November 9, 2022
Late November 1, 2022, the Centers for Medicare and Medicaid Services (CMS) issued the Final Rule on the 2023 Medicare Physician Fee Schedule (MPFS). The Academy has compiled a chart of 2023 reimbursement values for audiology codes, available here. This Final Rule contains significant provisions for the delivery of audiology services. We have provided an overview of important provisions below.
The final 2023 Medicare conversion factor is $33.06, reduced from the 2022 final conversion factor of $34.61. The Final Rule establishes a 4.47% cut to payments under the 2023 fee schedule unless Congress can pass legislation that would offset or mitigate this reduction in payment. Stakeholders had hoped for an improvement over the proposed rule’s 4.42% reduction to the conversion factor (CF), but the final rule’s methodology resulted in a slight decrease. Clinicians are concerned that full relief may not be possible given the significant cost of trying to offset an almost 4.5% cut and numerous competing interests facing Congress in an end-of-year legislative package. Watch for grassroots alerts for opportunities to take action.
CY 2023 MPFS Estimated Impact on Total Allowed Charges by Specialty
CMS estimates the combined impact on Audiology services to be -2 percent, based on the mix of services provided by each provider.
Audiology Services and Limited Waiver of Physician Order
Beginning January 1, 2023, CMS will allow Medicare beneficiary access to 36 audiology services without an order from physician or non-physician practitioner (NPP), for non-acute hearing conditions, once every 12 months through the use of a new “AB” modifier.
This final rule modifies the proposed rule that would have created a blended payment with a single, new HCPCS G-code intended to replace individual 36 CPT codes when service(s) are provided by an audiologist without a physician order. The Academy and others in the audiology community met with CMS and provided feedback that led to these modifications. The final rule still limits the direct access to any of the 36 audiology services in a 12-month period yet will use the existing CPT codes and values with the AB modifier. CMS has indicated that changes to its claims processing systems will take time to operationalize – up to 6 months.
The Academy has reached out to CMS to obtain better definitions and clarifications to help audiologists understand the opportunities and limitations for providing audiology services directly to Medicare beneficiaries. We will provide ongoing updates with expanded details and guidance on system changes as quickly as we obtain information. We also are offering the Academy as a resource to CMS, both to ensure clarity and consistency in educational materials to audiologists as well as to assist in dissemination of guidance.
The Academy acknowledges that the CMS provision for limited direct access is a step forward but still imposes unnecessary restrictions. We recognize challenges for members given the ambiguity and lack of direction in the final rule, and we hope that CMS will expedite the issuance of guidance.
This limited direct access provision only applies to 36 codes (listed below). Other codes still require a physician or NPP order. The current Medicare guidance remains in place. See here for a list of codes for tests that audiologists can bill with the AB modifier for non-acute hearing conditions without a physician or NPP order/referral.
Extension of Covered Telehealth Services
CMS finalized provisions to make certain audiology services available for coverage under telehealth through December 31, 2023. Coverage of other audiology services expires 151 days after the end of the declared Public Health Emergency (PHE). CMS has added these codes to the Medicare Telehealth Services List on a Category 3 basis:
Quality Payment Program (QPP) and Merit-Based Incentive Payment System (MIPS)
Many audiology practitioners will not meet the reporting requirements under MIPS. To be a mandated reporter under MIPS, a practitioner must:
- Bill more than $90,000 for Part B covered professional services,
- See more than 200 Part B patients, and
- Provide more than 200 covered professional services to Part B patients.
CMS has finalized an established measures set for audiologists to use for MIPS program reporting. Audiologists who participate in MIPS reporting need to report on at least 6 of the following measures:
#130 – Documentation of Current Medications in the Medical Record
#134 – Preventive Care and Screening: Screening for Depression and Follow-Up Plan
#155 – Falls: Plan of Care
#181 – Elder Maltreatment Screen and Follow-Up Plan:
#182 – Functional Outcomes Assessment
#226 – Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
#261 -Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness (Note: The Audiology Quality Consortium (AQC), currently chaired by the Academy, requested that CMS retain this measure in the audiology measures set. CMS had proposed to delete it.)
#318 -Falls: Screening for Future Falls Risk
NEW *#487 Screening for Social Drivers of Health: Percent of beneficiaries 18 years and older screened for food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety.
NEW * #431 Preventive Care and Screening: Unhealthy Alcohol Use: Screening & Brief Counseling: Percentage of patients aged 18 years and older who were screened for unhealthy alcohol use using a systematic screening method at least once within the last 12 months AND who received brief counseling if identified as an unhealthy alcohol user.
For the 2024 reporting year / 2026 payment year, CMS plans to require audiologists to report under the MIPS Promoting Interoperability category. Currently, audiologists must report only under the Quality and Improvement Activities categories. The Audiology Quality Consortium (AQC), currently chaired by the Academy, asked CMS to defer required reporting under Promoting Interoperability until 2025. CMS indicated it would keep this under advisement and monitor the number of audiologists currently voluntarily reporting under this category.
The Academy will continue to work on behalf of our members and to provide ongoing updates to this guidance via Web postings and e-mail alerts.
For additional information on the CY2023 MPFS:
View the Fact Sheet on Final Changes to the CY 2023 Quality Payment Program. Access the zip file here.
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