American Speech-Language-Hearing Association
December 30, 2010

CMS Requires Physician In-The-Room Supervision: Videostroboscopy & Nasopharyngoscopy

See also: Update on Compliance Requirements for Medicare In-the-Room Physician Supervision (1/21/2011)

The Centers for Medicare and Medicaid Services (CMS) has determined that, effective January 1, 2011, a physician must be in the room when a speech-language pathologist performs a videostroboscopy or nasopharyngoscopy procedure (CPT 31579 or 92511). The decision was made as the result of a practitioner's inquiry to a CMS regional office regarding Medicare supervisory requirements. ASHA is discussing the revision with other professional organizations and will take action to reverse this policy to the previous level of supervision, that is, that the physician be immediately available in the office suite.

The new requirement should be accessible on the CMS 2011 fee schedule "look-up" site very soon:

Once the 2011 fee schedule "look-up" is posted on the CMS Web site, the supervision levels may be accessed. To locate the supervision levels at this link, insert CPT code 31579 and/or 92511 and select "all modifiers". Then, select MEDICAL POLICY. In the next screen, at the bottom, see PHYS SUPV (physician supervision). The digit "3" represents personal supervision which means that the physician must be in the room.

Some Medicare Administrative Contractors (MACs) have included the supervision level in their online 2011 fee schedule information even though the fees do not yet reflect the latest legislative update:

An example of the Supervision level display is on the MAC Trailblazer Web site:

  • Select Year (2011), State (any), Locality (any)
  • Insert procedure code (31579 or 92511), Modifier (none)
  • Select "Search"
  • 31579 or 92511 fee information appears
  • Scroll down to "Indicators"
  • See "Physician Supervision of Diagnostic Procedures"
  • Select the question mark adjacent to "03" for a description of the 03 level of supervision

Readers should be aware that there has been a delay in CMS releasing the 2011 Medicare Physician Fee Schedule (MPFS) because section 101 of the Medicare and Medicaid Extenders Act of 2010 prevented a payment cut for physicians that would have taken effect on January 1, 2011. While the physician fee schedule update will be zero percent, other changes to the relative value units (RVUs) used to calculate the fee schedule rates must be budget neutral. To make those changes budget neutral, the conversion factor must be adjusted for 2011. CMS is currently developing the 2011 MPFS to implement the zero percent update, and expects all 2011 claims to be processed timely and in compliance with the new legislation.

Contact if you have any questions about the 2011 change in Medicare requirements for videostroboscopy and nasopharyngoscopy supervision.

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