by Kelly Appler and Mark Kander
Questions often arise from speech-language pathologists about Medicare policies and the use of a speech-language pathology assistant (SLPA). When a treatment plan is established by a certified clinician but implemented by an assistant, will Medicare reimburse facilities for these speech-language services?
Skilled Services
Medicare (as well as most private insurers) does not provide a different rate of reimbursement for the services of an SLP as opposed to an SLPA. When the SLPA is implementing treatment devised by the SLP, services may be covered as skilled services when consistent with Medicare coverage criteria (e.g., there must be expectation of significant improvement in a reasonable period of time). Medicare will not reimburse for non-skilled speech-language services such as routine, repetitive, and reinforced procedures. Clear definitions and examples of skilled/nonskilled services are provided in the Medicare Program Integrity Manual, Chapter 6, Section 6.5 of "Medical Review of SLP Services" [PDF].
SLPAs' Coverage Is Determined Locally
SLPAs (and services provided by an SLPA) are not recognized or defined in Medicare law or regulations. Medicare policy manuals for each provider setting state that covered speech-language pathology services "must be of such a level of complexity and sophistication, or the patient's condition must be such that the services required can be safely and effectively performed only by or under the supervision of a qualified speech-language pathologist."
The Centers for Medicare and Medicaid Services (CMS) have delegated to each local intermediary the responsibility to determine whether the type or degree of supervision is adequate for coverage of SLPA services. For example, in August 2000, ASHA received verification from the Wisconsin Medicare intermediary that SLPA services are covered when furnished under appropriate supervision. Facilities should contact their intermediaries to confirm if a policy for SLPA coverage has been established.
Remember also to abide by any state regulations that apply to SLP assistants or aides. You may wish to work with your state's Medicare intermediary and carrier network member if SLPA coverage is problematic. To identify your network member, contact Ingrida Lusis (see contact information below).
Supervision
If there are any questions regarding what constitutes adequate supervision, the Medicare intermediary should be directed to ASHA's 1995 "Guidelines for the Training, Credentialing, Use, and Supervision of Speech-Language Pathology Assistants." If the services provided by the SLPA constitute skilled care and the facility follows ASHA supervision guidelines, this should be sufficient information for the intermediary to establish an SLPA coverage policy.
The following materials can be provided to Medicare intermediaries that are considering coverage of SLPAs:
- 1996 CMS letter that gives discretion to local intermediaries (see "Reimbursing SLPA Services")
- Medical review guidelines (cited on page 3) that define skilled services
- SLPA's license/certificate/registration number, if your state has regulations for SLPAs
When Will Medicare Regulations Include SLPAs?
Once ASHA implements a national mechanism for recognizing SLPAs through a registration process beginning in January 2003, the Association will be in a better position to approach CMS on reimbursement issues or separate coverage for assistants. The ASHA Governmental Relations and Public Policy Board and the Health Care Economics Committee are currently studying the ramifications of revised regulations that would recognize ASHA-credentialed SLPAs.
For more information, visit ASHA's Web site. For additional information on Medicare and SLPAs, contact Mark Kander through the Action Center at 800-498-2071, ext. 4139, or by e-mail at mkander@asha.org; or contact Ingrida Lusis at ext. 4482 or by e-mail at ilusis@asha.org. For information about ASHA's guidelines for training, use, and supervision of SLPAs, contact the Action Center by email at actioncenter@asha.org or by phone at 800-498-2071.