ASHA and the American Academy of Audiology (AAA) have appealed the relative value units—a number used to determine reimbursement rates—assigned to billing codes for otoacoustic emission evaluations (OAE).
The OAE codes are new in 2012 (see The ASHA Leader, December 20, 2011). They describe limited evaluation (92587) and comprehensive diagnostic evaluation (92588). Values for each code in the Current Procedural Terminology (CPT; © American Medical Association) manual are determined by the Centers for Medicare and Medicaid Services (CMS) using a formula that includes, among other values, the professional work time involved in the procedure.
At a March meeting with CMS officials, ASHA and AAA argued that the professional work relative value units (RVUs) assigned to the OAE codes did not accurately represent the work involved in performing the procedures.
The initial RVU recommendation from the American Medical Association's RVU advisory committee were 0.45 work RVUs for CPT 92587 and 0.60 work RVUs for CPT 92588. The committee used survey data from ASHA and other audiology organizations for typical work time in determining those values. However, the rates assigned by CMS for 2012 were far below the recommendation: 0.35 RVUs for CPT 92587 and 0.55 RVUs for CPT 92588.
CMS, in its analysis of the OAE codes, used a massage therapy code for comparison. The result of this inappropriate comparison was a rank-order anomaly in audiology codes—that is, audiology procedure codes that involve less work have greater RVUs, and therefore higher reimbursement rates, than the OAE codes.
In the March meeting, ASHA and AAA explained to CMS staff the physiology of OAEs and the physical and analytical process for performing the procedures, and introduced other CPT codes for comparison.
Following the meeting, CMS invited ASHA and AAA to the 2012 Multi-Specialty Refinement Panel, the group responsible for making recommendations to CMS for alterations in work RVUs. The panel, composed of four Medicare contractor medical directors, heard the ASHA/AAA presentations, asked clarifying questions, then deliberated privately.
The refinement panel decisions will not be announced until the rates are published in the 2013 Medicare Physicians Fee Schedule.