Medicare Releases 2015 Proposed Rules

July 7, 2014

The Centers for Medicare & Medicaid Services (CMS) posted the proposed 2015 Medicare Physician Fee Schedule (MPFS) [PDF] and associated rules for Medicare Part B services on July 3, 2014, and will publish it in the July 11, 2014, Federal Register. The proposal includes changes to reimbursement rates and the Physician Quality Reporting System (PQRS).

Physician Quality Reporting System (PQRS)

CMS continues to implement the rules established in 2014, which require private practice audiologists and speech-language pathologists to report the documentation of medications in the chart for 50% of the Medicare beneficiary patient visits in order to avoid the 2% penalty in 2017. However, CMS is recommending removal of the quality measure used by audiologists to report referrals to a physician for patients diagnosed with benign paroxysmal positional vertigo (BPPV) or dizziness. The CMS rationale for removal of this measure is that medical referral is a "common practice in order to provide effective treatment for patients."

For more information regarding PQRS, visit the ASHA PQRS webpage.

Therapy Cap Exceptions Process and Manual Medical Review

CMS will continue to administer the outpatient therapy cap exceptions process (using the KX modifier) and manual medical review at the $3,700 threshold for physical therapy and speech-language pathology services combined, which were extended through March 31, 2015, by the Protecting Access to Medicare Act of 2014, including for hospital outpatient departments.

More information on the therapy cap exceptions process and manual medical review is available on ASHA's billing and reimbursement webpages.

Proposed Fee Changes

A conversion factor (CF) is used to calculate the MPFS reimbursement rates. The Protecting Access to Medicare Act of 2014 will prevent a drastic reduction in the CF between January 1, 2015, and March 31, 2015. CMS estimates that the CF for this period will be $35.7997, a reduction of less than 1% of the 2014 CF. However, CMS has projected a conversion factor for the remainder of 2015 that is 20.9% lower than the current conversion factor. Although this reduction is mandatory because of a statutory formula known as the sustainable growth rate (SGR), it is anticipated that Congress will enact legislation to prevent this reduction as it has done almost every year since the SGR was implemented.

ASHA will be submitting comments, due September 2, 2014, to CMS. The final rules for 2015 are expected to be published by November 2014.


Each year CMS releases proposed rules and rates for the following year with a 60-day comment period. Audiology and speech-language pathology services under Medicare Part B (outpatient) have reimbursement rates established by the MPFS. Speech-language pathology services provided in hospital outpatient settings are also based on the MPFS, while audiology outpatient hospital services are paid under the Hospital Outpatient Prospective Payment System. ASHA continues to work with CMS officials and will submit comments-on behalf of audiologists and speech-language pathologists-that reflect ASHA member concerns.

ASHA Resources

Please see the September 1, 2014, issue of The ASHA Leader for additional details. The current fee schedule and related information for audiologists and SLPs can be found on ASHA's Medicare Fee Schedule webpage.

For more information on the proposed rule, contact Lisa Satterfield, ASHA's director of health care regulatory advocacy, at or Neela Swanson, ASHA's director of health care coding policy, at

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