Including STARs Updates
Colorado State
Advocate for
Reimbursement
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The State Advocates
for Reimbursement (STARs) are ASHA-member
audiologists and speech-language pathologists
who are willing to advocate locally with
legislators, state insurance commissioners,
health plans, unions, and employers on matters
related to health plan reimbursement. They share
their advocacy skills and help create coverage
and reimbursement strategies with state
associations. They are the link between your
state and ASHA.
The
STARs network members are eager and willing to offer
assistance, share information, and seek
solutions to the reimbursement issues that
challenge the financial viability of our
professions. Network members must be able to
count on you, their colleagues, to work with
them to effect change in the health plan system.
Their mission is to
advocate for consistent coverage and equitable
reimbursement rates for speech-language
pathology and audiology services.
Colorado's State Advocates are Ann Pendley,
pendley@frii.com and Beth O'Brien,
Beth@chsl.org |
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| Updates and
Communications by Date |
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April 28, 2011
SNF Medicare Proposed Regulations Released
for FY2012
On April 28, 2011, the
Centers for Medicare & Medicaid Services (CMS)
posted proposed regulations for skilled nursing
facilities (SNFs). For services to Medicare Part
A patients, two topics are of special interest
to speech-language pathologists: (1) proposed
restrictions regarding group treatment and (2)
possible removal of restrictions regarding
supervision of students.
Currently, group
treatment for therapy services is defined as
similar services provided to two to four
patients. CMS would like to limit group therapy
size to four beneficiaries-no more or no less.
There are numerous issues caused by a four
patient requirement as well as problems in the
rationale. CMS states that in groups of two or
three participants "the opportunities for
patients in the group to interact and learn from
each other are significantly diminished given
the small size of the group." CMS cites no
evidence to support this claim. Therapy groups
of less than four participants are reasonable on
many grounds including the availability of a
lesser number of patients and the improvement
seen when there are two to three patients in a
group.
Another proposed change in group treatment
policy is one that would allocate Resource
Utilization Group (RUG) minutes of treatment
among each of the group treatment participants
rather than counting each patient's
participation time fully. The proposed revision
would require all groups to consist of four
patients and the time would be allocated among
each of the patients. Thus, a 30 minute session
for four patients would be counted as seven
minutes for each patient in regard to RUG
recording rather than 30 minutes per patient.
The CMS rationale appears to be that inaccurate
recording of resource allocation occurs when 30
minutes of therapist time is recorded as 90 or
120 minutes for three or four patients,
respectively.
The second proposal of interest is the
removal of supervision restrictions for therapy
students treating Part A patients. The current
requirement is line-of-sight supervision and the
supervisor cannot simultaneously be treating
other patients. CMS states that other Part A
inpatient settings (e.g., hospitals) have no
such restrictions and "we consider it
inequitable for SNFs to be subject to a more
restrictive set of standards in this regard."
Therefore, "each SNF would determine for itself
the appropriate manner of supervision of therapy
students consistent with applicable State and
local laws and practice standards."
ASHA is starting an
informal advisory group to assist with
developing comments. The regulatory comments are
due to CMS by June 27, 2011, with final
regulations taking effect October 1, 2011. The
full text of the proposed regulations is
available at
http://www.gpo.gov/fdsys/pkg/FR-2011-05-06/pdf/2011-10555.pdf.
For further information, please contact
reimbursement@asha.org.
Lemmietta G. McNeilly,PhD, CCC-SLP, CAE, ASHA
Fellow
Chief Staff Officer, Speech-Language
Pathology
American Speech-Language-Hearing
Association
2200 Research Boulevard, #229
Rockville, MD 20850-3289
+1 301-296-5705
telephone
301-296-8577 fax
lmcneilly@asha.org
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April 15, 2011
Please join us for a May is Better Hearing
and Speech Month Advocacy program at The State
Capitol!
When? -
Wednesday, May 4th from 8:15 a.m. - 10:00 a.m.
Schedule of events:
8:30 - 9:00 a.m. - Meet & Greet Legislators
(hallway with breakfast & information to share)
9:00 - 10:00 a.m. - Advocacy Program for
SLPs and Audiologists (Old Supreme Court
Chambers)*
*Contact hours (1) will be
available for participants.
Further details and directions will be coming
shortly. Help us get out the word and encourage
attendance!! - Send this announcement on to your
colleagues!!
- Terry Eberly will be coordinating the
food & drink, so if you are able to help us
provide breakfast items, please let her
know. (
teslp77@comcast.net )
- CSHA T-shirts should be available by
then and we will include information on how
to get yours in the next mailing.
- Students are welcome and encouraged to
attend.
- More to follow - MARK YOUR CALENDARS!!
CSHA Public Policy Committee
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January 1, 2011
Update on Compliance
Requirements for Medicare In-the-Room Physician
Supervision: Videostroboscopy and
Nasopharyngoscopy
NOTE: ASHA is in the
preliminary stages of discussing a joint letter
with AAO-HNS to CMS regarding this issue.
The Centers for
Medicare & Medicaid Services (CMS) determined
that, effective January 1, 2011; a physician
must be in the room when a speech-language
pathologist performs a videostroboscopy or
nasopharyngoscopy procedure (CPT31579, 92511).
The decision was made as the result of a
practitioner's inquiry to a CMS regional office
regarding Medicare supervisory requirements. The
new requirement is not currently available on
the national CMS WebSite. However, reference to
the supervision requirement should be available
on all Medicare Administrative Contractor (MAC)
Web sites. An example of the supervision level
display is on the [LINK:
http://www.trailblazerhealth.com/Tools/Fee%20Schedule/MedicareFeeSchedule.aspx
]
Trailblazer MAC fee
schedule Web site which, incidentally, can be
used to request geographically adjusted fees for
any locality.
· Select Year (2011),
State (any), Locality (any)
· Insert procedure code
(31579 or 92511), Modifier (none)
· Click on "Search" ·
31579 or 92511 fee information appears
· Scroll down to
"Indicators"
· See "Physician
Supervision of Diagnostic Procedures"
· Click on question
mark adjacent to "03" for a description of the
03 level of supervision: "Procedure must be
performed under the personal supervision of a
physician."
The regulatory
definition of personal supervision is "in the
room." CMS has not released an explanation
regarding this ruling, nor has a separate
announcement been released. Furthermore, CMS did
not request information from ASHA or the
American Academy of Otolaryngology - Head and
Neck Surgery (AAO-HNS) before making this
decision.
FAQs Regarding
Compliance
· Does the supervising
physician need to be an otolaryngologist? No,
but for hospital outpatients the physician must
be able to perform the procedure (i.e., have the
specific training). For non-hospital settings
the Medicare requirement does not specify a
specialist but states "physician."
· There are times when
the patient referred for the examination is not
a patient of the otolaryngologists in our
office. What is their responsibility? The fact
that the patient is not being seen by a
physician in the practice is not relevant to
this issue. The same rules apply whether the
patient was referred to the practice
specifically for the procedure or is a patient
under the care of physicians in the practice or
hospital.
See question #1.
· Can the supervising
physician be a resident? No. According to the
CMS Division of Practitioner Services a resident
in a teaching setting under the Medicare program
may not be a supervising physician. This applies
to diagnostic tests as well as other services.
· What documentation is
necessary to indicate that a physician was
present? CMS has not established documentation
requirements.
· I'm employed at a
hospital. Who can provide guidance about
complying with the new supervision requirements?
Your hospital compliance officer should have
guidance regarding Medicare physician
supervision requirements.
· How can I keep
informed of the latest developments? We will use
ASHA Headlines to notify members of new
developments including assistance in advocacy,
if needed.
To subscribe to ASHA
Headlines, go to [LINK: http://www.asha.org/]
ASHA's Web site and insert "Headlines" in the
search box. Follow the subscribe instructions
listed.If you have any questions about the 2011
change in Medicare requirements for
videostroboscopy and nasopharyngoscopy
supervision, please contact
reimbursement@asha.org . LEMMIETTA G.
MCNEILLY,PHD, CCC-SLP, CAE, ASHA FELLOWCHIEF
STAFF OFFICER, SPEECH-LANGUAGE PATHOLOGYAMERICAN
SPEECH-LANGUAGE-HEARING ASSOCIATION
2200 RESEARCH
BOULEVARD, #229
ROCKVILLE, MD
20850-3289
+1 301-296-5705 TELEPHONE
301-296-8577 FAX
LMCNEILLY@ASHA.ORG
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May 29, 2010
Medicare Releases New Audiology Transmittals
The
Centers for Medicare & Medicaid Services (CMS)
issued revisions to two Medicare policy manuals
on May 28, 2010, effective July 28, 2010. The
clarifications and revisions affect the use of
audiometric technicians, computer-administered
audiometric devices (e.g., Otograms),
reevaluations, services rendered as an employee
or contractor of a physician, physician
assistant or nurse practitioner, and hospital
outpatient services. We will be consulting with
CMS to obtain further clarification on some of
the policy changes which are not completely
clear to us. In the interim, the following is
our understanding of the sections that discuss
audiometric technicians and
computer-administered devices.
The two transmittals -
CR 6447 Pub. 100-02, Rev. 127 and
CR 6447 Pub. 100-04, Rev. 1975, Rev. 1975 -
are both entitled Revisions and Re-issuance of
Audiology Policies. They state that Medicare
contractors shall not pay under the Medicare
Physician Fee Schedule (MPFS) for audiological
diagnostic tests furnished by technicians under
the direct supervision of a physician if the
test requires professional skills. However, the
transmittals state that there may be subtests,
or parts of a battery of tests, that may be
appropriately furnished by an “educated and
experienced technician using a specific protocol
under the direction of a supervising physician.”
The Medicare contractor will determine what
services do not require professional skills.
That is, CMS did not identify the specific tests
that require professional skills but rather is
leaving the decision to local Medicare
contractors.
Current Medicare policy sections that address
the Otogram have been deleted, giving the
carriers or Medicare Administrative Contractors
(MACs) discretion to cover such tests using
recently established HCPCS Level III codes,
usually reserved for procedures under
investigation. Although current policy states
that the Otogram is for screening purposes and
therefore not covered, this statement does not
appear in the revision. In the revision, CMS
indicates that computer-administered tests may
or may not be screening tests and that
contractors continue to have discretion to cover
or deny payment for services represented by
Category III CPT codes for computer-administered
tests.
In the explanation of Professional
Component/Technical Component (PC/TC) divided
codes, such as vestibular function tests, CMS
states that “a physician may not bill for a PC
service furnished by an audiologist.” An
audiologist employed or in a contractual
relationship with a physician or physician group
should be an enrolled supplier of Medicare
services. Audiologists who render services in
office or clinic settings should bill for the PC
services (or any covered audiological service)
using their own NPI as the rendering provider on
the claim. Audiologist may complete a
Reassignment of Benefits form (CMS-855R) so that
the payment for the service rendered by the
audiologist can be directed to the office of the
physician or group who pays the audiologist.
Please contact
reimbursement@asha.org with
questions or comments.
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May 26, 2010
Factsheet: Medicare Billing for SLPs in
Private Practice
This factsheet provides a wealth of
information that will save a lot of time for
SLPs confronting the challenge of beginning to
treat and obtain reimbursement for services from
Medicare under recent rule changes.
Get answers to the following questions:
Speech-language pathologists
(SLPs) provide services within their scope of
practice that are necessary for the diagnosis
and treatment of speech and language disorders,
which result in communication disabilities, and
for the diagnosis and treatment of swallowing
disorders, regardless of a communication
disability. Historically, Medicare could only
pay for speech-language pathology services if
the services were billed by an enrolled provider
or supplier of services. The Medicare
Improvements for Patients and Providers Act of
2008 (MIPPA) gave the Centers for Medicare &
Medicaid Services (CMS) the authority to enroll
SLPs as suppliers of Medicare services,
consistent with the enrollment policies that
apply to physical therapists and occupational
therapists in private practice. Enrollment
allows SLPs in private practice to bill Medicare
and receive direct payment for outpatient SLP
services. The enrollment process for SLPs in
private practice began on June 2, 2009. CMS
began accepting appropriate claims for services
provided by enrolled SLPs in private practice on
July 1, 2009 for dates of service beginning July
1, 2009.
Download Factsheet (PDF)
March 9, 2010
Colorado Coalition
of Autism Professionals
CSHA Members:
Please see the update from the Colorado
Coalition of Autism Professionals. The Colorado
Speech Language Hearing Association’s Board of
Directors and Licensure Committee have been
monitoring and supporting the efforts of this
group to ensure adequate representation for
speech-language pathologists who work with
children and adults with autism. CSHA
representatives will be among those who meet
with the insurance commission later this week.
Please check back on our website for updates
related to this meeting.
Don't miss the
opportunity to make a difference with the
Colorado Coalition for Autism Professionals.
COCAP was founded in response to the passing of
Senate Bill 244 mandating state insurance
providers to increase the coverage offered to
families caring for persons with autism. In
addition to providing a united front to
interface with insurance companies COCAP also
strives to generate meaningful, universal
clinical standards for Colorado providers and
interface with legislators to advocate for our
families. Committees are already forming for
Membership, Clinical Standards, Contracting and
Legislative Interface. Here are some recent
developments:
- The Division of
Insurance has set up a meeting with the
Executive Director of Colorado Association
of Health Plans and autism providers in
response to implementation of SB244.
Multiple meetings will occur throughout
March, many of the providers attending this
meeting were directly recruited from COCAP
members.
- HB1154 which would have
imposed a one-year moratorium on health
insurance mandates, died in the House State
Affairs Committee by ONE vote February 4,
2010. Jennifer Mello, our lobbyist, had to
do quite a bit of last minute negotiating to
ensure its demise. Additionally, she had to
fight off several amendment attempts, which
would have kept the bill moving through the
legislative process. COCAP's lobbyist and
testimony from COCAP members played a
significant role in this result. COCAP also
made progress in creating effective
partnerships with other organizations who
share our policy interests at the State
Capitol.
You can still be a part of
this exciting movement in Colorado. The next
meeting is April 12, 2010 from 6:00-8:00. Please
visit the website to stay up to date on meeting
information.
Access the
Coalition's Web page at:
www.developmentalbehavioralhealth.com
Search on Facebook for "Colorado Coalition
of Autism Professionals"
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June 30, 2009
The June ASHA SLP
Advocate is devoted to Medicare
reimbursement issues.
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Notice on ASHA
Web Site, June 29th, 2009
If you
have submitted your enrollment application, but
have not received acknowledgement of your
enrollment in Medicare by July 1, you may still
render services beginning July 1. Once you have
been informed of your acceptance into the
Medicare program, you may then retroactively
bill Medicare for services provided on or after
July 1. However, if your enrollment application
is submitted after July 1, you may only
retroactively bill Medicare for the services
provided starting from the date you submitted
your application.
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June 29, 2009
Processing of
SLP Medicare Enrollment Applications Will Be
Delayed
Speech-language pathologists
(SLPs) in private practice were able to begin
enrolling in Medicare as of June 2, 2009. Once
SLPs have their Medicare provider number, they
can begin billing Medicare for services starting
July 1, 2009. However, an SLP that has submitted
an enrollment application will likely not
receive a provider number by July 1. CMS
informed ASHA that it still needs to modify the
enrollment and claims processing system. These
modifications should occur by July 7. SLPs can
still submit applications, but the Medicare
contractor will not be able to process the
application until the modifications take place.
CMS also reconfirmed that if
an SLP has submitted an enrollment application,
but still does not have their provider number by
July 1, they can retroactively bill for services
starting on July 1, 2009 once they receive their
Medicare provider number. For questions or
further information, please contact Kate Romanow,
ASHA's Director of Health Care Regulatory
Advocacy, at kromanow@asha.org or 800-498-2071,
ext. 5671.
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June 8, 2009
Private Practice SLPs
May Retroactively Bill Medicare
Private practice
speech-language pathologists (SLPs) can now
enroll in Medicare. ASHA has received
confirmation from the Centers for Medicare and
Medicaid Services (CMS) that if a
speech-language pathologist has submitted an
enrollment application, but still does not have
their provider number by July 1, 2009 they can
retroactively bill for services starting on July
1, 2009 once they receive their Medicare
provider number. For further information or
questions, please contact Kate Romanow, ASHA’s
Director of Health Care Regulatory Advocacy, at
kromanow@asha.org or 800-498-2071, ext. 5671.
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Medicare/Medicaid Information and Links |
Medicare Part
B Contractor for Colorado:
www.Trailblazer.com
ASHA
Information on SLP Medicare Enrollment:
www.asha.org/practice/reimbursement/medicare/SLPmedicareenroll.htm
Access instructions for National
Provider Identification
HERE
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