A Medicare administrative contractor (MAC) for seven states has imposed a more stringent level of supervision than that required by Medicare for speech-language pathologists performing videostroboscopy or nasopharyngoscopy.
Last fall, the Centers for Medicare and Medicaid Services (CMS) removed any national Medicare requirement for physician supervision of qualified SLPs performing video-stroboscopy (CPT 31579; Current Procedural Terminology, ©American Medical Association) or CPT 92511, nasopharyngoscopy. As with a number of Medicare requirements, however, local MACs are permitted to specify a more stringent level of supervision.
In mid-December 2011, Palmetto—the MAC for California, Hawaii, Nevada, North Carolina, South Carolina, Virginia, and West Virginia—posted the following requirement:
Speech-language pathologists (SLPs) are trained in basic laryngeal examination related to speech and dysfunctional swallowing conditions. Since an SLP does not have the experience or knowledge to biopsy a neoplasm or an anatomical pathologic condition, Palmetto PGA will reimburse a videostroboscopy and nasopharyngoscopy service when an SLP performs the service under the direct supervision of a physician credentialed by the hospital to perform the services.
Note that when the provider setting is a hospital, "immediately available" means in an office close to the hospital or satellite department of a hospital.
In addition, "physician" may include a nurse practitioner or physician assistant if allowed under state law.
ASHA has contested Palmetto's requirement and has raised the following issues:
- Palmetto's rationale for requiring direct supervision appears to be that SLPs lack the experience or knowledge to biopsy. However, SLPs perform a videostroboscopy or nasopharyngoscopy to determine a functional, not medical, diagnosis. CMS confirmed this SLP role in a July 18, 2011, letter. An SLP's inability to biopsy does not detract from the SLP's qualifications to perform the procedures.
- The requirement that the supervising physician be credentialed by "the" hospital might be interpreted to mean that the procedure is approved for hospital settings only. ASHA has requested that Palmetto clarify that the procedures are covered in office settings as well. In the latest available Medicare Part B data, 86% of videostroboscopies occur in an office setting.
For more information, see The ASHA Leader, Aug. 2, 2011 or visit ASHA's Medicare reimbursement webpage.