July 5, 2011 Audiology

Medicare Audiology Coverage Debate: ASHA Supports Comprehensive Benefit Over Direct Access

Hearing health care organizations are united in their desire to increase access to audiology services for Medicare beneficiaries. There are a number of different perspectives, however, on what type of access is best for the profession.

ASHA's 2010 and 2011 public policy agendas—developed by the Government Relations and Public Policy (GRPP) Board with significant input from members—call for advocacy for comprehensive Medicare audiology benefit legislation, as does the proposed 2012 agenda, which is now undergoing peer review. ASHA has given serious consideration to the pros and cons of pursuing a comprehensive audiology benefit.

The decision to support a comprehensive Medicare audiology benefit that would cover audiologists' professional evaluation, management, and treatment services—rather than direct access—is based on several factors. The most compelling reason is that direct-access legislation has the very real potential to codify audiology services as diagnostic-only, thereby defining audiology services as technical (rather than professional) under Medicare.

ASHA leadership believes that the autonomy of the profession is best achieved through a comprehensive benefit that would reimburse audiologists for the full scope of Medicare-covered services for which they are qualified, rather than only for diagnostic testing with or without physician referral.

Under the current health care system, Medicare rates and coverage policies often influence other insurance coverage. Medicare determines its rates based on its classification of audiology services as diagnostic. Pursuing a Medicare direct-access bill that codifies this classification is not in the best interest of audiology or the patient.

ASHA believes that audiology services—diagnostic, rehabilitative, and intraoperative neurophysiologic monitoring—should be available to the entire Medicare population and not be limited to those who are able to pay out-of-pocket. ASHA will advocate for coverage of diagnostic, rehabilitative, and monitoring services provided by audiologists as part of a comprehensive Medicare benefit. This benefit would not include hearing aids or services associated with the fitting of a hearing aid, because they are not Medicare benefits.

ASHA also realizes that audiologists should have a choice of whom they serve. Therefore, any ASHA-proposed and advocated legislation would include an opt-out provision, so that audiologists may choose whether to provide services to Medicare beneficiaries.  

Ingrida Lusis, director of federal and political advocacy, can be reached at ilusis@asha.org.

cite as: Lusis, I. (2011, July 05). Medicare Audiology Coverage Debate: ASHA Supports Comprehensive Benefit Over Direct Access . The ASHA Leader.

Questions and Answers: Comprehensive Medicare Audiology Benefit

Q: Why does ASHA support a comprehensive Medicare audiology benefit instead of direct access?

Extensive analysis of the current political climate, the changing health care landscape brought about by new laws, the Centers for Medicare and Medicaid Services (CMS) and physicians' opposition to direct access, and the very real potential that direct access could codify audiology as a diagnostic-only service are the major factors. Although direct access has been heavily discussed and promoted in the past, support for direct-access legislation has dwindled on Capitol Hill. In the 111th Congress, the number of direct-access legislation cosponsors in the House decreased, and no companion legislation was introduced in the Senate.

Q: How did ASHA receive input on this issue?

The comprehensive Medicare benefit proposal was included in ASHA's 2010 Public Policy Agenda (PPA), which was sent for peer review to members in 2009. The 2011 PPA, which also includes the proposal, was distributed for peer review in 2010. In addition, ASHA discussed the issue with 10 other audiology organizations in two meetings in 2010. ASHA thoroughly reviewed and answered questions that arose in and after the meetings, and will continue to meet with these organizations.

Q: What is the financial impact of potential change?

ASHA staff will work with an actuarial firm to develop a cost estimate for the legislation. However, given that Medicare beneficiaries may receive audiologic rehabilitation and treatment services from other professionals, allowing audiologists to provide those services should not increase costs substantially.

The potential cost of direct access also concerns CMS and physicians. In its report to Congress, CMS addressed concerns that direct access could lead to inappropriate billing by audiologists for services that are not covered by Medicare. CMS views requiring physician orders and referrals as a way to control costs and service utilization.

Q: Will audiologists' services be subject to a therapy cap?

Medicare therapy caps specifically include the services of occupational therapists, physical therapists, and speech-language pathologists. ASHA's proposed legislation would not amend this part of the Medicare statute. In addition, many members of Congress do not support therapy caps.  

Q: Will a comprehensive benefit lower Medicare reimbursement rates for audiology services?

ASHA does not anticipate decreased reimbursement rates as a result of a comprehensive benefit. Audiology procedures are now viewed as professional rather than technical services under Current Procedural Terminology codes (CPT; ©American Medical Association), primarily due to ASHA's efforts representing audiology on the AMA committee that makes reimbursement recommendations to CMS. A comprehensive benefit would solidify ASHA's stance that audiologists provide professional services to Medicare beneficiaries, and would increase the number of patients eligible to see an audiologist for services beyond diagnosis.


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