Wednesday, 01 August 2018

The Centers for Medicare and Medicaid Services released their proposed rules

Posted in ADA News

The Centers for Medicare and Medicaid Services (CMS) released their proposed rule for the 2019 Payment Year Quality Payment Program (QPP) and Medicare Physician Fee Schedule (MPFS) July 12, 2018. Audiologists can review the QPP fact sheet, the MPFS fact sheet and the proposed rule online.

Unfortunately, audiologists are not "eligible clinicians" in the 2019 QPP program. As a result, we are not eligible to participate in the QPP program in 2019. The goal is that audiologists will be eligible by 2021, when full participation by all Medicare providers is required. The only Medicare eligible professions not included in the QPP in 2019 are qualified speech-language pathologists, qualified audiologists, certified nurse-midwives, and registered dietitians or nutrition professionals. Audiologists are now the only doctoring profession not to be included in the QPP program, as occupational therapists, physical therapists, clinical social workers and clinical psychologists are poised to join the program in 2019.

The only significant proposal to affect audiologists in the MPFS is the 0.25% payment increase. The proposed Medicare conversion factor for 2019 is $36.05, which is a very small increase over the 2018 conversion factor of $35.99. Also, as the Physician Quality Reporting System (PQRS) was retired on December 31, 2016 and, as a result, there was no reporting requirements for 2017, there will be no payment deductions applied to audiologists in 2019.

Many changes were proposed to both the QPP and MPFS. Unfortunately, again given our status within the Medicare system, none of these changes apply to audiology or audiologists. These include:

  • Expansion of the low volume threshold for Merit Based Incentive Payment System (MIPS) and an opt-in provision for those providers who want to participate but do not meet the requirements due to low volume thresholds.
  • Allowing eligible providers to use time and medical decision making as a governing factor in selection of an Evaluation and Management code.
  • Addition of a communication technology based service code. This would provide coverage when the provider checks in with the patient via telephone or telepractice to determine if an office visit or other service is needed.

ADA will be submitting formal comments to CMS prior to the September 10, 2018 comment deadline.