Speech-language pathologists now have regulations to draw on in preparation for moving to private practice under Medicare, an option available as of July 1, 2009. The Centers for Medicare and Medicaid Services (CMS) is allowing SLPs to submit Medicare enrollment applications on or after June 2, 2009, and released requirements and regulations for doing so Oct. 30 in the 2009 Medicare Physician Fee Schedule.
The new regulations mirror those governing physical therapists' participation in Medicare Part B, but do not allow the use of assistants.
Under Title 42 of the Code of Federal Regulations §410.62, an SLP may provide services as one of the following:
- An unincorporated solo practice, partnership, or group practice, or a professional corporation or other incorporated speech-language pathology practice
- An employee of a physician group
- An employee of a group that is not a professional corporation
Services may be offered in:
- The SLP's private office space, provided that the space is owned, rented, or leased by and used exclusively for the
- The patient's home, not including any institution that is a hospital, a critical access hospital, or a skilled nursing facility. A private office space is not required if the SLP sees patients only in their homes.
Four Steps to Enrollment
1. Obtain an NPI number. You should prepare to enroll in Medicare by first obtaining a National Provider Identifier (NPI), a unique, 10-digit number required under the Health Insurance Portability and Accountability Act (HIPAA) for covered health care providers. It is required for enrollment and on Medicare claims forms. The NPI application process should be completed well before Medicare enrollment. You may complete an application on the CMS Web site or request a form by phone. Instructions are available on the ASHA Web site.
2. Identify a Medicare contractor. You next should determine the Medicare contractor in the area that will process the application. The contractor will be either a Part B carrier or Medicare Administrative Contractor (MAC). CMS is gradually replacing carriers and fiscal intermediaries with MACs (therefore, a carrier may become a MAC). The contractor will also process Medicare claims. Details on determining your contractor are available on the ASHA Web site.
3. Submit enrollment form. Once you have determined the appropriate contractor, the enrollment form may be submitted
on or after June 2, 2009. An individual SLP will complete a CMS-855i form to bill for individual services; a business or group practice would also fill out a CMS-855B form. Processing time for the application depends on the contractor.
4. Use ASHA's resources. ASHA is providing a Web/telephone seminar, "Medicare Enrollment and Compliance for SLPs in Private Practice," which will be broadcast live on Thursday, Feb. 12, 3–5 p.m. EST. "Medicare Billing for SLPs in Private Practice," which aired live Sept. 23, is still available for CEUs through Sept. 23, 2009. More information can be found at the ASHA Online Store (search Medicare).
ASHA's Health Care/Business Institute, April 4–5, 2009, in Bethesda, Md., will include a session on Medicare and private-practice speech-language pathology. ASHA will post additional articles on its Web site as the application and implementation deadlines approach. Information also can be found on the CMS Web site. CMS recently updated its Medicare Physician Guide: A Resource for Residents, Practicing Physicians, and Other Health Care Professionals [PDF], which provides information on enrollment and reimbursement.