Late Friday, November 1, the Centers for Medicare and Medicaid Services (CMS) posted the final 2020 payment rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System (OPPS). These rules contain proposed policy and payment changes under the Medicare program.
Medicare Physician Fee Schedule
There is a slight increase in MPFS conversion factor. The CY 2020 MPFS conversion factor was finalized at $36.0896, just above the CY 2019 MPFS conversion factor of $36.0391.
Computerized Dynamic Posturography Testing
The Academy worked with the American Speech-Language-Hearing Association (ASHA), the American Academy of Neurology (AAN) and the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS) to revise coding for CDP testing. Beginning in 2020, there will be two codes. CPT 92548 will be used to report computerized dynamic posturography sensory organization test (CDP-SOT), 6 conditions (i.e., eyes open, eyes closed, visual sway, platform sway, eyes closed platform sway, platform and visual sway), including interpretation and report. New CPT code 92549 is to be reported when the motor control test (MCT) and adaptation test (ADT) is completed in conjunction with the sensory organization test (SOT).
The Academy, ASHA, AAN and AAO-HNS also collaborated to submit recommended work and practice expense values to CMS. While the data presented was robust, CMS did not accept the recommendations from the societies and the AMA RUC and has chosen to implement lower values for both 92548 (CDP-SOT) and 92549 (CDP-SOT, MCT, and ADT). Unfortunately, there will be substantial reductions to practice expense values, which reflect the direct cost of providing CDP testing. ASHA and the Academy actively advocated CMS to phase-in the reductions over a 3-year span to mitigate the impact to audiologists, however, CMS chose not to implement the phase-in. As a result, audiologists should be prepared to see reductions of approximately 50% and 35% to payments for 92548 and 92549 respectively, beginning in 2020.
Auditory Function Evaluation Codes
The Academy worked with ASHA to revise CPT codes 92626 and 92627 to more accurately describe the work performed by the audiologist. 92626 has been revised to describe an evaluation of auditory function for surgically implanted device(s) candidacy or post-operative status of a surgically implanted device(s); first hour. CPT code 92627—an add-on code—may be reported in conjunction with 92626 for each additional 15 minutes of the evaluation.
CMS will maintain the current values for CPT codes 92626 and 92627. The Academy worked with ASHA to recommend these values to CMS, preventing potential reduction to payments for this evaluation.
E-Visit Codes (Online Assessment by Qualified Nonphysician Health Care Professional)
In the proposed rule, CMS proposed 3 new G-codes to parallel the CPT E-visit codes. CMS proposed the codes to refer to the performance of an “assessment” rather than an “evaluation.” The Academy supported this proposal and commented that audiologists should be included among the practitioner groups who may bill for these services. Unfortunately, CMS disagreed with the Academy position and clarified that audiologists and other specialist providers are ineligible to bill for these services.
Quality Payment Program
Under the final rule, CMS finalized a new Audiology Specialty Measure Set for the Merit-based Incentive Payment System (MIPS) 2020 performance period/2022 MIPS payment year.
The measures are:
- #130 Documentation of Current Medications in the Medical Record
- #134 Screening for Clinical Depression and Follow-Up Plan
- #154 Falls Risk Assessment
- #155 Falls Plan of Care
- #181 Elder Maltreatment and Follow up Plan (new)
- #182 Functional Outcomes Assessment (new)
- #226 Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention
- #261 Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
- #318 Falls Screening for Future Fall Risk (new)
Audiologists are subject to payment bonuses or penalties based on quality and improvement activities. The vast majority of audiologists will not be required to participate. To be a mandated participant, audiologists must treat 200 or more Medicare beneficiaries, receive $90,000 or more in Medicare reimbursement, and provide 200 or more covered professional services.
For additional information, please see the Quality Payment Program Fact Sheet.
Hospital Outpatient Prospective Payment System
OPPS Payment Adjustment for 2020
CMS has finalized an overall payment update of 2.6 percent under the OPPS in 2020. View the payment chart for audiology services. Note that all payments have increased above 2019 levels. In addition, there are no changes in status indicator assignments for audiology codes, meaning there are no new attempts to package payment for audiology services.
Site of Service Payment Differential
With this final rule, CMS completes its two-year phase-in of payment reductions for clinic visits furnished in the off-campus hospital outpatient setting, meaning these visits will be paid at the Medicare Physician Fee Schedule rate rather than the OPPS rate. Clinic visits are the most common service billed under the OPPS. CMS acknowledges that the United States District Court for the District of Columbia vacated this policy for CY 2019 and they are working to ensure affected 2019 claims for clinic visits are paid consistent with the court order. However, they do not believe it is appropriate to make a change to the second year of the two-year phase-in of the clinic visit policy. The government is evaluating whether to appeal the court’s final judgment.
The rule text and accompanying fact sheets may be viewed at:
- MPFS Rule Text: Final Rule | CMS Fact Sheet
- OPPS Rule Text: Final Rule | CMS Fact Sheet
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