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Kander, M. (2001, July 24). Is there a 15-minute billing code in our future? The ASHA Leader, 6(13), 3, 13.
By Mark Kander
Speech-language pathologists are calling ASHA to ask about the likelihood of Medicare and private payers resuming the practice of billing based on 15-minute time units. Since 1999, the Medicare Part B program—and many private payers, which follow Medicare's lead—have required billing strictly on the basis of the Current Procedural Terminology (CPT) code description. The CPT descriptors for the common speech-language pathology and dysphagia codes contain no designation of time. The current code for a speech-language pathology evaluation (92506) or treatment (92507) represents a "typical" evaluation or "typical" treatment session. As a result, a session 20 minutes long is billed at the same value as a 60-minute visit.
Some SLPs have requested that ASHA apply to the American Medical Association, owner of the CPT coding system, to revise the code descriptors by adding the words "each 15 minutes." They believe revenue will increase as a result, citing comparisons to our occupational therapy and physical therapy counterparts—about 90% of their codes billed in 15-minute units.
Will billing in time codes generate additional revenue? Not necessarily. Below are comparisons between per-session billing and billing for timed units for the speech-language pathology treatment code.
Assumption: 2007 SLP/dysphagia codes when converted to 15-minute codes will likely pay, under Medicare, the current average physical medicine rate of $31.50. This is based on the fact that Medicare determines the fee based on standard inputs: salary, square footage overhead, and equipment and supply costs. Equipment has a negligible effect on the fee because the costs are prorated across thousands of visits.
For 2007*, compare the Medicare SLP treatment session ($63.29) to $31.50 unit billing in 15-minute units:
- 20 minute visit: $63.29 for per-session billing, $31.50 ($31.50 X 1) for timed-unit billing
- 30 minute visit: $63.29 for per-session billing, $63.00 ($31.50 X 2) for timed-unit billing
- 45 minute visit: $63.29 for per-session billing, $94.50 ($31.50 X 3) for timed-unit billing
- 1 hour visit: $63.29 for per-session billing, $126.00 ($31.50 X 4) for timed-unit billing
Note that for each 30-minute visit—which are becoming more and more common—the current coding system yields 31% higher revenue than the 15-minute units.
At a 2001 meeting at the National Office, after much discussion and consultation with experts, ASHA's Health Care Economics Committee decided against applying for 15-minute CPT codes. Presenting data to the committee was a staff physician employee (coding expert and physiatrist) from the Centers for Medicare & Medicaid Services (CMS) and the former director of the Medicare physician fee schedule program. The committee has re-examined the topic of 15-minute coding several times since 2001, and decided against it because of the risk associated with timed codes that lies within the structure of the Medicare resource-based relative value scale (RBRVS). ASHA's concern centers around the portion of the code called the "professional component." From a legal standpoint, relative value units currently identified in this component represents physician services, not speech-language pathology services. Thus, if the current untimed code was converted, the relative value units identified as "physician" value, could be partially or totally removed from the code's value. In 2007, the physician portion of the speech-language pathology treatment code represents 45% of the total relative value. The physician portion of the dysphagia treatment code represents 33% of the relative value. Reduction in this professional component could yield a significant decrease in the dollar value assigned of each code.
The committee concluded that it would be best to move forward with 15-minute coding could not be considered until Medicare has designated private provider status for SLPs, for which ASHA is advocating in Congress. When SLPs are independent providers under Medicare, they will occupy the same professional component slot as physicians. Contact your legislators and urge them to support SLP supplier status by going to ASHA's Take Action Web site.
"Until SLPs are recognized as independent providers under Medicare, it appears there is significant risk that the fee schedule amount would be reduced," noted Nancy Swigert, president of Swigert & Associates and a member of the Health Care Economics Committee.
For more information on the 15-minute billing code topic, go to ASHA's Timed and Untimed Codes section or contact reimbursement@asha.org.
Updated September 24, 2007
*Correction: The article originally read "For 2004..." Numbers have been updated to reflect 2007 Medicare rates.
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