Speech-language pathologists may bill for cognitive skills treatment and treatment for swallowing disorders provided to the same Medicare patient on the same day, according to a clarification from the Centers for Medicare and Medicaid Services (CMS).
In a letter, ASHA had requested that CMS reconsider language in the National Correct Coding Initiative (NCCI) Policy Manual regarding treatment of dysphagia and cognitive disorders provided and billed to the same patient on the same day. The policy manual outlines which procedures may not be billed together for the same patient.
The procedures delineated in ASHA's letter included the following CPT (Current Procedural Terminology, © American Medical Association) codes:
- 97532: Development of cognitive skills to improve attention, memory, problem solving (includes compensatory training), direct (one-on-one) patient contact by the provider, each 15 minutes.
- 92526: Treatment of swallowing dysfunction and/or oral function for feeding.
CMS responded to the letter, stating "...if an SLP separately performs the services described by CPT code 97532 entirely unrelated to the services described by CPT code 92526, the services may be reported separately." For these cases, the modifier -59 would be added to CPT code 97532.
This interpretation represents a shift from previous explanations that indicated 97532 could not be billed in combination with swallowing treatment codes on the same day. The letter from CMS maintains that the codes may be billed together only for patients who have two distinct plans of care for dysphagia and cognitive impairments, indicating it would be most efficient to treat both disorders on the same day.
Providers should bill CPT 97532 only when cognitive treatment is truly a distinct, separate activity. SLPs should not bill cognitive treatment when they provide only swallowing or language treatment to a patient who also has cognitive disorders. However, it may be appropriate to bill 97532 on the same day if there are distinct plans of care and specific goals and treatment activities for cognitive impairment and for swallowing.
For example, working on swallowing with a patient with mild dementia would not warrant use of 97532 in addition to 92526. In contrast, working on separate dysphagia and attention goals for a patient with TBI could be billed as 97532 and 92526. Clear documentation of distinctive treatment is necessary when a single provider includes 97532 with other speech-language treatment codes on the same day to the same patient.
For more information on NCCI edits, go to ASHA's reimbursement webpage.