The Centers for Medicare & Medicaid Services (CMS) posted the proposed rule for the 2011 Medicare Physician Fee Schedule [PDF, 4MB] on June 25, 2010. ASHA is analyzing the 1,200 page rule and will be providing comments on the proposed changes by the deadline of August 24, 2010. There are several substantive first-time issues proposed that will affect speech-language pathologists and audiologists. The percentage reduction in rates is 6.1% in addition to the 21.3% reduction that has been delayed this year based on the sustainable growth rate (SGR) formula established in the Balanced Budget Act of 1997. However, we expect that Congress will, once again, act to prevent these reductions from taking place as has occurred for the past few years.
Multiple procedure payment reduction policy (MPPR) is proposed for therapy services. Medicare has a longstanding policy to reduce payment for the second and subsequent surgical and nuclear medicine procedures furnished to the same patient by the same practitioner on the same day. CMS proposes to expand MPPR to therapy services, making full payment for the therapy service or unit with the highest practice expense value. For additional procedures on the same day, a reduction would occur in the practice expense (i.e., supplies, equipment and indirect costs) but there would be no reduction in the professional work and malpractice expense components of the therapy service payment. MPPR will primarily affect professions that commonly bill multiple procedures or a timed procedure billed more than once per visit. Nine SLP procedure codes have been designated as applicable to MPPR. Thus, if a speech-language pathologist rendered a speech-language visit on the same day as a dysphagia visit to the same patient, payment for the latter would be reduced by 50% of its practice expense (yields a 24% reduction).
Alternatives to the therapy cap. CMS has requested comments on three proposals for developing an alternative to the cap. ASHA has been working with CMS-contracted research projects to develop these proposals over the past two years. Alternatives under consideration modify the current exceptions process based on severity and complexity; develop edits regarding medical necessity; or create per-session bundled payments. Absent congressional action, the exceptions process will expire on December 31, 2010.
Physician Quality Reporting Initiative (PQRI). CMS proposes to continue the current audiology and speech-language pathology PQRI measures through 2011. The three audiology measures are referral for otologic evaluation for patients with: congenital or traumatic deformity of the ear; history of active drainage from the ear within the previous 90 days; and a history of sudden or rapidly progressive hearing loss. The eight speech-language pathology measures are Functional Communication Measures for spoken language comprehension; attention; memory; motor speech; reading; spoken language expression; writing; and swallowing.
For 2010, the incentive payment for satisfactorily reporting on measures is 2% of all allowable Medicare charges for that reporting period. The proposed rule sets an incentive payment of 1% for 2011 and .5% for 2012-2014. Starting in 2015, eligible professionals that do not satisfactorily report on quality measures will be subject to a penalty. This penalty will be a reduction in payments of 1.5% in 2015, and 2% in 2016 and each subsequent year.
Currently, providers participating in PQRI need to report on 80% of patients that fit into a measure. In the proposed rule, providers would only need to report on 50% of patients that fit into a measure. Speech-language pathologists and audiologists that are interested in participating in PQRI can find further information on ASHA's Web site for audiologists and for speech-language pathologists.
Telehealth. CMS addresses telehealth services and again makes clear that such services are covered by Medicare only when specific professions are designated by law. However, ASHA expects to work with Center for Medicare and Medicaid Innovation (a department within CMS created under health care reform) in the near future on a pilot project involving telehealth services for stroke patients in rural areas.
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