Summary of MPFS CY2021 and Call to Action for Audiology

The Centers for Medicare and Medicaid Services (CMS) issued the final 2021 Medicare Physician Fee Schedule (MPFS) on December 2, 2020. Unfortunately, CMS failed to provide relief from a significant shift in physician and non-physician payments slated to take effect on January 1, 2021. This change is estimated to impact audiology services by -6 percent. These changes are due to regulatory policies beyond the control of the Academy, specifically budget neutrality requirements triggered by higher payment for evaluation and management (E/M) services.

TAKE ACTION: Medicare Payment Cuts for 2021 

Congress must act to stop these cuts! The Academy joined a coalition of about 65 societies to oppose these cuts and urge Congress to intervene. 

We need your help! to pass the “Holding Providers Harmless from Medicare Cuts Act” (H.R. 8702), which provides a two-year reprieve while specialties work toward a permanent resolution. Contact your U.S. Representative and express your support for passage of H.R. 8702. Let your lawmaker know what the fee schedule cuts mean to your practice and importantly, let them know what this will mean for your patients. Your voice counts most with your lawmakers! 

Visit the Academy’s Legislative Action Center

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2021 Physician Fee Schedule Overview

Conversion Factor: The 2021 conversion factor is $32.41, a decrease of $3.68 from last year; cuts to audiology services could be about 6 percent, depending on your practice’s mix of services. 

New Audiology Codes for 2021 Finalized

Auditory Evoked Potentials (CPT codes 92584, 92650, 92651, 92652, and 92653)

To better describe tests of auditory function, the American Medical Association Current Procedural Terminology Editorial Panel (AMA CPT) created CPT code 92584 (Electrocochleography) and replaced CPT codes 92585 and 92586 with four new services. CMS finalized the AMA/Specialty Society Relative Value Scale Update Committee (RUC)-recommended work RVUs of 1.00 for CPT code 92584, 1.00 for CPT code 92651 (Auditory evoked potentials; for hearing status determination, broadband stimuli, with interpretation and report), 1.50 for CPT code 92652 (Auditory evoked potentials; for threshold estimation at multiple frequencies, with interpretation and report), and 1.05 for CPT code 92653 (Auditory evoked potentials; neurodiagnostic, with interpretation and report). CPT code 92650 (Auditory evoked potentials; screening of auditory potential with broadband stimuli, automated analysis) is a screening service and is not payable by Medicare; however, CMS did incorporate the RUC-recommended work RVU of 0.25.

Vestibular Evoked Myogenic Potential Testing (CPT codes 92517, 92518, and 92519)

CPT code 92517 (Vestibular evoked myogenic potential testing, with interpretation and report; cervical (cVEMP)); CPT code 92518 (Vestibular evoked myogenic potential testing, with interpretation and report; ocular (oVEMP)); and CPT code 92519 (Vestibular evoked myogenic potential testing, with interpretation and report; cervical and ocular). CMS accepted RUC-recommended work RVU of 0.80 for CPT codes 92517 and 92518. For CPT code 92519, CMS has also finalized the RUC-recommended work RVU of 1.20. CMS is also proposing the RUC-recommended direct practice expense (PE) inputs without refinement for these three VEMP codes.

Note: The Academy requested that CMS create specific TC/PC splits for our new CPT codes. CMS acknowledged receipt of this request and stated it will review and consider in future rulemaking. The Academy will continue to address this issue to ensure members may appropriately bill services based on the site in which care is delivered.   

CMS Finalizes Telehealth Service List

For CY 2021, CMS finalized additional services similar to services already on the telehealth list. Additionally, CMS clarified that licensed clinical social workers, clinical psychologists, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) can furnish the brief online assessment and management services as well as virtual check-ins and remote evaluation services. In order to facilitate billing by these practitioners for the remote evaluation of patient-submitted video or images and virtual check-ins, CMS established two new HCPCS G codes.

CMS also received questions as to whether services should be reported as telehealth when the individual physician or practitioner furnishing the service is in the same location as the beneficiary; for example, if the physician or practitioner furnishing the service is in the same institutional setting but is utilizing telecommunications technology to furnish the service due to exposure risks. CMS, therefore, reiterated in this final rule that telehealth rules do not apply when the beneficiary and the practitioner are in the same location even if audio/video technology assists in furnishing a service.

Merit-Based Incentive Payment System (MIPS)

There are no changes to the measure set available for reporting by audiologists under MIPS. The measures for 2021 are:

#130–Documentation of Current Medications in the Medical Record

#134–Preventive Care and Screening: Screening for Depression and Follow-Up Plan

#154–Falls: Risk Assessment

#155–Falls: Plan of Care

#181–Elder Maltreatment Screen and Follow-Up Plan

#182–Functional Outcome Assessment

#226–Preventive 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

CMS Delays MIPS Value Pathways (MVPs)

CMS will delay its MVPs framework, originally slated to begin with the 2021 performance period. CMS now states that MVPs will not be implemented until the 2022 performance period, or later.

2021 Payment Tables for Audiology Services

See the detailed payment chart noting the changes from CY 2020.

CMS Resources

• CMS fact sheet on the CY 2021 Physician Fee Schedule Final rule 
• CMS fact sheet and frequently asked questions on the CY 2021 Quality Payment Program final rule 
• CY 2021 Physician Fee Schedule and Quality Payment Program final rule text  
• CMS Quality Payment Program summary (no significant changes for 2021)