Proposed 2020 Changes to Medicare and Their Impact on Audiology

Author: Kim Cavitt, Au.D.

Proposed 2020 Changes to Medicare and Their Impact on Audiology By KIM CAVITT, Au.D.
Conversion Factor
The conversion factor is a significant aspect of each Medicare allowable rate. Allowable rates are the sum of the conversion factor, multiplied by each CPT code’s Relative Value Unit (RVU) and the geographical adjustment for your community. The 2019 conversion factor is $36.0391. The proposed conversion factor for 2020 is $36.0896, resulting in a potential nominal increase for 2020.
CPT Coding Changes
There are significant changes to 92626, 92627 and 92548. These codes descriptions will be changed for 2020, regardless of any Medicare actions as they have been approved by the American Medical Association (AMA). The code changes are:
  • 92626: Evaluation of auditory function for surgically implanted device(s),candidacy or post-operative status of a surgically implanted device(s); first hour.
  • 92627: Evaluation of auditory function for surgically implanted device(s), candidacyor post-operative status of a surgically implanted device(s); each additional 15 minutes.
The above codes should ONLY be used for candidacy and post-operative evaluation of an implantable auditory prosthetic device, such as a cochlear implant, auditory osseointegrated device, or auditory brainstem implant. These codes should NOT BE BILLED, to any entity, for any other clinical purpose.
  • 92548: Computerized dynamic posturography sensory organization test (CDP-SOT), 6 conditions (ie, eyes open, eyes closed, visual sway, platform sway, eyes closed platform sway, platform and visual sway), including interpretation and report)
  • 92XX0 (the exact code has not been finalized): Computerized dynamic posturography sensory organization test (CDP-SOT), 6 conditions (ie, eyes open, eyes closed, visual sway, platform sway, eyes closed platform sway, platform and visual sway), including interpretation and report; with motor control test (MCT) and adaptation test (ADT).
Merit Based Incentive Payment System (MIPS)
The proposed rule seeks to maintain the 2019 low volume thresholds ($90,000 in Medicare reimbursement, providing covered care to 200 or more Medicare beneficiaries and providing 200 or more covered Medicare services). As a result, most audiologists would continue to be voluntary MIPS reporters, with the exception of those working within a Medicare Alternative Payment Model (APM; this is uncommon in private audiology practices with no medical practice or hospital affiliation). We are seeking clarification though on the impact of MIPS on group practices with greater than 15 eligible providers. Audiology will be eligible to report on nine total quality measures and will continue to be eligible to attest to clinical improvement activities. The quality measures are:
  • Documentation of Current Medications in the Medical Record
  • Preventive Care and Screening: Screening for Depression and Follow-Up Plan
  • Falls: Risk Assessment
  • Falls: Plan of Care
  • Referral for Otologic Evaluation for Patients with Acute or Chronic Dizziness
  • Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention
The six measures listed above were available in MIPS in 2019 and were also available in the 2016 Physician Quality Reporting System (PQRS).
  • Elder Maltreatment Screen and Follow-Up Plan
  • Functional Outcome Assessment
  • Falls: Screening for Future Falls Risk
These three measures listed above would be new to audiology in 2020 (if the proposed rule stands). There are no details yet about how these codes will be applied to audiology or to what codes they will be assigned.

Again, as in 2019, ADA strongly advises members to voluntarily report MIPS and complete and attest to the clinical improvement activities. It is important that audiologists educate and familiarize themselves with this program and generate Medicare data on quality and improvement. The goal of this program is to increase the number of participating providers. As a result, this low volume threshold exception could be reduced or eliminated any year. Audiology practices must be prepared. It is these types of activities and programs that differentiate us from hearing aid dispensers and disruptive delivery channels.

ADA will be submitting a comment to Medicare on the proposed rule and its impact on our profession. Please note:
  • These changes are proposed and not final. They become final ONLY if maintained in the Medicare Final rule, which typically comes out in November.
  • These changes, if finalized, would go into effect on January 1, 2020.
PLEASE CLOSELY FOLLOW THE ADA WEBSITE, E-BLASTS, AUDIOGRAM, AUDIOLOGY PRACTICES AND WEBINAR ANNOUNCEMENTS FOR ADDITIONAL UPDATES AND INFORMATION, ESPECIALLY IN NOVEMBER AND DECEMBER 2019. THIS IS HOW MEMBERS WILL BE INFORMED OF THE FINAL 2020 CHANGES.

If ADA members have further questions or would like to learn more, please contact Kim Cavitt at kim.cavitt@audiologyresources.com or 773-960-6625 (text or call).    
Dr. Kim Cavitt was a clinical audiologist and preceptor at The Ohio State University and Northwestern University for the first ten years of her career. Since 2001, Dr. Cavitt has operated her own Audiology consulting firm, Audiology Resources, Inc. She currently serves on the State of Illinois Speech Pathology and Audiology Licensure Board. She also serves on committees through AAA and ASHA and is an Adjunct Lecturer at Northwestern University.
References
United States Federal Register. 2020 Medicare Physician Fee Schedule Proposed Rule. August 14, 2019. Accessed on August 14, 2019.

U.S. Centers for Medicare and Medicaid Services (CMS) Newsroom website. Proposed Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2020. July 29, 2019. Accessed on August 15, 2019.

U.S. Centers for Medicare and Medicaid Services (CMS) Quality Payment Program Website. Accessed on August 15, 2019.