The Academy submitted a letter to CMS to supplement related comments submitted collectively with other physician and non-physician provider groups about the impact of the expected 2021 reimbursement reductions.
The Academy letter highlights some of the nuances of these planned reductions in relation to providing audiological care. In the 2020 Physician Fee Schedule (PFS) final rule, CMS accepted the AMA RUC recommendations for increased payment for the office/outpatient evaluation and management (E/M) codes. However, in an effort to maintain budget neutrality and offset the increased E/M payments, CMS also announced significant decreases in Medicare reimbursement effective 2021 that will impact providers with low utilization of E/M services and providers who do not bill office/outpatient E/M codes.
Academy comments point out that:
- Current regulations prohibit audiologists from billing Medicare for E/M codes.
- Audiologists are not permitted to use the new G codes for E/M services.
- Audiologists do not have any dedicated E/M codes at this time in contrast to some other non-physician providers.
- The inclusion of audiologists in an AMA list of providers that provide E/M services was erroneous. Audiology codes identified are procedural services with “evaluation” in the descriptor. However, “evaluation” in these codes describes cognitive work—not management.
Audiologists do not have access to E/M services to offset the expected reimbursement cuts, and the Academy urges CMS to consider an alternate approach to achieve budget neutrality that takes into account the inherent differences between provider types.