Final Rule Changes to the 2015 Medicare Physician Fee Schedule
American Academy of Audiology Analysis
On October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) issued the Revisions to Payment Policies under the Physician Fee Schedule, Clinical Laboratory Fee Schedule and Other Revisions to Part B for CY 2015 final rule. The final rule addresses adjustments to the physician fee schedule and other Medicare Part B payment policies to reflect changes in medical practice and the relative value of services. The finalized changes will go into effect on January 1, 2015. The Academy has prepared a list of payment rates by CPT code for audiology procedures covered under the fee schedule as follows: FY 2015 (with SGR fix), FY 2015 (without SGR fix), and FY 2014 for comparison, along with helpful fee calculation definitions. The Academy has prepared an analysis of the final rule below and will continue to add to this analysis and update our membership as more information becomes available.
New Payment Rates in Effect for Vestibular Codes
Last March, the American Academy of Audiology and the American-Speech-Language-Hearing Association worked in collaboration with the American Academy of Otolaryngology-Head and Neck Surgery and the American Academy of Neurology to survey Current Procedural Terminology (CPT) codes 92541, 92542, 92543, 92544, and 92545 to assess and revise the “professional work” value for each procedure. Professional work value includes factors such as mental effort and judgment, technical skill, and psychological stress. This is part of the valuation process established by the American Medical Association’s Relative Value Update Committee (RUC). The payment rates published in this year’s final rule reflect the first time that the values for these vestibular services, provided by audiologists, are based on the professional work components referenced above, a transition that began in 2007.
Click here for more information and to view the new payments rates for these vestibular codes.
Fee Schedule and Sustainable Growth Rate (SGR)
The Protecting Access to Medicare Act of 2014, a bill that was signed into law on April 1, 2014, provides for a zero percent Medicare Physician Fee Schedule update for services furnished between January 1, 2015 and March 31, 2015. After March 31, 2015, current law requires that fee schedule rates be reduced by an average of 21.2 percent from CY 2014 rates. In past years, Congress has taken action to avert such large-scale cuts before they went into effect. The Academy has offered several comment letters in support of Congressional proposals which seek a permanent repeal of the SGR and overall payment reform.
Visit the Academy's Legislative Action Center to urge Congress to find a more permanent fix to the SGR formula. The Academy has been active in congressional discussions regarding SGR repeal and Medicare payment reform. Visit the Academy’s Government Relations News page to view comments submitted on various proposals, beginning in February 2013.
Physician Payment, Efficiency, Quality Improvements—Physician Quality Reporting Systems (PQRS)
Retirement of Measure #261
The Academy, in conjunction with its Audiology Quality Consortium (AQC) partners, actively opposed CMS’ proposal to retire measure #261, Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness, the only audiology specific PQRS measure. The Academy believes that maintaining measure #261 is critical to ensure audiologists have 1) a clinically-relevant measure to report in 2015 (in addition to #130- Documentation of Medications in the Medical Record and #134- Screening for Clinical Depression), 2) a measure by which to train and educate audiologists in proper PQRS quality reporting, and 3) an interim (one-year only) measure while audiology stakeholders develop and finalize six measures, currently in the testing phase of measure development.
The Academy is pleased to report that CMS reversed their decision to retire measure #261. As a result, in 2015, audiologists will continue to report this one audiology-specific measure if the measure specific CPT and ICD-9/10 codes are applicable for 50% of eligible patients, and the two eligible measures to participate in PQRS, if applicable. The Academy will update the membership when the Measure-Applicability Validation (MAV) is updated for 2015 measures as there may be changes from the 2014 MAV:
- Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness (Measure #261), for at least 50% of all Medicare beneficiaries
- Documentation of Current Medications in the Medical Record (Measure #130), for at least 50% of the Medicare patient visits
- Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan (Measure #134), for at least 50% of Medicare beneficiaries receiving CPT code 92625, assessment of tinnitus (includes pitch, loudness matching and masking).
Definition of satisfactory reporting/satisfactory participating
The Academy continues to be impacted by the increase in reporting requirements in 2014 from 3 measures to 9 measures covering at least 3 of the National Quality Strategy (NQS) domains. The Academy has urged CMS to continue the use of the Measure-Applicability Validation (MAV) process as a method for audiologists to report on PQRS measures and avoid the 2% payment penalty when current circumstances requires they report on fewer than 9 measures. In the PFS final rule, CMS states that eligible professionals who report on 1-8 measures would still be subject to the MAV process.
CMS also recognizes the need to clarify the MAV process for both claims and registry, as a means of providing further transparency to the process. CMS has education and outreach documents available for the 2014 MAV process, and they will update these materials as necessary for the 2015 MAV process. The AQC will update the 2015 PQRS Step-by-Step Guide when the 2015 MAV is released. Visit the Academy’s website for more information and regular updates regarding PQRS.
The Academy’s Quality Measures Subcommittee (QMS), along with the AQC, will continue to work diligently to develop additional discipline-specific quality measures for the profession of audiology.
Value-Based Payment Modifier (VM) Expansion
CMS has responded to requests from the Academy and other stakeholders acknowledging that non-physician providers, including audiologists, could benefit from more time for education and training in order to effectively participate in the VM program beginning in 2015. CMS has agreed to delay applying the VM from the CY 2017 payment adjustment period to the CY 2018 payment adjustment period for non-physician providers, including audiologists, who are solo practitioners and those who are in groups with two or more eligible professionals. CMS believes this delay allows non-physician providers additional time to understand the policies for calculating the VM. CMS is expected to announce the performance period for the CY 2018 payment adjustment for the VM in the CY 2016 PFS proposed rule.
Since CY 2018 would be the first year for such groups to be subject to the VM, CMS is finalizing a policy that would prevent them from being subject to a downward adjustment in CY 2018. The Academy will continue to work with CMS on this VM expansion and provide education and resources to our members to ensure successful participation in this program.
Physician Compare Web Site
The Academy has continued to advocate for its ongoing involvement in the development and refinement of the Physician Compare Website. We have requested that our representative experts continue to advise CMS as the Agency updates the Physician Compare website to assure that audiologists are meaningfully represented and can be easily identified by other professionals and patients. CMS directly addressed this request in the final rule, indicating that they will review this and other recommendations and will continue to work with stakeholders on this issue. CMS also notes that throughout the site, both physicians and other health care professionals are available to search and view. If a professional is in an active status in PECOS and has submitted Medicare Fee-For-Service claims under their National Provider Identifier in the last 12 months, they will be included on the Physician Compare website. The Academy will continue to work with CMS and other stakeholders ensure that the profession of audiology is accurately represented on the Physician Compare website.
Non-MD Professional Liability Insurance (PLI) Risk Factor/Premium Crosswalk
CMS maintained its Academy-supported decision to crosswalk the PLI premiums of non-MD specialties to the lowest MD risk factor- Allergy Immunology.
The Academy will continue to monitor CMS Medicare Part B policies, provide commentary, and meet with CMS at Agency headquarters as necessary to advocate for the profession of audiology.