Purpose of Session Review Medicare audiology coverage policy 2008 Medicare audiologytransmittals Discuss Issues raised by transmittals Possible outcomes 1
Three Audiology Update Transmittals Transmittal 84 re: Medicare Publication 100-02 Transmittal 1470 re: Medicare Publication 100-04 Transmittal 1550 re: Medicare Publication 100-04 Purpose oftransmittals: Update Re-affirm Clarify Codify Transmittal 84 Published February 29, 2008, Effective Date: April 1, 2008 Implementation Date: April 7, 2008 Update toaudiology Policies for Benefit Policy Manual Significant clarifying language 2
Transmittal 84: Medicare Benefit Policy Audiology tests under "Other Diagnostic Tests" category Defines audiology diagnostic services Affirms that Medicare does not pay for treatment of auditory (or vestibular) disorders Affirms that tests may be ordered when suspicion of impairment of auditory system (tinnitus, auditory processing, and balance) Transmittal 84: Background The Medicare Benefit Policy Manual re: audiology services not been updated since 2003. Over previous 5 years, requests for clarification for some ofthe language. The definition of hearing aid has been changed since 2003 (100-02, chapt. 16); the updated language included in Transmittal 84 3
Transmittal 84: Major Points Audiology services paid under the policy of "other diagnostic tests" Audiology services will not be paid if billed "incident to" Audiology services paid based on the reason for the test Payment not be based solely on the posttest information Transmittal 84: Major Points Payment will not be based on the specialty ofthe physician or non-physician practitioner ordering the test Payment for retest will not be denied when the procedure is necessary for: Appropriate medical treatment Appropriate surgical treatment Evaluate the results oftreatment 4
Transmittal 84: Major Points No payment for computer administered tests that do not require the skills of an audiologist Medicare will pay global charge of audiological diagnostic tests when they are furnished by a qualified audiologist, physician, or non-physician practitioner Tests administered by a qualified technician must be documented including the name and professional identity ofthe technician who actually performed the service Transmittal 84: Major Points Payment oftests performed by a qualified technician is contingent upon role of physician or non-physician supervisor who provides: Direct supervision Clinical decision making Active participation in delivery ofthe service 5
Transmittal 84: Major Points Audiologists not paid for treatment services (AR & canalith repositioning 2009) Payment not made for services furnished by an AuD 4 th year student or others who are not qualified according to section 1861(11)(3) ofthe Social Security Act Speech-language pathology services for impairments ofthe auditory system paid under SLP service policies Transmittal 84: Major Points Physician orders for diagnostic audiological tests provided by technicians must specify each test individually that the technician will perform 6
Transmittal 84: Hearing Devices Osseointegrated prosthetic devices (e.g., BAHA) are covered for payment according to indications in Publication 100-02, chapter 16, section 100 Congenital malformations Chronic disease Severe sensorineural hearing loss (single sided deafness) Surgery Transmittal 1470 Update toaudiologypolicies for Medicare Claims Processing Published February 29, 2008 Effective Date: April 1, 2008 Implementation Date: April 7, 2008 7
Transmittal 1.470: Payment Policy Contractors shall pay audiologists for the global service when audiologists perform both the technical and professional components of services that have both components Contractors shall pay audiologists for the technical component of audiological tests when they perform only the technical component and the physician provides the professional component Transmittal 1.470: Payment Policy Diagnostic analysis of implants (cochlear, osseointegrated or brainstem implants) shall not be paid as part ofthe global fee for the surgery Auditory processing: Contractors shall pay for the timed codes when billed for appropriately provided evaluation of central auditory function 8
Transmittal 1.470: Payment Policy Diagnostic programming of implant device: service is payable to audiologists or physicians who personally provide the service Diagnostic programming of implant device: service is NOT payable to speech-language pathologists Transmittal 1.470: Payment Policy Auditory rehabilitation: evaluation of auditory rehabilitation status is payable to both audiologists and speech-language pathologists - now in question Auditory rehabilitation: distinguished between diagnostic programming of implant device and rehabilitation services 9
Transmittal 1.470: Payment Policy Contractors shall not pay for services documented as audiological services when they have been furnished through the use oftests administered by computers that do not require the skills of an audiologist Transmittal 1.470: Payment Policy Osseointegrated implants: Payment is under a pass-through payment. Contractors will pay for the covered device using whatever payment system is appropriate 10
Transmittal 1500 Clarifications to AudiologyUpdate Transmittal 1.470/ Change Request 571.7 Published July 18/2008 Effective Date: October 1/ 2008 Implementation Date: August 18/ 2008 Transmittal 1550: Payment Policy For claims with dates of service on or after October 1/2008/ audiologists shall enroll in the Medicare program For claims with dates of service on or after October 1/ 2008/ the NPI ofthe enrolled audiologist shall be used on the claims in the appropriate rendering and billing fields 11
So/ what does this mean? "Other Diagnostic Tests" Radiological tests Audiological tests Established in 2003 Not to be billed "incident to" Policy ignored or misunderstood by physicians Re: billing through the physician Re: billing through the practice Should have been billing through the audiologist So, what does this mean? The reason for the test trumps the outcome ofthe test Relative to hearing aids Relative to when there is no change in hearing The reason for the test must focus on "medical necessity" Undiagnosed complaints, symptoms, and presenting concerns Change in status of previous diagnosis 12
So/ what does this mean? Affirms that reimbursement system based on the clinical judgment and personal delivery of services for audiological tests Majority of reimbursement is based on personal delivery of services and skills of an audiologist Physician work Stafftime for audiologists Will not pay for delivery of services not requiring skills of audiologist or physician E.g.,otogram So, what does this mean? Restates that audiologists are eligible for global payment (both professional and technical components) ifthe audiologist performs both parts Audiologists are eligible for technical component only ifthe physician provides the interpretation and professional component 13
So/ what does this mean? When audiologist does not perform test, physician must be intimately and directly involved in delivery of service. Must be a qualified technician Physician must provide direct supervision, provide clinical judgment, and ensure the appropriate administration ofthe test Each procedure may be billed as a test Identity oftechnician must be documented So, what does this mean? As ofoctober 1,2008, audiologists must enroll in Medicare and must bill under their own NPI This requirement applies only to Medicare (at this time) Enforcement left to contractors No prohibition against "incident to" billing for private commercial payers 14
So/ what does this mean? Questions yet to be addressed: Physician billing of audiological tests relative to evaluation and management (ElM) services Will there be a determination of which procedures a technician cannot perform even under physician supervision? What is next? Audiology organizations - ASHA and AAAwill be meeting with Centers for Medicare and Medicaid Services (CMS) officials ASHA represented by Health Care Economics Committee audiologist and Health Care Economics and Advocacy National Office staff 15
This PowerPoint Will be on the 2008 ASHA Convention site Transmittals are on CMS website and ASHA website (can do Internet search and find them too) Questions? 16