By Alexis Guerra
Three national audiology assiociations sent a joint letter to the Centers for Medicare and Medicaid (CMS) requesting the removal of the Medicare physician order requirement. The Academy of Doctors of Audiology (ADA), the American Academy of Audiology (AAA), and the American Speech-Language-Hearing Association (ASHA) sent the letter on June 2.
"Our organizations request that CMS remove the requirement under Medicare that beneficiaries obtain a physician order prior to an appointment with an audiologist because it exceeds state scope of practice laws, impedes beneficiary access to care, and adds unnecessary costs to the healthcare system," the letter states.
Because of the requirement, Medicare beneficiaries must go to their physician first before getting access to an audiologist's services. Most states and private insurances, however, do not have this requirement — allowing patients with private or no medical insurance to have direct access to an audiologist.
The letter states that the Department of Defense, the Veterans Health Administration (VHA), and a majority of the plans offered through the Federal Employees Health Benefits Program also allow direct access.
"Medicare's requirement that a patient has a physician order for the diagnostic testing services of the audiologist is sort of contrary or contradicts what most states, if not all states, currently expect," said ASHA's Director of Health Care Policy, Medicare, Sarah Warren.
According to Warren, the requirement delays access to Medicare beneficiaries because of the need to coordinate an appointment with both the physician and audiologist. If the requirement were to be eliminated, "the harmful downstream effects of untreated hearing loss such as fall and expedited cognitive decline" could decrease, according to the letter.
In addition to the impediment to care, the physician order requirement adds unnecessary costs to the health care system. The letter includes quotes from then VHA Acting Deputy Under Secretary for Health, Michael Kussman, MD, about the VHA's direct access policy from a 2004 letter. The quotes say that the direct access policy avoids unnecessary clinic visits, and the VA has not experienced patient complaints or problems as a result of the policy.
The letter also points out that there is no statutory language in place that prohibits Medicare from allowing beneficiaries direct access to audiology services — giving CMS the authority to eliminate the physician order requirement. It also states that allowing direct access would not have an impact on the role of physicians and other primary care providers.
To bypass the physician order requirement, the letter suggests that audiologists could also be added to the list of certain non-physician providers currently able to administer diagnostic tests without a physician order. Warren says that legislation (H.R. 4056 and S. 2446) presented previously to the U.S. House and Senate by audiology organizations would not only remove the physician order requirement but also allow for covered treatment outside of diagnostic testing, and reclassify audiologists under Medicare as practitioners.
"The legislation would enable audiologists to perform the treatment that's within their scope of practice under state law that they're trained and educated to provide by the virtue of completing their doctoral program," Warren told The Hearing Journal.
Reclassifying audiologists as practitioners would also allow for audiologists to provide Medicare-covered telehealth services. Currently, there is a statutory exclusion for those classified as a supplier under Medicare to do so.
"This legislation is so crucial because all three organizations worked together to develop this legislation and are working hard together to get it passed," said Warren. "I think that speaks volumes about how critical this legislation is."
Audiologists looking to support these efforts can use ASHA's take action center, where information on key legislation and elected officials can be found, or visit the AAA and ADA websites.
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