September 16, 2022
(Rockville, MD) In comments submitted to the U.S. Centers for Medicare & Medicaid Services (CMS) this week, the American Speech-Language-Hearing Association (ASHA) urged the agency to adopt key changes to its proposed Medicare Physician Fee Schedule for 2023 to better meet the needs of patients with hearing, balance, and related disorders.
A critical driver of patient access to healthcare services, the fee schedule dictates reimbursement rates for providers and, in turn, out-of-pocket expenses for Medicare beneficiaries. It also sets forth policies related to the delivery of healthcare services. Comments to CMS’ proposed 2023 fee schedule closed September 6; a final rule from the agency is expected in early November.
In its comments to CMS, ASHA noted a provision that would allow Medicare beneficiaries to visit an audiologist without first obtaining a separate order from their physician/practitioner for hearing and balance assessment services. ASHA has long contended that audiologists, in their role as specialized care providers, are well equipped to determine reasonable and medically necessary interventions for hearing and balance disorders without a separate order. Also, requiring a physician order can be burdensome for beneficiaries, at times resulting in delayed care while patients wait for an appointment or order—as well as face increased costs for additional medical appointments.
Removing this barrier to audiology care is critical. “Untreated hearing loss contributes to accelerated cognitive decline, social isolation, communication challenges, and mental health challenges,” ASHA notes in its comments to CMS. “However, removing the physician/NPP order requirement has the potential to minimize the occurrence of such negative health outcomes.”
ASHA’s comments also point out a sizeable financial benefit to Medicare that would stem from direct access to audiology care: “Notably, eliminating the physician/NPP ordering requirement for audiology hearing and balance assessment services would result in an estimated savings to Medicare over a 10-year period of approximately $108 million. Medicare beneficiaries would also see a savings of $36 million in copayments, further enhancing affordable access to medically necessary care.”
One Visit Per Year Limit Raises Concerns
CMS’ proposed fee schedule for next year allows for only one visit to an audiologist per 12 calendar months without a physician referral; all subsequent appointments within 12 months would require a new order. ASHA is very concerned about this aspect of the schedule and maintain that it could not only continue to limit patient access to critical hearing and balance diagnostic services, which is counterproductive to CMS’ goal, but also add a layer of financial uncertainty for both patients and providers.
Moreover, there are circumstances when it is clinically appropriate for diagnostic hearing services to be provided multiple times within a 12-month period. For a patient who receives a cochlear implant, for instance, multiple reprogramming visits are often needed. In fact, the clinical standard of care for cochlear implant reprogramming is to see the patient at 3-, 6-, and 12-months post-implantation with additional visits as necessary.
Another example involves cancer patients who are monitored for changes in hearing during the course of their treatment (ototoxic monitoring). A physician/NPP order for each visit would be burdensome for the physician/NPP, patient, and audiologist. Should a physician visit be conducted multiple times to obtain an order, the requirement would be unnecessarily costly for the Medicare program and beneficiaries.
GAUDX Code Also Problematic
ASHA’s comments also emphasized its concern with the development of a new master G-code to replace individual codes for 36 clinical hearing and balance services, noting that it would limit data for demonstrating the types and circumstances in which hearing assessment services are provided. The proposed replacement of individual codes appears to contradict the stated goal of CMS to collect data for the purpose of developing a robust policy associated with audiology assessment services. Moreover, the code change could lead to patients overpaying for some services—and audiologists being either over or under-reimbursed the appropriate amount.
While well intentioned, these referral and coding changes have generated widespread concern among audiologists as well as consumer organizations. ASHA members submitted more than 300 letters citing these and other issues during the comment period. AARP and the Consortium for Constituents with Disabilities have also provided comments with concerns on behalf of its members.
About the American Speech-Language-Hearing Association (ASHA)
ASHA is the national professional, scientific, and credentialing association for 223,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Audiologists specialize in preventing and assessing hearing and balance disorders as well as providing audiologic treatment, including hearing aids. Speech-language pathologists (SLPs) identify, assess, and treat speech, language, and swallowing disorders.