The Centers for Medicare and Medicaid Services (CMS) issued revisions for two Medicare policy manuals on May 28, 2010, effective July 28, 2010. The clarifications and revisions affect the use of audiometric technicians, computer-administered audiometric devices (e.g., Otograms), reevaluations, services rendered as an employee or contractor of a physician, physician assistant or nurse practitioner, and hospital outpatient services. We will be consulting with CMS to obtain further clarification on some of the policy changes which are not completely clear to us. In the interim, the following is our understanding of the sections that discuss audiometric technicians and computer-administered devices.
The two transmittals—CR 6447 Pub. 100-02, Rev. 127 and CR 6447 Pub. 100-04, Rev. 1975—are both entitled Revisions and Re-issuance of Audiology Policies. They state that Medicare contractors shall not pay under the Medicare Physician Fee Schedule (MPFS) for audiological diagnostic tests furnished by technicians under the direct supervision of a physician if the test requires professional skills. However, the transmittals state that there may be subtests, or parts of a battery of tests, that may be appropriately furnished by an "educated and experienced technician using a specific protocol under the direction of a supervising physician." The Medicare contractor will determine what services do not require professional skills. That is, CMS did not identify the specific tests that require professional skills but rather is leaving the decision to local Medicare contractors.
Current Medicare policy sections that address the Otogram have been deleted, giving the carriers or Medicare Administrative Contractors (MACs) discretion to cover such tests using recently established HCPCS Level III codes, usually reserved for procedures under investigation. Although current policy states that the Otogram is for screening purposes and, therefore, not covered, this statement does not appear in the revision. In the revision, CMS indicates that computer-administered tests may or may not be screening tests and that contractors continue to have discretion to cover or deny payment for services represented by Category III CPT codes for computer-administered tests.
In the explanation of Professional Component/Technical Component (PC/TC) divided codes, such as vestibular function tests, CMS states that "a physician may not bill for a PC service furnished by an audiologist." An audiologist employed or in a contractual relationship with a physician or physician group should be an enrolled supplier of Medicare services. Audiologists who render services in office or clinic settings should bill for the PC services (or any covered audiological service) using their own NPI as the rendering provider on the claim. Audiologists may complete a Reassignment of Benefits form (CMS-855R) so that the payment for the service rendered by the audiologist can be directed to the office of the physician or group who pays the audiologist.
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