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ASHA has advised the Medicare fiscal intermediary for Connecticut to start over in its attempt to write a coverage policy for reasonable and necessary audiometry services. First Coast Service Options, Inc. drafted a Medicare local coverage determination (LCD) for audiometry services so fraught with errors and inconsistencies that ASHA recommended a complete revision over and above the specific comments it submitted on March 24, 2006.
The most conspicuous error in the draft LCD called for a reversal of coverage for an audiologist's services if a physician's documentation in the patient record did not show that the service was medically necessary. ASHA pointed out that an audiologist has no control over the referring physician's practice to ensure that the medical record note is complete. The draft LCD also stated that medical necessity for testing beyond determination of three types of hearing loss (conductive, sensorineural, or mixed) is based on the results of basic audiometric tests. ASHA argued that the medical necessity of all tests should be on the basis of presenting symptoms/complaints, history, preliminary findings, and/or the physician's physical examination of the patient.
First Coast also stated that an audiogram would be considered reasonable and necessary "only after the physician has examined the beneficiary and determined that the signs and symptoms are not due to a more serious disorder a (e.g., sepsis, metaboloic abnormalities, CVA, etc)." ASHA countered that the statement erroneously implies that the audiometric services are a last resort. This requirement would inappropriately impede the diagnostic process by causing some physicians to delay audiometric testing.
In a conference call with the First Coast medical director, ASHA representatives discussed the issues concerning the draft LCD. ASHA's written comments recommended that the audiology community be involved with the development of a new draft. ASHA referenced an acceptable CIGNA audiology Medicare LCD as a model for appropriate and accurate representation of Medicare coverage rules. For further information, please contact Mark Kander, ASHA's Director of Healthcare Regulatory Analysis, via e-mail at mkander@asha.org or by phone at 800-498-2071, ext. 4139.
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