American Speech-Language-Hearing Association

Medicare Delays Face-To-Face Requirement for Speech-Generating Devices

(September 13, 2013)

The Centers for Medicare & Medicaid Services (CMS) has delayed the enforcement of the face-to-face physician visit requirement for certain Durable Medical Equipment (DME), including speech-generating devices (SGDs). The announcement indicated that full compliance and enforcement of the rule will be expected “…beginning by a date that will be announced in Calendar Year 2014.”

The rule, finalized in the 2013 Medicare Physician Fee Schedule, was originally scheduled for enforcement beginning July 1, 2013, and then was postponed until October 1, 2013, to allow physicians and suppliers to prepare for the new rule. This most recent delay, issued September 9, cites “…concerns that some providers and suppliers may need additional time to establish operational protocols….”

SGDs were on the list of items that require a face-to-face visit with a physician or nonphysician practitioner (NPP; i.e., nurse practitioner, physician assistant, clinical nurse specialist). While speech-language pathologists (SLPs) have no additional responsibilities, they should continue to work with SGD-prescribing physicians/NPPs and inform them of the rule expected in 2014. In the face-to-face office visit, the treating physician/NPP is expected to review the SLP's evaluation and then write an order for the SGD and any associated equipment recommended by the SLP.

Background

The Affordable Care Act requires a face-to-face physician office visit for certain DME. Before submitting the written order for DME to the supplier, the physician/NPP must document in the medical record that the visit for the related condition has taken place within the past 6 months. The Medicare 2013 Final Rule determined the list of DME for which the face-to-face physician office visit is required; the list was developed based on utilization and/or cost of each DME item and includes the four high-cost SGD device codes.

Currently, the physician/NPP only needs to sign the SLP’s evaluation for the SGD before ordering the device. The change in the rule means that (a) the patient will have to schedule a visit with the physician/NPP before the written order can be submitted and (b) DME suppliers must establish an internal process that ensures they receive appropriate documentation of the visit. When the revised rule was proposed, ASHA submitted comments opposing the inclusion of SGDs, citing patient hardship and lack of evidence that physicians/NPPs were issuing inappropriate orders for SGDs. CMS determined that the cost of the SGDs justified their inclusion on the final DME list.

Resources

CMS Website: Face-to-Face Encounter Requirement for Certain Durable Medical Equipment
The ASHA Leader:Bottom Line: Medicare Requires Physician Visit for Speech-Generating Devices

For updates or more information, follow ASHA Headlines or contact a member of the ASHA’s health care economics and advocacy team at reimbursement@asha.org.


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