson, ASHA's director of health care coding policy, at email@example.com.