The Challenge of Dysphagia Codes On March 1, when the 2003 Medicare Fee Schedule (MFS) took effect, payment rates for two common dysphagia assessment procedures—92610 and 92611—declined by nearly 70%. These codes were new, having been developed to replace two of the temporary “G” codes established in 2001 by the Centers for Medicare and Medicaid ... Bottom Line
Bottom Line  |   March 01, 2003
The Challenge of Dysphagia Codes
Author Notes
  • Steven White, is ASHA’s director of health care economics and advocacy.
    Steven White, is ASHA’s director of health care economics and advocacy.×
Article Information
Swallowing, Dysphagia & Feeding Disorders / Bottom Line
Bottom Line   |   March 01, 2003
The Challenge of Dysphagia Codes
The ASHA Leader, March 2003, Vol. 8, 1-19. doi:10.1044/leader.BML.08052003.1
The ASHA Leader, March 2003, Vol. 8, 1-19. doi:10.1044/leader.BML.08052003.1
On March 1, when the 2003 Medicare Fee Schedule (MFS) took effect, payment rates for two common dysphagia assessment procedures—92610 and 92611—declined by nearly 70%. These codes were new, having been developed to replace two of the temporary “G” codes established in 2001 by the Centers for Medicare and Medicaid Services (CMS).
The reductions came as a direct consequence of the loss of “physician work relative values”—which assess the role of physicians in clinical treatment—in the calculation of those procedures. No physicians testified about their role in these codes, and the change in work values was not made public because new codes were not published in the proposed MFS last spring, allowing no period of public comment.
In response, ASHA is pursuing two channels of advocacy to lessen the impact on SLPs—legislation that would allow clinicians to bill Medicare directly and have their services valued on the same scale as physicians, physical therapists (PTs), and occupational therapists (OTs); and exploring options that SLPs might use to lessen the impact of the cuts.
How the Codes Evolved
CMS established two temporary “G” codes in 2001 to report dysphagia assessment procedures. G0195 was used to report the evaluation of oral and pharyngeal swallowing function, and G0196 was used to report motion fluoroscopic evaluation of swallowing function by cine or video recording. G codes are used until permanent CPT codes are established; G0195 became CPT92610, and G0196 became 92611.
Many private payers do not recognize codes outside of the CPT system, which presented problems for some clinicians. Because of the temporary nature of these codes, ASHA was obliged to develop and submit applications for permanent CPT codes for these and a variety of other G codes assigned to dysphagia assessment and speech-generating device services.
ASHA’s Health Care Economics Committee (HCEC) proposed new procedural codes that were reviewed and approved by the American Medical Association (AMA) CPT Editorial Panel for inclusion in the 2003 CPT. Following approval by the CPT Editorial Panel, ASHA conducted surveys to document how much time was needed to conduct the procedures and the equipment and supplies necessary for the procedures. Those data were presented to the AMA Health Care Professionals Advisory Committee of the Relative Value Update Committee.
The data that were submitted and approved reflected the time the SLP spent preparing to conduct the procedure; the time spent with the patient during the procedure, and counseling the patient and others; and the time spent writing the report and contacting professionals involved with the care of the patient. CMS converted the accepted time, equipment, and supplies to a practice expense relative value unit.
Why Rates Were Reduced
The relative value units for each code included in the MFS have three components —a value for physician work, a value for practice expenses, and a value for malpractice expense. Physician work is only added to procedures in which a physician (or certain other private practitioners recognized by Medicare) participates in the service. Since the inception of the MFS in 1992, all dysphagia codes contained relative value units for physician work, which was most likely an error. When ASHA presented the new dysphagia codes in 2002, there were no data to justify the values being claimed, and therefore no support for physician involvement beyond the work of the SLP.
The time spent by the SLP for the dysphagia codes is considered practice expense. For example, for CPT 92610, a total of 74 minutes of an SLP’s time was assigned to this service. The time is multiplied by the salary cost per minute to derive the clinical staff cost. This cost and overhead costs are included in the practice expense value.
The practice expense relative value unit also declined for the two codes, since that value is linked to the physician work component.
Shortly after the 2003 MFS was released, ASHA discussed the problem with CMS officials. Agency officials confirmed that the loss of physician work accounted for most of the reduction in the total relative value for the procedures. Had the SLP time been considered to represent physician “work” as opposed to practice expense, the service would have been more generously valued. There is little chance, however, that CMS would reconsider the physician work issue because SLPs are not currently considered physicians under the Medicare law and do not have the ability to bill the program directly for their services, unlike PTs and OTs.
Grassroots Help Needed
ASHA is considering a variety of short- and long-term solutions to ameliorate this problem. In the short term, two avenues are being explored. First, HCEC is exploring all billing options that SLPs might use to ease the impact. One option would be to determine whether a combination of codes might be billed during the same visit or on the same day based on revisions of Medicare rules that currently prohibit the clinical evaluation, the modified barium swallow, and treatment being performed on the same day. Second, ASHA has identified a potential technical problem with CMs’ calculation of the 2003 fee schedule for the dysphagia codes. CMS has agreed to re-examine their calculation.
One long-term remedy is federal legislation to secure the ability of SLPs to bill Medicare directly for their services. A federal law could improve the position of SLPs related to private practice billing. Achieving such federal legislation is among the highest priorities on the ASHA 2003 Public Policy Agenda.
SLPs should support ASHA’s efforts to have this legislation passed. Please monitor the ASHA Web site and watch for Action Alerts for information on how to support the legislation when it is introduced. The need for new CPT codes was obvious, as the data reflected considerable work by the SLP, but the Medicare formula did not capture the needed elements to equitably pay for the service.
For more information about the MFS, contact Mark Kander at or Ingrida Lusis at
Specialty Recognition in Swallowing and Swallowing Disorders

Last month, the Inaugural Specialty Board in Swallowing and Swallowing Disorders met for the first time, with the goal of completing an operational manual establishing the board’s policies and procedures. The board also worked to refine and clarify the process for granting the designation of Board-Recognized Specialist in Swallowing and Swallowing Disorders (BRS-S).

The Specialty Board includes 12 members of Special Interest Division 13, Swallowing and Swallowing Disorders, and one consumer member: Bonnie Martin-Harris, chair; Maureen Lefton-Greif, vice-chair; Joan Arvedson; Caryn Easterling; Susan Langmore; Jeri Logemann; Linda McKay; Adrienne Perlman; Jo Puntil-Sheltman; JoAnne Robbins; Justine Joan Sheppard; Barbara Sonies; and Marty Mash.

The Specialty Board anticipates accepting applications for charter members by May. Charter members will be speech-language pathologists who already meet the specific criteria previously defined for the members of the Inaugural Specialty Board. Charter members will help construct and refine examinations for future applicants and renewal examinations, and will work closely with the Inaugural Board and its examination committee. BRS-S will be granted to charter members upon completion of their tasks.

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March 2003
Volume 8, Issue 5