Academy provides comments to CMS on proposed rules for the Medicare Physician Fee Schedule and Hospital Outpatient Prospective Payment System

The Academy submitted comments to the Centers for Medicare and Medicaid (CMS) on the proposed CY 2020 Medicare Physician Fee Schedule (PDF).  Academy comments provide specific feedback on Computerized Dynamic Posturography (CPT Codes 92548 and 92549) as well as on Auditory Function Evaluation (CPT Codes 92626 and 92627).  In addition, Academy comments urge CMS to reconsider its proposed restructuring of Evaluation and Management (E/M) Services due to the potential reimbursement cuts to services provided by audiologists due to the redistribution of the E/M code value increases.  Finally, Academy comments provide specific recommendations in response to the CMS proposal to add three new quality measures (Elder Maltreatment Screen, Screening for Future Fall Risk, and Functional Outcome Assessment) to the six available now for audiologists.

The Academy also submitted comments to CMS on the Proposed Rule for the Hospital Outpatient Prospective Payment System (PDF). Academy comments express opposition to any changes in OPPS status indicators which would result in further packaging of services.  In addition, Academy comments urge CMS to reconsider a re-designation of CPT code 92557 from the status indicator “Q1” to “S” in light of the fact that this primary service is not performed ancillary to any other services and as such should remain separately payable.

Final rules on both proposals are expected on or around November 1.