Analysis of 2009 Medicare Fee Schedule for Audiologists Available

The Centers for Medicare and Medicaid Services (CMS) released the final 2009 Medicare Physician Fee Schedule on October 30, 2008. There are a number of important changes for next year for which audiologists should be prepared. A complete analysis of the final rule www.asha.org is available on ASHA's Web site.

The following audiology procedures show substantial increases: central auditory function (60 minutes) and each additional 15 minutes, evaluation of auditory rehab status (60 min.) and each additional 15 minutes, tinnitus assessment, and brainstem implant analysis/programming.

Unfortunately, there are also procedures with reductions for comprehensive audiometry and acoustic reflex decay. These reductions are a result of elimination of the zero work pool and a transitioned removal of direct practice expenses through 2010. ASHA will be meeting with and formally commenting to CMS regarding remedies to these unfair fee reductions.

A provision of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) required CMS to change the method for achieving budget neutrality from reducing the work value to reducing the conversion factor (CF). Coupled with a 1.1 percent inflationary update, the CF is reduced from 38.0870 to 36.0666 in 2009, a 5.3 percent reduction. In 2008, work values were all reduced by 11.94 percent largely to compensate for an increased usage of evaluation and management codes.

In 2007, ASHA's Health Care Economics Committee successfully advocated for services rendered by audiologists to be valued as professional rather than technical by Medicare. ASHA collaborated with the American Academy of Audiology and the American Academy of Otolaryngology - Head and Neck Surgery in surveying six audiology procedures (CPT codes: 92620, 92621, 92625, 92626, 92627, and 92640) and presented the results to the American Medical Association. As a result, those procedures will have newly assigned work relative value units (RVUs) in 2009.

In the CMS introduction to the revaluation of the six audiology codes and agreement with their work values, it is noted that under Medicare, audiology services are provided under the diagnostic test benefit. CMS said that some of the procedure work descriptors include "counseling," "the potential for remediation," and the establishment of "interventional goals," but are interested in receiving comments on this issue. ASHA will be commenting that the assessment aspects of these procedures are what allow them to fit within the diagnostic test benefit.

Please contact reimbursement@asha.org with any questions or comments.