The Centers for Medicare and Medicaid Services (CMS) has proposed a 4.3% cut in 2006 payments under the Medicare fee schedule as published in the Federal Register on August 8th. Several bills already have been introduced in Congress to repeal the statutory formula used to determine the payment reduction. Comments on the proposed rule are due by September 30.
ASHA expected CMS to propose an end to the non-physician work pool (NPWP) and CMS has included this in the proposed rule. CMS created the NPWP "to protect the technical component (TC) services from the substantial decreases…until further refinement could take place." CMS now wants to have the procedures that have no professional component or "physician work" value but only a TC included in the practice expense methodology used for all other procedures. CMS has proposed that the NPWP would begin a four-year phase out process in 2006.
Audiology procedures in the pool will be among those most negatively affected unless a methodology can be agreed upon between CMS and ASHA. CMS predicts that the value of the audiology procedures will be reduced by more than 21% by 2009. ASHA has been advocating for removal of audiology and speech-language pathology procedures from the NPWP by relocating the practice expense labor to the professional component (i.e., physician work) using survey data that ASHA can present to the AMA Health Care Professional Advisory Committee. ASHA is now intensifying these efforts with the publication of the proposed rule.
CMS provided proposed relative value units for all procedures. Incorporating the 4.3% cut in the conversion factor, those SLP and audiology procedures that have the most notable changes are: speech-language evaluation (+2 ½%), swallowing treatment (+5%), clinical swallowing evaluation (-13%), motion fluoroscopic swallowing evaluation (-10%), comprehensive audiometry (-5%), evoked otoacoustic emissions - limited (-13%), and evoked otoacoustic emission - comprehensive (-9%).
The proposed rule also makes clear that without congressional intervention, the annual (per beneficiary) combined therapy cap for physical therapy and speech-language pathology services, and a separate occupational therapy cap will again be in effect at the beginning of 2006. CMS estimates that the value of the cap for 2006 will be $1,750. ASHA is actively working with Congress and other rehabilitation groups to repeal or modify the reintroduction of the caps. For further information contact Mark Kander, Director of Health Care Regulatory Analysis, at mkander@asha.org or 800-498-2071, ext. 4139.
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