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Otolaryngologists Adopt New FEES Policy

by Janet Brown

Speech-language pathologists were taken by surprise when their colleagues in otolaryngology informed them that the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS) had approved a new position statement in March that rescinded an earlier joint statement on fiberoptic endoscopic evaluation of swallowing (FEES).

The new AAO-HNS statement, "The Roles of the Speech-Language Pathologist and Otolaryngologist in the Interpretation of Fiberoptic Endoscopic Examinations of Swallowing," states that otolaryngologists or other physicians should directly supervise nonphysician professionals.

The document supersedes an earlier joint position statement issued by AAO-HNS and ASHA in 1999 that stated that SLPs "…with expertise in dysphagia and specialized training in FEES are qualified to use this procedure for assessing swallowing function and related functions of structures within the upper aerodigestive tract."

Otolaryngologists’ concerns about SLPs’ ability to perform FEES without direct supervision were not raised until recent changes in coding and fees for the procedure took effect. In 2002, the American Medical Association—based on the input of ASHA, AAO-HNS, and other professional associations—approved Common Procedural Terminology (CPT, ©American Medical Association) codes for endoscopic swallowing assessments, effective in 2003. These codes replaced "G" codes established by Medicare in 2001.

Effective March 1, the Medicare Physician Fee Schedule established the following reimbursement rates for the new endoscopic swallowing codes:

  • 92612 —Flexible fiberoptic endoscopic evaluation of swallowing by cine or video recording (FEES); Fee (without geographic adjustors) = $172.89
  • 92613 —Physician interpretation and report only (of above procedure; not covered by Medicare) = $0.00
  • 92616 —Flexible fiberoptic endoscopic evaluation of swallowing and laryngeal sensory testing by cine or video recording (e.g., FEESST); Fee (without geographic adjustors) = $182.82
  • 92617 —Physician interpretation and report only (of above procedure; not covered by Medicare) = $0.00

In determining these reimbursement rates, the Centers for Medicare and Medicaid Services stated, "The interpretation of this test is an integral part of the testing itself. If a nonphysician professional has the credentials and experience to perform this testing, then that professional should also provide the interpretation of the findings" ( Federal Register , Dec. 31, 2002; p. 80010).

Otolaryngologists now contend that, since only physicians can provide a medical diagnosis, they must supervise every FEES procedure. However, FEES is performed by SLPs to assess swallowing function rather than diagnose medical conditions.

A few SLPs have been directly challenged by otolaryngologists on the local or institutional level since the release of the new AAO-HNS position statement. To help members obtain information on this issue and to provide advocacy, ASHA has posted "Talking Points on SLPs Performing Endoscopy for Swallowing Assessment" online.  In addition, ASHA has conducted a brief survey through the ASHA Web site to gather specific information about the circumstances under which members currently perform and code the FEES procedure.

Janet Brown is ASHA’s director of health care services in speech-language pathology. Contact her by e-mail at jbrown@asha.org .



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