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Including STARs Updates
Colorado State Advocate for Reimbursement
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

Updates and Communications by Date

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.

 

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:

  • What is a private practice?

  • Who can bill?

  • How do I register for Medicare?

  • How do I bill?

  • and many more ....

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 
Facebook Logo Search on Facebook for "Colorado Coalition of Autism Professionals"

June 30, 2009

The June ASHA SLP Advocate is devoted to Medicare reimbursement issues. 

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.

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.

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.

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

Update Log
Medicare Info HERE
Medicare Releases New Audiology Transmittals
(May 29, 2010)
Medicare Billing for
SLPs in Private Practice

(May 26, 2010)
Colorado Coalition of Autism Professionals
(March 9, 2010)
SLP Advocate Features Medicare Issues
(June 30, 2009)
Enrollment After July 1 (June 29, 2009)
Processing Delayed
(June 29, 2009)
Retroactive Medicare Billing
(June 8, 2009)
 
 

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