Let Me Hear From You
SEPARATE and DISTINCT Professions Deserve SEPARATE Representation
By M. Patrick Feeney
The American Medical Association’s (AMA) Resource Value Scale (RVS) Update Committee (RUC) Health Care Provider Advisory Committee (HCPAC) consists of limited license practitioners and allied health professionals. The RUC represents 23 medical disciplines including otolaryngology and decides the relative value of CPT codes, including those for audiology. This process results in recommendations for consideration by the Centers for Medicare and Medicaid (CMS) as to the reimbursement rate for codes used for services to its beneficiaries. The AMA allows a professional association to represent the interests of each profession represented at the RUC HCPAC. This is referred to as holding a seat at the RUC HCPAC. The current seat holder representing the profession of audiology is the American Speech-Language-Hearing Association (ASHA). They were awarded this seat in 1992.
In July 2008, speech pathologists, through the passage of House Bill HR 6331, were awarded “qualified provider” status with Medicare. This allows speech pathology to petition to have its own representation at the RUC HCPAC just as audiology has. However, ASHA has decided not to do this. Instead, ASHA contends that as an umbrella organization (i.e., an organization representing more than one discipline), it best represents audiology and speech pathology by holding one seat at the RUC HCPAC. The Academy is not in agreement. The Academy is currently a guest of ASHA at these meetings, and although we are invited to make comment to ASHA, it is the ASHA representative that ultimately presents to the RUC or the RUC HCPAC on behalf of the profession of audiology.
This scenario is frustrating in view of the fact that reimbursement for audiology services will suffer a double-digit reduction for 2009 and will have an even greater reduction in 2010. In fact, audiology regrettably holds the distinction of having the biggest drop in reimbursement of any of the RUC specialties; the only one with a double-digit reduction. This is unacceptable.
The Academy believes that both audiology and speech pathology should hold seats at the RUC HCPAC—we believe that audiology should be represented by the Academy and speech pathology should be represented by ASHA. Audiology and speech pathology are separate and distinct professions that should each be represented by the organizations that represent each profession, not by an umbrella organization. If one were to follow the logic of ASHA, one could argue that the professions of physical therapy and occupational therapy are intertwined and need to be represented by a single umbrella organization. However, this is not the case at the RUC HCPAC—physical therapy and occupational therapy are recognized as two SEPARATE and DISTINCT professions, each with its own representative and vote. This distinction is powerful for both professions when their codes are reviewed and valued.
The need for change arises from the simple fact that audiology and speech pathology have evolved into two SEPARATE and DISTINCT professions. Each deserves separate representation. This is not a power struggle between ASHA and the Academy. The Academy is not asking ASHA to lose a seat at the RUC HCPAC. Instead, we argue that ASHA should hold the seat for speech pathology and the Academy should hold the seat for audiology. This would be powerful; each profession would have an independent vote.
In October, the Academy held a summit to discuss these issues. I would like to thank members Kadyn Williams, chair of the Coding and Reimbursement Committee, and Committee members, Paul Pessis and Alan Desmond, for their expertise and dedication in these discussions along with our director of reimbursement, Deb Abel.
As a result of this summit, the Board of Directors formed the Practice Policy Advisory Council (PPAC), a new Academy committee, with the charge of representing the Academy at the RUC HCPAC and the CPT Editorial Panel. The PPAC will consist of a chair, a RUC representative and alternate, a CPT Editorial Panel representative and alternate, the chair of the Coding and Reimbursement Committee, the chair of the Government Relations Committee, and three members at large. The establishment of the PPAC is the next step in the process of securing effective representation of audiology as a SEPARATE and DISTINCT profession at the RUC and CPT Editorial Panel HCPACs.