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Medicare and University or College Clinics

Issues Related to Audiology and Speech-Language Pathology Services

This site contains information on how to appropriately treat patients and comply with federal regulations when providing audiology and speech-language pathology services to Medicare beneficiaries in a university clinic setting.

Table 1: Medicare Billing Requirements for University and College Clinics

Supplier Enrollment Physician Role Claim Submission Student Supervision
Medicare Rule(s) Each SLP who treats beneficiaries must submit application form 855i. See Enrollment Process. Physician must certify Plan of Care within 30 days of first SLP visit. Each certification for up to 90 days. Form CMS-1500 or electronic version. Same form as used by private health plans. See Billing Medicare. 100% by a qualified SLP in the room. See Coverage of Students.
Facilitating Tips

In addition to form 855i:

  • Consider form 460 to "accept assignment"
  • Add form 855B to represent the group practice

See Enrollment Process.

  • Evaluation and treatment can initiate without physician order or referral
  • "Physician" includes nurse practitioner or physician assistant
  • Electronic submission required if clinic employs >10 FTE
  • Evaluation and treatment allowed on same day
  • Certain CPT coding rules unique to Medicare
Supervisor cannot be engaged in other activities and must direct the services rendered.

Table 2: Options for University Clinics That Do Not Wish to Bill Medicare

Services at no cost to patient Services not "Medically Necessary" Students with less than 100% in-the-room supervision Advance Beneficiary Notice of Noncoverage (ABN)
Rationale Medicare rules do not apply if services for Medicare patients are free.
  • Maintenance care, or
  • Very slow functional progress
Such services are not covered.
  • Informs patient of noncoverage
  • Patient accepts financial responsibility
Caveat State or local laws might require all patient services to be free if one group is free. Patient can request claim submission; requires provider enrollment. Patient can request claim submission; requires provider enrollment. Patient can later request claim submission;requires provider enrollment.

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