Abel’s Advice Corner – October, 2020

On or around July 1 of every year, the Centers for Medicare and Medicaid Services (CMS) releases the Medicare Physician Fee Schedule (MPFS) proposed rule, a glimpse into the next year’s policies and payments. The release date — the latest it’s been in the over 15 years that I’ve been reviewing it — was August 3. Comments are welcome and can be made here by October 5, 2020. It only takes a few minutes and brings the concerns of the impacts on the profession to CMS.


1. There will be three new CPT® VEMP codes: cVEMPs, oVEMPs and the paired combination of those VEMPs. The final rule will contain the actual codes, not these placeholders. These are currently listed in the MPFS as:
a. 925X1 for vestibular evoked myogenic potential testing, with interpretation and report; cervical (cVEMP)
b. 925X2 for vestibular evoked myogenic potential testing, with interpretation and report; ocular (oVEMP)
c. 925X3 for vestibular evoked myogenic potential testing, with interpretation and report; cervical and ocular


2. There will be 4 new CPT auditory evoked potentials tests codes. The two existing codes, 92585 (comprehensive) and 92586 (limited), will be deleted. Again, the permanent codes will be in the MPFS final rule:

a. 92X51 auditory evoked potentials; screening of auditory potential with broadband stimuli, automated analysis

b. 92X52 auditory evoked potentials; for hearing status determination, broadband stimuli, with interpretation and report

c. 92X53 auditory evoked potentials; for threshold estimation at multiple frequencies, with interpretation and report

d. 92X54 auditory evoked potentials; neurodiagnostic, with interpretation and report

3. The Conversion Factor (CF), a multiplier for the components of the Relative Values that is changed annually by Congress, will go down 10.6% from 2020’s $36.09 to $32.26 for 2021 and is anticipated to affect payment rates downward.


4. Audiology will sustain a combined impact of -7% due to the requirement for budget neutrality and the adjustment for the increases in the Evaluation and Management codes that audiologists are not permitted to use within Medicare. There will be changes to the requirements for use of E/M codes, including the deletion of CPT 99201.


5. CMS has currently not made any telehealth changes for audiologists for 2021. Until the current pandemic health emergency has been deemed concluded, only the four cochlear implant codes — 92601, 92602, 92603, and 92604 — are permitted to be provided via telehealth, which occurred due to the waivers that CMS instituted during the pandemic.


6. The Merit Incentive Payment System (MIPS) is maintaining the same reporting requirements for mandatory reporting for audiologists, which will impact very few audiologists. You must meet all three of these requirements:
a. Receive $90,000 or more in allowed reimbursement from Medicare and
b. Provide 200 or more covered professional services and
c. Provide services to 200 or more Medicare beneficiaries

You may choose to report voluntarily. If you elect to do so, contact Debbie Abel, Au.D., at [email protected], and the process can be explained. It is strongly recommended that you check your eligibility here. Currently, you can access information for 2020, but information for 2021 is likely to be posted in early 2021.

The next step is that on or around November 1, the final rule is to be distributed. This is what will take place in the following year and will be effective on January 1, 2021.

Finally, if you haven’t already started to use the updated Advanced Beneficiary Notice (ABN) CMS-R-131, with the 6/30/2023 expiration date, you may use it now, but it will be required by 1/1/2021. It is posted on CEO and can be found here.

If you have any questions, please contact Debbie Abel, Au.D., at [email protected].

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Deb Abel, Au.D. – ADA President and Manager of Coding and Contract Services

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