Audiologists and speech-language pathologists (SLPs) have faced significant payment cuts to Medicare Part B (outpatient) services beginning in 2021. Although extensive advocacy by ASHA and other stakeholders resulted in legislation that mitigated the 2021 cuts, they are set to return in 2022 if Congress or the Centers for Medicare & Medicaid Services (CMS) do not intervene. ASHA is engaged in ongoing advocacy and collaboration with CMS, key decision makers—including members of Congress—and other provider groups to find short- and long-term solutions. These activities are a part of our overall efforts to ensure adequate Medicare reimbursement of audiology and speech-language pathology services.
In its release of the 2022 proposed rule for the Medicare Physician Fee Schedule (MPFS) for Part B services, CMS did not propose specific changes to mitigate the payment cuts set to return in 2022 for audiologists, speech-language pathologists (SLPs), and over 30 other Medicare provider groups. CMS uses an annual CF to calculate MPFS payment rates. For 2022, CMS estimates that the CF will be $33.59, representing a nearly 4% decrease from the $34.89 CF for 2021, and a nearly 7% decrease from the 2020 CF. As a result, absent additional intervention by Congress or CMS, audiologists and SLPs will continue to face significant payment cuts, based on the changes to the CF. The Centers for Medicare & Medicaid Services (CMS) estimates overall payment for audiology services will see a 1% decrease and speech-language pathology services will see a 2% decrease, in addition to the 3.75% decrease in the conversion factor (CF), the dollar amount CMS uses to calculate Medicare Part B payment rates. As a result, audiologists could see an overall payment decrease of 4.75% and SLPs could see a 5.75% decrease in 2022. For additional details, please see ASHA's summary policy analysis.
In addition to the cuts resulting from the E/M payment changes, sequestration cuts could also resume in 2022, meaning that audiologists and SLPs would see a steeper overall reduction in payments.
The payment reductions came about because CMS finalized changes to office-based outpatient evaluation and management (E/M) procedure codes, resulting in payment increases for primary care services beginning in 2021. Every year, CMS must ensure that rate changes for all procedure codes paid under the MPFS remain budget neutral, as mandated by law. As a result, Medicare Part B providers may see incremental decreases in payments annually when CMS shifts funding to accommodate increases in payments for other services. The negative impacts to audiologists and SLPs were higher than usual because of the significant increase in value for the new E/M codes. Although legislation significantly reduced the 2021 cuts, it didn't stop the E/M code changes, so the payment reductions will go into effect in 2022 to meet the budget neutrality mandate, unless Congress or CMS find short- and long-term policy solutions.
Other Medicare cuts unrelated to the E/M changes were also scheduled to take effect in 2021. These reductions resulted from sequestration, a 2011 law requiring automatic reductions in programs, such as Medicare, to impose fiscal restraint on federal spending. Advocacy by ASHA and other stakeholders helped lead to legislation postponing these cuts for 2021.
ASHA engages in ongoing advocacy with House and Senate members and staff directly and as part of a broad coalition of physician and nonphysician groups urging Congress to prevent resumption of the sequestration cuts and to seek short- and long-term solutions to preserve payment increases for primary care services without the negative impact to other provider groups, including audiology and speech-language pathology.
ASHA engages in ongoing advocacy with CMS and the Department of Health and Human Services (HHS) directly and as part of a broad coalition of physician and nonphysician groups to find regulatory solutions to preserve E/M related payment increases for primary care services without the negative impact to other provider groups, including audiology and speech-language pathology.