Medicare Proposes New Codes and Reporting Measures, Payment Cuts, and Continued Telehealth Coverage for 2024

The Centers for Medicare & Medicaid Services (CMS) has released the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, which establishes payment policies and rates for Part B (outpatient) audiology and speech-language pathology services. Significant policies addressed in this rule include—but are not limited to—new codes for auditory osseointegrated device (AOD) programming and caregiver training; payment cuts for audiology, speech-language pathology, and other services; audiology access; telehealth services; quality reporting; and alternative payment models.

ASHA will submit comprehensive comments on the proposed rule by early September and the final rule will apply to services provided in the 2024 calendar year.

The following information highlights key provisions impacting audiologists and speech-language pathologists (SLPs). We will post a more detailed summary of these and other proposed changes on ASHA’s website next week, and will also share through ASHA Headlines.

Payment Rates and Coding Updates

Conversion Factor

CMS uses an annual conversion factor (CF) to calculate MPFS payment rates. For 2024, CMS estimates that the CF will be $32.7476, representing a 3.36% decrease from the $33.89 CF for 2023. The proposed decrease in the CF is mostly due to expiration of the temporary 2.5% positive adjustment that Congress implemented to mitigate significant payment cuts in 2023 and Medicare’s requirement to maintain a budget neutral program. However, it’s important to note that the proposed CF includes a 1.25% increase required by Congress to help mitigate the 2024 payment cuts.

ASHA continues to work with a large coalition of health care provider groups to find short and long-term solutions to address Medicare payment issues, including supporting H.R. 2474, the Strengthening Medicare for Patients and Providers Act. ASHA members can take action by urging their members of Congress to improve fiscal stability for Medicare providers by supporting H.R. 2474, which would provide an annual inflationary payment update based on the Medicare Economic Index (MEI).

Coding Updates

CMS proposes to add five new Current Procedural Terminology (CPT®) codes related to AOD programming (3 codes) and caregiver training (2 codes) as covered services under the 2024 MPFS. ASHA worked with stakeholders to develop and value the new procedure codes through the American Medical Association’s (AMA) code development process [PDF].

Auditory Osseointegrated Device (AOD) Services

Effective January 1, 2024, audiologists will see two new timed codes describing the first hour and each subsequent 15 minutes of time for the analysis, programming, and verification of an auditory osseointegrated sound processor. CMS proposes to add both codes to the list of services that can be billed with an AB modifier when performed by an audiologist without a physician referral for a nonacute hearing condition.

ASHA will post more information on the new codes, including final code numbers, on ASHA’s coding webpage when the AMA releases the 2024 CPT code set in September.

Caregiver Training

Beginning in 2024, SLPs can report caregiver training services (CTS) without the patient present when provided under an established, individualized, and patient-centered plan of care. This proposed rule marks the first time CMS will allow therapists, including SLPs, to bill and receive MPFS payment for services without the patient present. CMS acknowledges the importance and efficacy of reasonable and necessary caregiver training to influence successful health outcomes for patients.

The three new codes will be billed based on the individual patient whose caregiver(s) require training to assist with the treatment plan and facilitate functional performance in the home or community. Billing will not be based on the number of caregivers present during the training session.

ASHA will post more information on the new codes, including final code numbers, on ASHA’s coding webpage when the AMA releases the 2024 CPT code set in September.

Access to Audiology Services and AB Modifier

In 2023, CMS implemented a policy that allows audiologists to provide nonacute hearing assessment services under limited circumstances without a physician order. No substantive changes were made to this policy with the exception of adding two CPT codes to the list of services that can be provided without an order—926X1 and 926X2—bringing the total number of services that can be provided under the limitations of the policy to 38 CPT codes. More details regarding this policy can be found on the ASHA website.

Telehealth

CMS implements the requirements of the Consolidated Appropriations Act of 2023 (CCA) by extending telehealth coverage of audiology and speech-language pathology services paid under the fee schedule through December 31, 2024. All CPT codes covered under the federal public health emergency (PHE) will remain covered through the end of next year.

CMS also seeks feedback on coverage of outpatient physical and occupational therapy and speech-language pathology services provided by institutional providers, including hospital outpatient departments, skilled nursing facilities, and home health agencies. As they analyze this feedback, CMS proposes that institutional providers continue to bill for telehealth services as they did under the PHE through December 31, 2024.

ASHA remains committed to securing permanent authority for audiologists and SLPs to receive reimbursement for services provided via telehealth at parity with reimbursement for in-person services. Please visit ASHA's Take Action site to contact your members of Congress to advocate for permanent telehealth coverage under Medicare.

Merit-Based Incentive Payment System (MIPS)

The audiology specialty measure set for the 2024 performance/2026 payment year would include two new measures:

• Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented: Percentage of patient visits for patients aged 18 years and older seen during the measurement period who were screened for high blood pressure AND a recommended follow-up plan is documented, as indicated, if blood pressure is elevated or hypertensive
• Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health-related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least 1 of their HRSNs within 60 days after screening

The Speech-Language Pathology specialty measure set for 2024 would add three measures for the 2024 performance/2026 payment year:

• Assessment of Cognitive Impairment or Dysfunction for Patients with Parkinson’s Disease: Percentage of all patients with a diagnosis of Parkinson’s Disease (PD) who were assessed for cognitive impairment or dysfunction once during the measurement period
• Screening for Social Drivers of Health: Percent of patients 18 years and older screened for food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety
• Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health-related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least 1 of their HRSNs within 60 days after screening

Clinicians continue to be excluded from mandatory MIPS participation if they have allowed charges for covered professional services less than or equal to $90,000, furnish covered professional services to 200 or fewer Medicare Part B-enrolled individuals, or furnish 200 or fewer covered professional services to Medicare Part B-enrolled individuals. As a result, ASHA estimates that less than 1% of its members are subject to MIPS.

ASHA Resources

The current 2023 Medicare outpatient payment rates and related information for audiologists and SLPs are available on ASHA’s website.

Questions?

Please contact reimbursement@asha.org.