The Centers for Medicare & Medicaid Services (CMS) released the 2019 Proposed Rule for the Medicare Physician Fee Schedule (MPFS) [PDF] on July 12, 2019. Following is a summary of key issues for audiologists and speech-language pathologists (SLPs). ASHA will be developing and submitting official comment to CMS on the proposed rule.
Proposed Rate Change
CMS uses a conversion factor (CF) to calculate the MPFS reimbursement rates. For 2019, CMS estimates that the CF will be $36.0463 representing a slight increase over the $35.9996 CF for 2018. The update reflects the combination of a 0.25% payment update legislated by the Bipartisan Budget Act of 2018 and other mandated adjustments.
CMS also proposed to accept ASHA’s recommendations to maintain the current professional work values for CPT (Current Procedural Terminology® American Medical Association) codes related to standardized testing of aphasia (CPT 96105) and cognition (CPT 96125). These codes were part of a larger family of psychological and neuropsychological testing codes previously identified by CMS as potentially misvalued services and reviewed by the American Medical Association Relative Value Update Committee (AMA RUC). With the support of data collected from professional work surveys of SLPs, ASHA was able to work with the AMA to submit accurate recommendations to CMS that prevented significant reductions to payment for these evaluation services.
No additional proposals related to the value of audiology related services were included for 2019.
Quality Payment Program
The Quality Payment Program (QPP) is a combination program that is transitioning Medicare payments away from the volume-based fee for service system to a more quality and outcomes-based payment system. The program includes the Merit-Based Incentive Payment System and Advanced Alternative Payment Models
Merit-Based Incentive Payment System (MIPS)
MIPS is one track of the QPP whose aim is to focus on quality improvement in Medicare. For 2019, CMS does not propose to add audiologists and SLPs to MIPS because they intend to remove the interdisciplinary measures from the quality category that audiologists and SLPs are currently eligible to report. However, physical therapists and occupational therapists are in the initial proposal. CMS did request comments regarding its proposal to eliminate the interdisciplinary codes and indicated the potential for inclusion of additional professionals (including audiologists and SLPs) under MIPS for 2019. Given the lack of appropriate discipline-specific measures for ASHA members, a delay in the application of MIPS is appropriate and will allow ASHA to work with clinical experts to develop meaningful quality and outcome measures for reporting. ASHA will continue to pursue the adoption of appropriate measures for MIPS and the development of a clinical data registry to facilitate member reporting and participation in coming years when participation is mandated.
Advanced Alternative Payment Models (APMs)
APMs, a key initiative within the QPP, are Medicare approaches that incentivize for quality and value. APMs take a variety of forms: accountable care organizations, patient-centered medical homes, bundled payments, and episodes of care. Audiologists and SLPs are able to participate in the Advanced APM option in 2019. Those who successfully participate will be eligible to receive a 5% lump-sum incentive payment on their Part B services in 2021. An example of an Advanced APM is the Medicare Shared Savings Program ACO-Track 2.
Medicare Targeted Manual Medical Review
CMS notes in the proposed rule that the Bipartisan Budget Act of 2018 permanently repealed the hard caps on therapy services and permanently extended the targeted medical review process first applied in 2015. The proposed rule provides no additional information regarding potential changes to the targeted medical review process.
Functional Limitation Reporting (“G-codes”)
CMS has proposed to remove functional limitation reporting effective January 1, 2019. The removal of this requirement will reduce the claims reporting burden on therapy providers such as SLPs.
Other issues of interest addressed in the MPFS proposed rule include payment rates for certain categories of hospital off-campus provider-based departments and new CMS-developed codes for communication technology-based services.
Comments on the proposed rule are due September 10, 2018, and the final rule will be issued around November 1. The provisions of the final rule will be applicable to services provided from January 1, 2019 – December 31, 2019.
Additional details will be published in the September 1, 2018, issue of The ASHA Leader. Current 2018 Medicare Part B payment rates and related information for audiologists and SLPs are available on ASHA’s Outpatient Medicare Physician Fee Schedule webpage.
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