2015 Medicare Physician Fee Schedule Released
The Centers for Medicare and Medicaid Services (CMS) posted the final 2015 Medicare Physician Fee Schedule (MPFS) and associated rules for Medicare Part B services on October 31, 2014, and will publish it in the November 7, 2014, Federal Register. The rules go into effect January 1, 2015.
A conversion factor (CF) is used to calculate the MPFS reimbursement rates. The conversion factor for January 1 through March 31, 2015, is $35.8013. On April 1, 2015, the conversion factor converts to $28.2239, 21.2% lower because of a statutory formula known as the sustainable growth rate (SGR). Congress extended the current SGR in anticipation of passing a Medicare payment reform bill; however, there has been little progress in the bill passage. It is anticipated that Congress will enact legislation to prevent this reduction as it has done almost every year since the SGR was implemented.
New Rates for Vestibular Testing Codes
Earlier this year, ASHA and the American Academy of Audiology surveyed audiologists in order to update the professional work value of vestibular testing codes 92541, 92542, 92543, 92544, and 92545 through the American Medical Association’s Relative Value Update Committee (RUC) valuation process. The 2015 MPFS reflects the first time that the payment rates for these vestibular testing codes are based on the professional work of the audiologist (e.g., clinical judgment, mental effort, risk).
The CY2015 therapy cap is $1,940. However, the final rule reiterated that the current therapy cap exceptions process (using the KX modifier) and manual medical review at the $3,700 threshold for physical therapy and speech-language pathology services combined will continue through March 31, 2015. However, absent Congressional action, the exceptions process and manual medical review will expire April 1, 2015.
Go to ASHA's Take Action site to tell your members of Congress to allow the exceptions process to continue in 2015.
More information on the therapy cap exceptions process and manual medical review is available on ASHA's billing and reimbursement webpages.
Physician Quality Reporting System (PQRS)
Due to advocacy efforts by ASHA, the Audiology Quality Consortium, and other audiology organization stakeholders, CMS determined to change their position to retire audiology measure #261, Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness. ASHA requested the reconsideration to 1) ensure audiologists have a clinically relevant measure to report in 2015, 2) have a measure by which to train and educate, and 3) have an interim measure while audiology stakeholders develop and finalize six measures, currently in the testing phase of measure development.
In 2015, audiologists will report:
· Measure #261 for a minimum of 50% of all Medicare beneficiaries
· Measure #130, the documentation of medication, for a minimum of 50% of the Medicare patient visits
· Measure #134, screening for depression, for a minimum of 50% of the Medicare beneficiaries receiving tinnitus evaluations
Speech-language pathologists continue to participate in the documentation of medication measure, and have pain assessment as an optional measure for participation.
Audiologists and SLPs who work in private practice, group practice, or university clinics, and do not meet the benchmark requirements for the measures in 2015, will receive a 2% deduction on all of their Medicare services in 2017.
For more information regarding PQRS, please visit ASHA’s PQRS webpage.
Value-Based Modifier (VBM)
Medicare finalized the expansion of the VBM and associated rules to specialty-care providers not previously subject to the additional requirements. However, due to advocacy efforts from ASHA and other audiology and therapy organizations, CMS agreed to postpone the implementation to audiologists, speech-language pathologists, and other non-physician professionals. This is a significant decision for ASHA members providing services to Medicare beneficiaries, as non-compliance in 2015 would result in an additional 4% deduction from all Medicare claims in 2017.
The reprieve is temporary, however, as the recommendations in the rule included expansion in 2016. ASHA will work with CMS and other stakeholders to ensure members are prepared for the additional quality reporting program requirements.
Each year, CMS releases proposed rules and rates for the following year with a 60-day comment period. Audiology and speech-language pathology services under Medicare Part B (outpatient) have reimbursement rates established by the MPFS. Speech-language pathology services provided in hospital outpatient settings are also based on the MPFS, while audiology outpatient hospital services are paid under the Hospital Outpatient Prospective Payment System.
Further analysis is pending and details will be noted on ASHA's Billing & Reimbursement website, in future ASHA Leader articles, and through ASHA Headlines.
For more information, contact Lisa Satterfield, ASHA’s director of health care regulatory advocacy, at firstname.lastname@example.org or Neela Swanson, ASHA’s director of health care coding policy, at email@example.com.
Lemmietta G. McNeilly, PhD, CCC-SLP, CAE, ASHA Fellow
Chief Staff Officer, Speech-Language Pathology
American Speech-Language-Hearing Association
2200 Research Boulevard, #229
Rockville, MD 20850-3289
+1 301-296-5705 telephone