An individual who needs a speech-generating device must meet face-to-face with a physician or nonphysician practitioner before receiving the device, according to new Medicare rules that take effect Oct. 1.
Previous regulations required only that the physician ordering an SGD have a written evaluation signed by a certified speech-language pathologist. Medicare delayed enforcement from July 1 to give physicians and suppliers more time to prepare for the rule, which requires the visit to take place no more than six months prior to ordering the device.
The rule affects four Healthcare Common Procedure Coding System (HCPCS) codes:
- E2502: Speech-generating device, digitized speech, using pre-recorded messages, 8–20 minutes.
- E2506: Speech-generating device, digitized speech, using pre-recorded messages, greater than 40 minutes.
- E2508: Speech-generating device, synthesized speech, required message formulation by speech and access by physical contact with the device.
- E2510: Speech-generating device, synthesized speech, permitting multiple methods of message formulation and multiple methods of device access [most commonly used type].
Why did the rule for SGDs change?
The Affordable Care Act directs the Centers for Medicare and Medicaid Services to require a "physician face-to-face encounter" with Medicare beneficiaries no more than six months prior to prescribing any of approximately 150 medical devices or supplies. The requirement is designed to reduce Medicare fraud, waste and abuse.
What funding programs does the new rule affect?
The rule applies only to Medicare. CMS proposed regulations to apply this requirement to all state Medicaid programs, but those regulations have not been finalized.
Do SLPs have a new role or responsibility?
No, SLPs have no additional responsibilities, as the procedural change applies only to treating physicians. However, an SLP can help ensure Medicare reimbursement by making sure the physician and patient know about the need for a face-to-face visit.
In the face-to-face meeting, the treating physician is expected to review the SLP's evaluation and then write a prescription for the SGD and any associated equipment the SLP has recommended.
What will treating physicians need to do?
If an SLP recommends any of the four SGDs affected by the rule, the physician must:
- Have a face-to-face encounter with the client.
- In the encounter, complete one of the following activities: a client evaluation; a needs assessment of the client; or treatment of the client for the medical condition that supports the medical need for the SGD, and which will be included in the physician's prescription.
- Document the encounter in the client's medical records, including the date it occurred.
- If the face-to-face encounter was performed by a physician assistant, nurse practitioner or clinical nurse specialist, document that it occurred.
- Forward the record of the face-to-face encounter and the prescription to the SGD manufacturer or supplier.
Can a physician conduct the face-to-face encounter through telepractice?
Yes, a physician encounter may take place through telepractice if the medical record clearly documents that the patient was evaluated or treated for a condition that supports the need for the SGD, and if the visit complies with state laws. Telepractice services performed by an SLP, however, are not covered by Medicare.
The final regulations are contained in the 2013 physician fee schedule rule [PDF, 12.5MB]. For more information, contact firstname.lastname@example.org.