CY2023 Proposed Medicare Physician Fee Schedule (MPFS): Proposal for Audiology Direct Access

The MPFS is released annually and updates payment policies, payment rates, and other provisions for services in Medicare. The most recent proposal was issued July 6, 2022, and includes a proposal for limited direct access to audiology services in Medicare.

Under this proposal, “non-acute,” non-vestibular services (36 codes) may be provided without a physician order and creates new GAUDX code for these 36 codes. Under this approach, a “blended” reimbursement rate would apply for all of these services. Beneficiaries could receive one GAUDX coded services every 12 months.

The Academy submitted comments to CMS and provided the following recommendations:

• Utilize existing CPT codes with existing fee schedule reimbursement rate + a new modifier to identify services provided without physician order (rather than GAUDX).
• Make time-limited patient eligibility to these services available in existing on-line tools (MAC portals) to assist audiologists.
• Remove “acute” criterion from the proposal. Audiologists are skilled at care coordination and necessary referrals.
• Remove commentary in proposal that references presumptive safety concerns with direct access to audiology services. These claims lack documentation or citations supporting patient “safety.”