ASHA recently submitted comments to the Medicare intermediary for Maryland and the District of Columbia (Highmark Medicare Services), in response to its draft Local Coverage Determination (LCD) on the overage of speech-language pathology services. In its comments, ASHA requested the following revisions:
- Allowance for periodic reevaluations of maintenance programs;
- Coverage of services rendered by an SLP but billed to Medicare carriers by physical and occupational therapists in private practice (subject to a written contract between the SLP and PT/OT);
- List of conditions under which therapy students may participate in rendering covered SLP services;
- Correction of an inaccurate description for modification of voice prosthetics;
- Clarification in the description of CPT code 97532 (Cognitive skills development) as a treatment code rather than evaluation code; and
- Clarification in the description of CPT 97533 (Sensory integrative techniques).
Regarding the first three bullets, ASHA referenced specific sections in the Medicare Benefit Policy Manual and Claims Processing Manual as the basis for revisions to the draft LCD. ASHA also requested the addition of 48 diagnoses codes and code groups (ICD-9) that are causes of communication disorders. Twelve of the 48 codes are dementia related. ASHA substantiated the appropriateness of speech-language pathology treatment of early-stage dementia patients by referencing a 2001 policy statement from the Centers for Medicare and Medicaid Services (CMS), "Medical review of Services for Patients with Dementia," as well as section 3.5.1.1 of the Medicare Program Integrity Manual:
"The appearance of a progressively debilitating disease on a claim or history does not permit automated prepay denials that presume a stage of that disease that negates the effectiveness of treatment."
The final version of the LCD is expected to be issued by Highmark in April or May. For further information, please contact Mark Kander, ASHA's Director of Health Care Regulatory Analysis, by phone at 800-498-2071, ext. 4139, or e-mail at mkander@asha.org.
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