Representatives from ASHA and the American Academy of Otolaryngology – Head and Neck Surgery (AAO-HNS) met with officials of the Centers for Medicare & Medicaid Services (CMS) in late March to discuss the 2011 requirement for personal (i.e., in the room) physician supervision of videostroboscopy and nasopharyngoscopy procedures performed by speech-language pathologists. Both organizations strongly urged CMS to change the supervision requirement to direct supervision – that is, the physician must be "immediately available" but not necessarily in the room while the procedure is being performed.
At the meeting, CMS officials noted their concerns, including a lack of a formalized certification process to ensure that speech-language pathologists are properly trained to perform invasive endoscopic procedures. ASHA emphasized that speech-language pathologists have performed these procedures successfully since the mid-1980s without any evidence of a negative outcome. Moreover, speech-language pathologists are bound by the ASHA Code of Ethics to have education, training, and experience consistent with the Knowledge and Skills for Speech-Language Pathologists With Respect to Vocal Tract Visualization and Imaging.
The collaborative position of the speech-language pathology and otolaryngology professions makes us hopeful that the recommendation for modification of the supervision requirement will receive a favorable response from CMS. Unfortunately, it will be at least three months before a decision is made. Therefore, speech-language pathologists must abide by the personal supervision requirement until a new Medicare supervision level is announced. As for ASHA member advocacy, we advise that speech-language pathologists be patient until a CMS decision is rendered. If the decision is unfavorable, ASHA will appeal to CMS leadership. ASHA will keep members informed of any developments knowing how important this issue is to SLPs who perform videostroboscopy and nasopharyngoscopy procedures.
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