Medicare Manual Revisions Will Affect Clinicians Substantive revisions to Chapter 15 of the Medicare Benefit Policy Manual were recently announced by the Centers for Medicare and Medicaid Services (CMS), effective June 6. A detailed table on ASHA’s Web Site addresses each policy revision. This column discusses the revisions that will most impact coverage, documentation and claims ... Bottom Line
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Bottom Line  |   July 01, 2005
Medicare Manual Revisions Will Affect Clinicians
Author Notes
  • Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.
    Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.×
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Practice Management / Bottom Line
Bottom Line   |   July 01, 2005
Medicare Manual Revisions Will Affect Clinicians
The ASHA Leader, July 2005, Vol. 10, 3-15. doi:10.1044/leader.BML.10092005.3
The ASHA Leader, July 2005, Vol. 10, 3-15. doi:10.1044/leader.BML.10092005.3
Substantive revisions to Chapter 15 of the Medicare Benefit Policy Manual were recently announced by the Centers for Medicare and Medicaid Services (CMS), effective June 6. A detailed table on ASHA’s Web Site addresses each policy revision. This column discusses the revisions that will most impact coverage, documentation and claims submission procedures. Keep in mind that although Part B coverage is generally outpatient, it also applies to qualified inpatients who have exhausted Part A benefits.
The complete revision in the Medicare Benefit Policy Manual [PDF] is available at the CMS Web site.
Although not a new Medicare policy, it is worth noting that all physician responsibilities cited below may also be carried out by non-physician practitioners: physician assistants, nurse practitioners or clinical nurse specialists. The policies discussed apply equally to SLPs, physical therapists and occupational therapists unless otherwise indicated.
  • Physician orders/referrals—A physician order or referral is no longer required before a rehabilitation professional commences treatment. Furthermore, an order or referral need not be documented in the medical record as long as a physician approves the plan of care (POC). A referral, however, is one way to be assured that a physician is involved in the care and available to certify the POC. (The POC must be physician-approved within the first 30 days or one month interval of treatment. The plan for each interval of treatment must be approved/certified by a physician before or during the interval.) (§15/220.1.1)

  • Physician visits—Visits are no longer required at minimum intervals; they are now at the discretion of the attending physician. (§15/220.1.3.C)

  • Plan of Care—It is essential that documentation include a plan of care, established by the therapist or physician prior to treatment and approved by the physician within the first 30 days. The minimum requirements for a plan are diagnosis; long term goal(s); and type, frequency, intensity and duration of treatment, signed and dated including the author’s credential (CCC-SLP). (§15/220.1.2.B)

  • Physician Certification—Approval of the POC represents physician certification that the plan was established, the patient needed the care, and the patient is under the care of a physician. It may be in any form that conveys this information and includes a dated signature. For example, physician approval of the POC can be confirmed by submitting a physician order including a plan, or a progress note referencing the plan. (§15/220.1.3.A)

  • Delayed certification—Physician certification can be signed up to 30 days late without documented justification for lateness. After this grace period, it may be necessary to submit other evidence of the physician’s involvement in the care, if requested by the intermediary or carrier. (§15/220.1.3.D)

  • Aural rehabilitation—Speech-language pathologists are now covered for aural rehabilitation beyond speech reading services. This includes auditory training, multimodal training, communication strategies, and comprehension/production in oral, signed, and written modalities. (§15/230.3.D.3)

  • Modified barium swallow studies—Dysphagia instrumental assessments can be performed using fixed, mobile, or portable equipment in a team setting with a physician or NPP who provides supervision of the radiological examination and interpretation. (§15/230.3.D.4)

  • Dysphagia services: demonstrated competencies—Practitioners who perform dysphagia services are expected to have specific competencies in upper aerodigestive tract structure and function as well as oral, pharyngeal, laryngeal and respiratory function. (§15/230.3.D.4)

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July 2005
Volume 10, Issue 9