The Centers for Medicare and Medicaid Services (CMS) Medicare Proposed Physician Fee Schedule (Proposed Rule) includes a proposal to allow Medicare Part B beneficiaries limited direct access to audiologists for hearing assessment services by allowing audiologists to furnish certain diagnostic tests without a physician order.

CMS states: “We are proposing to allow beneficiaries to have direct access, when appropriate, to an audiologist without a physician referral by creating a new HCPCS code (GAUDX) for audiologists to use when billing for audiology services they already provide that are defined by other code(s).

The service(s) encompassed by the new HCPCS code would be personally furnished by the audiologist and would allow beneficiaries to receive care for non-acute hearing or assessments unrelated to disequilibrium, hearing aids, or examinations for the purpose of prescribing, fitting, or changing hearing aids. We are proposing to permit audiologists to bill for this direct access (without a referral) once every 12 months.”[1]

CMS, in its proposal, agrees with “interested parties”, including the Academy of Doctors of Audiology (ADA) that CMS has the authority to authorize the elimination of the physician order requirement and agrees with a report provided by ADA and other interested parties, that the proposal will result in a cost savings to the Medicare system.[2]

• The CMS Proposed Rule affirms that the Medicare statute must be changed to classify audiologists as [Non-Physician Practitioners] NPPs as defined by the statute (that is, they are not listed at section 1842(b)(18)(C) of the Act), but notes “beginning in 2008, we [CMS] allowed audiologists to enroll in the Medicare program so that they could independently bill for their audiology services rather than relying on physicians or other enrolled practitioners to bill on their behalf.”
• Because audiology services are currently classified under Medicare statute as “diagnostic other.” CMS, in the proposed rule affirms that unless there is a statutory update, to allow audiologists to deliver the Medicare-covered treatment services that they are licensed to provide, audiologists are not recognized under Medicare Part B to treat or manage patients.
• The Medicare Audiologist Access and Services Act (H.R. 1587 and S. 1731 will make the necessary updates to Medicare statutes to improve beneficiary access to audiology services, to reclassify audiologists from suppliers to practitioners and to effectively deploy audiologists as clinical doctoring professionals within the Medicare system.

[1] https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2023-medicare-physician-fee-schedule-proposed-rule
[2] https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched