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The Medicare Fee Schedule sets the reimbursement rates for all outpatient speech-language pathology services and for audiology services provided in physicians' offices and audiologists' offices. The fee schedule includes values for each procedure using three components: (1) the professional component or work, (2) the technical component or practice expense, and (3) the malpractice component. The Centers for Medicare and Medicaid Services (CMS) has published two proposed regulations for revising the fee schedule. The first responded to a review of specific procedures where elements of the values are said to have changed and to address a change in the calculation of the practice expense component. The second proposal addressed other annual changes to the 2007 fee schedule. This message reflects changes from both proposed regulations.
CMS has proposed a decrease of over 5% for all fee schedule payments in 2007 due to changes in Medicare's conversion factor resulting from the Sustainable Growth Rate (SGR), unless Congress again intervenes. ASHA is working with provider groups to help gather congressional opposition to the proposed cut and to replace the flawed annual update formula for the Medicare fee schedule. More than 80 Senators, organized by Senators Jon Kyl (R-AZ) and Debbie Stabenow (D-MI), have signed such a letter. A similar letter is being circulated in the House by Representatives Nancy Johnson (R-CT) and Ben Cardin (D-MD).
A major concern for audiology and speech-language pathology (SLP) procedure values has been the proposed elimination of the non-physician work pool (NPWP)-a method established by CMS for determining the practice expenses of services without a "physician work" value. This included the technical components of most audiology services and certain speech language pathology codes as well as radiology and cardiology services.
CMS first announced its goal to eliminate the NPWP in 2005. Under their initial proposal, payments for audiology would have been reduced by 17%. ASHA argued strongly against the proposed changes and presented several options to CMS for moderating the proposed reductions in payment. Because of objections raised and technical errors discovered in the proposal, CMS decided not to implement any of the practice expense changes for 2006.
For 2007, CMS announced a modified revision of the practice expense methodology that represents a significant improvement from its initial proposal. If implemented in its current form, audiology services would see about a 3% reduction in payment over a 4-year transition period. However, some audiology procedures that are frequently provided would receive an increase over time. For example, the values for pure tone, air and bone testing, cochlear implant programming, the new tinnitus assessment procedure, and comprehensive audiometry would all be increased. However, some high-volume audiology procedures, such as acoustic reflex threshold testing, are proposed for substantial reductions.
The situation is also mixed for SLP procedures. While the SLP evaluation and treatment codes are proposed for increases, the clinical swallow evaluation and the modified barium swallow evaluation would be substantially reduced under the proposed rule. CMS officials have told ASHA that the 4-year transition will allow for corrections to those procedures that have their values unfairly reduced.
ASHA recently submitted comments on the first proposed rule stressing the negative impact of the proposed changes and the professional role of the speech-language pathologists and audiologists. ASHA recommended that CMS calculate the values of the procedures performed by the two professions in the same manner as they do for physical therapists, occupational therapists, and psychologists, utilizing the professional component of the fee schedule formula. ASHA recommended several interim approaches to CMS for moderating the proposed reductions in payment for audiology and SLP procedures since this issue is unlikely to be resolved by the time a final rule is issued in early November.
Members may view ASHA's comment letter to CMS on the Billing & Reimbursement section of ASHA's Web site. For further information, please contact Mark Kander, ASHA's Director of Health Care Regulatory Analysis, by e-mail at mkander@asha.org or by phone at 800-498-2071, ext. 4139, or Steven White, ASHA's Director of Health Care Economics and Advocacy, at swhite@asha.org or 800-498-2071, ext. 4126.
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