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by Susan Boswell
Speech-language pathologists scored a victory in the 2004 Medicare Physician Fee Schedule with dramatic increases in reimbursement rates for dysphagia evaluation procedures. The rate increases came as the result of strong advocacy by the ASHA Health Care Economics Committee (HCEC) to rectify major reductions for dysphagia procedures in the 2003 fee schedule.
Next year, reimbursement for a clinical dysphagia evaluation (CPT 92610) will increase to $122.26 from $42.30, and the motion fluoroscopic evaluation of swallowing (CPT 92611) also will increase to $122.26, up from $45.98—representing an increase of more than 250% over the 2003 rates for these procedures. The fee schedule applies to all speech-language pathology and audiology Medicare Part B services, except for those audiology services provided in a hospital.
In a conference call with Centers for Medicare and Medicaid Services (CMS) officials shortly after the release of the 2003 fee schedule and during an April meeting, the HCEC emphasized that the fees for dysphagia assessment were far below the incurred costs.
"The CMS representatives welcomed us and were receptive to our concerns," said Dee Adams Nikjeh, a member of ASHA's HCEC and an SLP at Ear, Nose, and Throat Associates in Palm Harbor, FL. In September, ASHA argued that the proposed increase of 50% for the modified barium swallow study and 17% for the dysphagia evaluation did not make up for the value lost in 2003 when temporary Medicare "G" codes were replaced by CPT codes.
Based on feedback from SLPs nationwide, the HCEC stated that reductions in payment for 2003 reduced access to dysphagia services and prevented patients in need of dysphagia care from transferring to less costly treatment settings. "Many hospitals decided not to perform these procedures as they were now cost prohibitive," said R. Wayne Holland, a member of ASHA's HCEC and a private practice consultant. "Outpatient facilities, including nursing homes, also reduced swallowing services to their patients."
The HCEC urged CMS to consider factors in the dysphagia assessment procedures normally limited to the physician work component when determining the relative value unit. These factors include the technical skill, judgment, knowledge, and mental and physical effort needed by the highly trained professionals, who often hold doctoral degrees, in performing these procedures.
"It's a perfect illustration of member advocacy in action," Nikjeh said. "These services will now be more readily available for our patients, the dysphagia plan of care will be more accurate and complete, and ASHA members will be appropriately reimbursed for performing a valuable and skilled service."
Fee Schedule Analysis
As part of the fee schedule, CMS announced that the conversion factor, which adjusts the base formula for all Medicare services, will be $35.1339, a 4.5% drop from last year. Legislation enacted as part of a larger Medicare prescription drug benefit will increase the conversion factor by approximately 6%—or 1.5% over the published 2004 rate. CMS issued the final version shortly after the bill was signed into law.
In spite of the reduction in the conversion factor, the new rate for a speech-language evaluation is $125.07—34% above the 2003 rate. The increase is the result of survey data gathered by the HCEC, including time with the patient, post-visit time, and the cost of supplies and equipment.
The rate for speech-language pathology treatment was reduced to $59.37 from $77.25. Clinicians should note that the rate is per session and not time-based, and can be adjusted appropriately. The reduction could have been worse, but CMS accepted ASHA's position that the description of a typical case that was used to determine the relative value unit (RVU) was inappropriate because it reflected treatment for a child, typically seen for a shorter period of time than an adult patient. ASHA is pursuing changes in the typical case description to more accurately reflect clinicians' caseloads and consideration of practice expenses that reflect a more equitable reimbursement rate.
Reimbursement for group speech-language pathology treatment was also significantly reduced to $28.11 from $63.27. In treatment planning, clinicians should consider the total reimbursement rate in providing services for a group of three patients at this rate (a total of $84.33) compared to the rate for serving an individual patient ($59.37).
Rates for all audiology procedures were slightly reduced due to the reduction in the conversion factor and similar or slightly reduced RVUs.
Other than changes in reimbursement rates, CMS made no significant policy changes to the Medicare regulations in the final rule. Download ASHA's analysis of the 2004 Medicare Fee Schedule for Audiologists and the 2004 Medicare Fee Schedule for Speech-Language Pathologists. This Web page also provides a link to the final rule, published in the Nov. 7 Federal Register. For more information, contact Mark Kander by e-mail at mkander@asha.org or by phone through the Action Center at 800-498-2071, ext. 4139; or Ingrida Lusis at ilusis@asha.org or ext. 4482.
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