CMS Issues Proposed Payment Rules for 2020

Late Monday, July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) posted the Proposed Medicare Physician Fee Schedule (MPFS) and Hospital Outpatient Prospective Payment System (OPPS) Rules for 2020. These comprehensive rules contain proposed policy and payment changes under the Medicare program.

As a follow up to the Academy’s posting of an initial review, the following contains more detail on proposed changes.

Medicare Physician Fee Schedule

Impact of Proposed E/M Coding Changes on Audiology Beginning 2021

CMS would retain 5 levels of coding for established patients, reduce the number of levels to 4 for office/outpatient E/M visits for new patients, and revise the E/M code definitions.  These changes will have a direct impact on all specialties billing under Medicare due to the redistribution of a limited pool of funds.  CMS issued a proposed impact table that shows payment for audiology would decrease by -6 percent in 2021.

Conversion Factor

CMS estimates a conversion factor of $36.09, a slight increase from the 2019 conversion factor of $36.04.

CPT Codes 92626 and 92627–Auditory Function Evaluation

For CY 2020, CMS proposes the HCPAC-recommended work RVU of 1.40 for CPT code 92626, which is identical to its current RVU. CMS also proposes the HCPAC recommended work RVU of 0.33 for the add-on code, CPT code 92627. Further, CMS proposes the RUC-recommended direct PE inputs for all codes in the family.

Computerized Dynamic Posturography (CPT Code 92548 and 92XX0)

CPT code 92548 (Computerized dynamic posturography) was identified via an AMA RUC screen for review.  As part of the that process, AAA, along with ASHA, AAN and AAO-ENT revised the current CPT code 92548 and added a new CPT code 92XX0 to more accurately describe the current clinical work and equipment necessary to provide this service.

Unfortunately, CMS did not agree with the RUC’s recommended work RVUs of 0.76 for CPT code 92548 and 0.96 for CPT code 92XX0. CMS proposes alternate work RVUs which more closely align with the current valuation 92458 than either the specialties or the AMA RUC recommended. We are disappointed and will continue to address discrepancies in the valuation of these wRVUs in comments to the Agency.

Quality Payment Program (QPP) Changes

CMS proposes a new specialty measures set for Audiology for the 2022 Merit-based Incentive Payment System (MIPS) payment year and future years.  Of note, CMS proposes inclusion of new measures that are in addition to the six available now for audiologists.

The six measures current available for audiologists include:

#130 Documentation of Current Medications in the Medical Record

#134 Screening for Clinical Depression and Follow-Up Plan

#154 Falls Risk Assessment

#155 Falls Plan of Care

#226 Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention

#261 Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness

CMS proposes the addition of the following measures:

• #181 Elder Maltreatment Screen and Follow-Up Plan – Percentage of patients aged 65 years and older with a documented elder maltreatment screen using an Elder Maltreatment Screening Tool on the date of encounter AND a documented follow-up plan on the date of the positive screen.
• #182 Functional Outcome Assessment –  Percentage of visits for patients aged 18 years and older with documentation of a current functional outcome assessment using a standardized functional outcome assessment tool on the date of the encounter AND documentation of a care plan based on identified functional outcome deficiencies on the date of the identified deficiencies.
• #183 Falls –  Screening for Future Fall Risk: Percentage of patients 65 years of age and older who were screened for future fall risk during the measurement period.

Medicare Physician Fee Schedule Values – Comparison 2019 Final / 2020 Proposed

The Academy has prepared a table to show the MPFS proposed values for top audiology codes, along with the final values from 2019.

Hospital Outpatient Prospective Payment System

Proposed Ambulatory Payment Classification (APC) assignments and reimbursement impacts for audiology codes will be available soon.

Comments on the proposed rules will be accepted until September 27, 2019. The Academy will continue its analysis of the rules and submit comments to CMS. Final rules are expected on or around November 1, 2019.