Speech-language pathologists in private practice are celebrating a huge win in Congress after ASHA's advocacy helped push through passage of the Medicare Improvements for Patients and Providers Act (MIPPA), which allows private-practice SLPs to participate in Medicare. Once enrolled as Medicare providers, SLPs will be able to bill Medicare directly for services delivered to beneficiaries under Medicare Part B. The law takes effect July 1, 2009.
Like other rehabilitation service providers, SLPs in private practice will be allowed to bill Medicare Part B when the services are delivered in an office or outpatient clinic. There are two exceptions: home health agencies and skilled nursing facilities. Under the home health prospective payment system, Medicare reimburses the agency (not the provider) for the episode of care; in skilled nursing facilities, the facility is mandated to bill Medicare for all services through consolidated billing. SLPs in private practice may provide services in these settings as contractors but may not bill Medicare directly.
The Centers for Medicare and Medicaid Services (CMS) will spend the next year developing regulations to support the new legislation and modifying its systems to allow SLPs to enroll as Medicare providers. ASHA has met with CMS and will continue to closely monitor the implementation of the legislation. Although SLPs can't begin billing Medicare until the effective date, they can begin preparing to be Medicare providers.
First Step: NPI
The first step in preparing to become providers is to obtain a National Provider Identifier (NPI), which will be required on all Medicare claims forms. The NPI is a unique 10-digit identifier required under the Health Information Portability and Accountability Act for administrative and financial transactions. Providers may apply for their NPI as an individual provider or an organization through the CMS Web site.
The application process is free and takes less than 20 minutes. To complete the application, SLPs must create a user name and password. Required information includes Social Security number, state license number, contact information (address, phone, and e-mail), and taxonomy provider type (i.e., speech, language, and hearing).
If an SLP has a Medicaid provider number, this must be put on the application so it is linked with the SLP's NPI. The completed application is assigned a tracking number for follow-up, but the NPI may be assigned via e-mail as quickly as within five minutes.
Even after receiving their NPI, applicants should keep their user name and password in a safe place for future reference. When the time comes to actually enroll as Medicare providers, SLPs can access their application to change information. For example, if clinicians rent office space for their private practice, their contact information can be easily modified online.
Impact of Provider Status for SLPs
The impact of this legislation may change the face of private practice in the profession, creating a more equal balance between private practitioners who serve children and those who treat older adults covered by Medicare. Currently, SLPs must bill under a physician's provider number or from a rehabilitation agency to be reimbursed by Medicare.
According to ASHA's 2007 SLP Health Care Survey, approximately 19% of the respondents own or co-own a private practice. Of this group, 42% reported delivering services in home health/client's home. Only 26% of the clients served by private practice owners were adults. More information about the "pre-Medicare provider" private practitioner, including hourly and annual salaries and sources of reimbursement, is available in the Private Practice Owners Report (see Resources for Private-Practice SLPs).
ASHA staff receive frequent calls from SLPs about starting a private practice; SLPs typically receive little coursework in business topics during their graduate careers. ASHA's victory in winning the right for SLPs to bill Medicare may prove an additional impetus for SLPs to explore their entrepreneurial side.