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ASHA Urges Immediate Action by CMS to Protect, Improve Medicare Beneficiaries’ Access to Needed Services

Vulnerable Patients at Risk of Serious Complications Without Medically Necessary Care, Association Stresses in Comment Letters

October 5, 2020

(Rockville, MD) In a series of comment letters delivered today to the Centers for Medicare & Medicaid Services (CMS), the American Speech-Language-Hearing Association (ASHA) is advocating for agency action on multiple fronts to improve access to telehealth services during the continuing COVID-19 public health emergency as well as to preserve Medicare beneficiaries’ access to medically necessary services provided by audiologists and speech-language pathologists, who are set to experience significant payment reductions in 2021.  

Medicare Physician Fee Schedule Payment Reductions to Hamper Access to Current Services

In CMS’s 2021 Medicare Physician Fee Schedule proposed rule, the agency recommends significant payment reductions to more than three dozen health care provider groups, including audiologists and speech-language pathologists. This is an effort to offset increasing payments for office/outpatient evaluation and management (E/M) codes typically used by primary care providers.  

Audiologists are facing a 7% cut to Medicare reimbursement, and speech-language pathologists are facing a 9% cut—which could hinder Medicare beneficiary access to diagnostic and therapy services for a range of hearing, balance, communication, cognition, and swallowing disorders common in seniors. These disorders are often a result of conditions that include stroke, brain injury, Alzheimer’s disease, Parkinson’s disease, and head and neck cancers, along with hearing loss—one of the most common health conditions that seniors experience. 

The proposed cuts are the result of a Medicare statutory requirement known as budget neutrality, which requires that any increase in costs to the Medicare program (in 2021, higher spending on E/M codes) must result in decreased spending elsewhere under Medicare. The cuts will go into effect in 2021 unless CMS or Congress take action to waive the budget neutrality requirement or hold affected providers harmless. Although ASHA supports increasing payment to primary care providers, the association stresses that such supports should not occur at the expense of other specialties, especially those who cannot bill E/M services.  

In a letter to CMS [PDF], ASHA 2020 President Theresa H. Rodgers, MA, CCC-SLP, notes that ASHA is “extremely concerned by the significant negative financial impact the budget neutrality requirement will have on many specialties—including audiology and speech-language pathology—that cannot report E/M services as part of their Medicare benefit category. ASHA urges CMS to consider the far-reaching implications of this policy, especially given the unprecedented circumstances facing the health care system at this time.”  

Rodgers further notes, “The unanticipated public health emergency (PHE) has resulted in significant economic challenges, causing increased concern regarding the sustainability of provider practices, especially those in rural or underserved areas. We also now know that the recovery and staggered return to full patient utilization of health care services will continue longer than initially expected.  

The cumulative impact of the E/M changes and the PHE will leave many providers unable to sustain their practices, further hampering economic recovery and restricting Medicare and non-Medicare patient access to medically necessary services, including the essential hearing, balance, speech, language, swallowing, and cognitive services audiologists and SLPs provide.” 

In addition to its own comment letter, ASHA has joined with a coalition of physician and nonphysician provider groups to encourage CMS take immediate steps to prevent cuts from going into effect on January 1. The coalition letter [PDF] details the potential consequences of such cuts, including crippling the recovery of the nation’s economy, undermining the health care system, reducing patient access to medically necessary specialty services, and reducing Medicare payment for services provided across health care settings—at a time when the spread of COVID-19 remains unchecked. 

Representatives Roger Marshall (R-KS) and Bobby Rush (D-IL) have also spearheaded a letter from Congress to CMS calling for the agency to “take immediate actions to delay or mitigate these cuts while allowing the scheduled increases to go into effect.” This letter garnered 161 signatories from a bipartisan group of Congressional representatives.

Expansion of Telehealth Services Needed for Hearing, Swallowing and Other Conditions 

With Medicare beneficiaries cut off from in-person evaluation and treatment services for neurodegenerative, hearing, balance and other conditions due to the pandemic—putting them at risk for falls, aspirating, and choking, among other complications—ASHA, along with its members and consumer partners, is also calling for increased access to clinically appropriate audiology and speech-language pathology Medicare telehealth services to address such needs.  

These telehealth services are already provided to many patients with Medicaid or commercial insurance. Allowing audiologists and speech-language pathologists to provide additional Medicare-covered services via telehealth would enable beneficiaries to access those same critical services.  

Shortly after the pandemic began and a national PHE was subsequently declared, CMS included a limited number of audiology and speech-language pathology services on its list of Medicare-covered telehealth services. Although this decision was a welcome first step, the telehealth list has not kept up with needs as the emergency has become prolonged and has changed the daily circumstances of Medicare beneficiaries. Most individuals with Medicare coverage cannot afford to pay for such services out of pocket, resulting in them forgoing needed care and putting them at risk. 

“Absent any means to receive core audiologic testing services via telehealth, Medicare beneficiaries with undiagnosed hearing or balance disorders face an even higher risk for isolation and depression,” ASHA said in a letter to CMS [PDF]. 

The association also expressed concern that Medicare beneficiaries with swallowing difficulties may not be identified for risk of aspiration due to their fears of in-person services during the pandemic.  Meanwhile, patients with neurodegenerative diseases, such as amyotrophic lateral sclerosis (ALS), that have sharply reduced their ability to communicate are cut off from using a speech-generating device because they lack coverage for a Medicare-required evaluation by a speech-language pathologist that would qualify them for the device.  

Separately, a coalition of patient organizations sent a letter to CMS [PDF] urging the agency to “expand coverage of certain telehealth services during the public health emergency to ensure that individuals with hearing, speech, swallowing, and cognitive impairments have access to medically necessary rehabilitative and habilitative services they need to restore, improve, and maintain their health and ability to function as independently as possible in the face of the COVID-19 pandemic.” 

Now, in addition to the other reasons ASHA has raised, there is a very timely imperative for CMS to increase beneficiary access to services via telehealth. With the nation heading into “the dangerous cold and flu season,” ASHA’s letter noted, allowing for Medicare coverage of these services via telehealth would enhance the “ability to meet the needs of patients, return clinical practices closer to normalcy, and further reduce the risk of transmitting COVID-19.” 

About the American Speech-Language-Hearing Association (ASHA) 
ASHA is the national professional, scientific, and credentialing association for 211,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Audiologists specialize in preventing and assessing hearing and balance disorders as well as providing audiologic treatment, including hearing aids. Speech-language pathologists identify, assess, and treat speech and language problems, including swallowing disorders.  


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