Medicare's unfair market barriers restrict access to audiologic care for older Americans and hold the audiology profession hostage. To receive coverage for diagnostic audiology services provided by an audiologist, Medicare Part B patients must first obtain a physician order—even though there is no order requirement in the Medicare statute and audiologists are already responsible for medical necessity under Medicare.
Other federal agencies recognize that a mandatory visit to a physician's office for adult patients who may have a hearing or balance problem inflates the cost of care with no meaningful clinical benefit. Federal programs like the Veterans Affairs (VA), the Federal Employee Health Benefit Plan (FEHBP), and many Medicaid programs allow patients to seek treatment directly from audiologists without a physician order. In 2016, the U.S. Food and Drug Administration (FDA) also took voluntary action to stop enforcing the medical evaluation requirement for adult patients seeking hearing aids (US FDA, 2016).
Audiologists are licensed in every U.S. state and territory to provide a wide range of Medicare-covered treatment services, yet Medicare beneficiaries are statutorily channeled to a limited set of legacy providers. Meanwhile, audiologists are sidelined—prohibited from receiving Medicare reimbursement for treatment services altogether. As Medicare continues its progression toward outcome-based reimbursement models, audiologists will be increasingly left behind because they are not recognized treatment providers under Medicare Part B. For example, under the proposed Medicare Physician Fee Schedule released on July 12, 2018, audiologists are slated to become the only clinical doctoring provider class excluded from participation in Medicare's Merit-based Incentive Payment System (MIPS) in 2019.
Private insurers, including most Medicare Advantage plans, already allow patients direct access to audiologists and reimburse audiologists for the covered services they are licensed to provide. Other federal laws prohibit health plans from discriminating against entire classes of qualified, licensed health care professionals solely based on their provider type. Why do Medicare Part B patients have to undergo an expensive and time-consuming process to obtain coverage for audiologic care that could be efficiently and conveniently provided by audiologists?
The Audiology Patient Choice Act (APCA), if enacted by the U.S. Congress, will bring Medicare in line with today's evidence-based practices, allowing Medicare Part B coverage for beneficiaries who seek care directly from audiologists, including covered treatment services provided within the audiologists’ state-defined scope of practice. APCA has been introduced in both the U.S. House of Representatives and the U.S. Senate (H.R. 2276 and S.2575, respectively) to improve patient access to audiology services and increase public awareness about the importance of hearing and vestibular health.
APCA will add audiologists to the list of Medicare-defined physicians, as is consistent with Medicare's treatment of clinical doctoring providers such as optometrists, podiatrists, dentists, and chiropractors. Placing audiology in the correct classification will ensure proper tracking of outcome measures and foster greater transparency and accountability in the delivery of hearing and balance care to Medicare Part B patients.
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