by Mark Kander
Following the recent release of the proposed 2005 Medicare Fee Schedule, ASHA submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) in late September on proposed rates and regulatory revisions. ASHA's comments targeted vestibular functionvertical electrode recording, initial preventive physical examinations, qualifications of SLPs employed by physicians, and successful audiology and speech-language pathology telehealth applications.
Vertical Electrode Recording
ASHA requested that CMS instruct local intermediaries and carriers regarding new coding rules for vertical electrode recording (CPT™ 92547). Additionally, ASHA will work with the American Medical Association (AMA) so that it revises the instruction for this procedure to state that the code may be billed more than once per day, reflecting the revised Medicare fee based on payment for each recording instead of per patient. The new national average payment for vertical electrodes will reflect the actual time to perform the add-on procedure.
Preventive Examinations
ASHA also addressed the role of hearing screening as an element of the preventive physical examination to be covered by Medicare as mandated by the Medicare Modernization Act of 2003. ASHA presented evidence to ensure that a conventional or handheld audiometer would be required for screening and, in lieu of such devices, the use of one of two recommended hearing questionnaires. The comments stressed the inaccuracy of other so-called hearing screens such as the whisper, coin click, or watch-tick test. The proposed regulations also specify that education, counseling, and referral are components of the physical examination. Thus, ASHA provided specific guidance regarding referrals, referencing peer-reviewed articles that identified audiometric testing by an audiologist as the first step in the clinical workup after hearing loss is detected.
Minimum Qualifications
CMS proposed the following minimum standard for SLPs in physician offices: (1) meets the education and experience requirements for a Certificate of Clinical Competence granted by the ASHA, or (2) meets the educational requirements for certification and is in the process of accumulating the supervised experience required for certification.
ASHA presented comments on a similar preliminary proposal in 2003, stating that the qualifications will ensure that high quality services are rendered in physician practices. This regulation is especially important because the Medicare law does not require state licensure for therapists employed by physicians.
Telehealth Services
By January 2005, CMS must submit recommendations to Congress for coverage of additional telehealth services by Medicare. In the proposed regulation, CMS acknowledged that ASHA had earlier submitted reports illustrating a number of existing telehealth networks that are successfully providing diagnosis, treatment, and management of speech, language and hearing disorders. ASHA's written comments stress the importance of including this information in the CMS report to Congress.
For more information contact Mark Kander, director of health care regulatory analysis, at mkander@asha.org or through the Action Center at 800-498-2071, ext. 4139.