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August 29, 2022

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

  • Coding

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.”
Review the Comment Letter
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