Medicare Update Cites SLPs’ Role Several changes in the Centers for Medicare and Medicaid Services (CMS) Benefits Policy Manual will improve services to patients, and recognize the primary role that speech-language pathologists play in the delivery of services to patients. ASHA had a hand in the changes, providing extensive comments to CMS on the draft ... Policy Analysis
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Policy Analysis  |   June 01, 2005
Medicare Update Cites SLPs’ Role
Author Notes
  • Lusis Ingrida, director of federal and political affairs, can be reached at ilusis@asha.org.
    Lusis Ingrida, director of federal and political affairs, can be reached at ilusis@asha.org.×
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Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   June 01, 2005
Medicare Update Cites SLPs’ Role
The ASHA Leader, June 2005, Vol. 10, 1-15. doi:10.1044/leader.PA.10082005.1
The ASHA Leader, June 2005, Vol. 10, 1-15. doi:10.1044/leader.PA.10082005.1
Several changes in the Centers for Medicare and Medicaid Services (CMS) Benefits Policy Manual will improve services to patients, and recognize the primary role that speech-language pathologists play in the delivery of services to patients. ASHA had a hand in the changes, providing extensive comments to CMS on the draft revisions to Medicare’s coverage policies for outpatient speech-language pathology services.
The CMS issued the modifications on May 6. New language states that a physician order alone is not required for speech-language pathology services to be provided to a Medicare beneficiary. Rather, Medicare payment will be contingent on the physician’s certification of the plan of care. This change does not allow for direct access to therapy services, as Medicare law requires the patient be under the care of a physician.
“The fact that the SLP does not have to have an order in hand before seeing the patient will facilitate service delivery,” said Nancy Swigert, chair of ASHA’s Health Care Economics Committee, who called the changes “exciting.”
As part of the changes, CMS outlines specific requirements that must be met in order to receive payment for outpatient rehabilitation services:
  • The services are medically necessary

  • A plan of care has been established by either a speech-language pathologist or the physician

  • Services were provided while the individual is or was under the care of a physician

CMS cautions that although an order is not required for payment, documentation of an order is prudent because it confirms that the physician is involved in the care of the beneficiary. Medicare will continue to require a physician review of the plan of care every 30 days. CMS has waived the necessity that the beneficiary be seen by the physician in order to certify the treatment plan.
CMS also changed the requirements for physician visits from at least once during the first 60 days and every 30 days thereafter, to allowing the physician to determine necessary time and interval visits.
In clarifying speech-language pathology services specifically, CMS added expanded information on the coverage of aural rehabilitation, stating that covered services include comprehension and production of language in oral, signed or written modalities, auditory training, speech reading, multimodal training and communication strategies.
MBS Exams
In rewriting its coverage criteria for dysphagia services, CMS recognizes that fixed, mobile or portable equipment can be used in the modified barium swallow (MBS) examination. CMS also addressed ASHA’s concerns that under current requirements incompetent individuals could provide dysphagia evaluation and treatment services. In its revisions CMS includes a list of competencies required for reimbursement for dysphagia services. Payors may evaluate competencies in their audits of retroactive denials. An SLP can demonstrate competencies by documenting education, training and experience.
“For patients with dysphagia in long-term care facilities, the description of equipment used for instrumental assessments as ‘fixed, mobile or portable’ may mean greater access to crucial instrumental evaluations,” Swigert said.
The changes also codified regulations that outline what qualifications an individual must have in providing services incident to a physician’s services. Before a physician can bill for such speech-language pathology services, the provider must meet education and experience requirements for a Certificate of Clinical Competence, or meet educational requirements for certification and be working to accumulate the required supervised experience.
Swigert said ASHA applauds CMs’ efforts. “It is exciting to see specific competencies defined,” she said, noting the importance in mentioning SLPs as those professionals who perform clinical and instrumental assessments. “They are recognized for their ability to analyze and integrate the diagnostic information to determine candidacy for intervention as well as appropriate compensation and rehabilitative therapy techniques.”
The CMS change request is available at www.cms.hhs.gov/transmittals/downloads/R34BP.pdf.
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June 2005
Volume 10, Issue 8