Preliminary Analysis – Medicare Physician Fee Schedule Final Payment Rule for CY 2019 and Quality Payment Program Rule for 2019

On Thursday, November 1, 2018, the Centers for Medicare and Medicaid Services (CMS) posted the Final Medicare Physician Fee Schedule (MPFS) for 2019 and Quality Payment Program (QPP) rule for 2019. This comprehensive, joint rule changes policy and payment under the Medicare program.  It projects an increase in audiologists’ fees in 2019, and adds audiologists to the Quality Payment Program.

Audiology Fees

For audiology CMS had proposed a net 1 percent fee reduction in the July proposed rule but in the final rule fees will increase by an average of 1 percent. Average fees will increase by 1% for audiologists in 2019 because of changes in how CMS is calculating practice expenses. The average physician/provider will see no change in 2019. CMS set the 2019 conversion factor at $36.0391, an increase from the 2018 conversion factor of $35.9996. See data on the utilization and fee changes for the top 25 audiology codes in Medicare.

Audiologists Subject to MIPS in 2019

In a surprise move, CMS decided to add audiology to the MIPS program. This will allow audiologists to enter into this program and receive potential payment bonuses.  Many audiologists would not be subject to program participation because they would meet the low volume threshold criteria.   Audiologists who score well in the MIPS program during 2019 will receive additional reimbursement in 2021. Those who score poorly will receive reduced payments in 2021. More information on the MIPS program for audiologists will be coming shortly.

Audiology Codes and the List of Potentially Mis-valued Services

CMS is required to periodically identify potentially mis-valued services using certain criteria and to review and make appropriate adjustments to the relative values for those services. CMS did not identify any audiology codes on their list of potentially mis-valued services for CY 2019.

Telehealth and Health Communications Technologies

CMS is expanding access and promoting more coordinated patient care through paying for use of health telecommunications technology and expansion of covered telehealth services.  According to CMS’s press release “Practitioners could be separately paid for the brief communication technology-based service when the patient checks in with the practitioner via telephone or other telecommunications device to decide whether an office visit or other service is needed.” The Academy will be working with CMS to see if this opportunity will be available for audiologists.

The Academy will continue to analyze this final rule and will provide more detailed information to members in the coming days.