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Medicare and Speech-Language Pathologists in Private Practice

Questions and Answers from Web/Telephone Seminar on Medicare Billing

The following questions were submitted by e-mail during the web/telephone seminar on Medicare Billing for SLPs in Private Practice and are not included in the replay because of the seminar time restriction.

See also: Medicare & SLPs in Private Practice FAQs

Does this change in supplier status apply to billing for Medicaid recipients?

Medicare enrollment does not allow one to serve Medicaid patients; you must enroll directly into your state's Medicaid program.

If the company has two SLP owners, do both fill out the CMS-855B enrollment form?

Section 5 of the form 855B must identify all individuals or organizations that have five percent or more ownership interest.

How do we handle the application process when the private practice crosses over two states, with several employees? Does the main office site qualify as the primary site or business entity on form 855B, and then each business employee completes the 855i?

If the office locations are not in the jurisdiction of the same Medicare Administrative Contractor (MAC) or carrier, you will have to complete another form 855B for the second MAC or carrier. Each employee or contractor would also have to complete another form 855i if they are also rendering services in the second location.

What forms do you use to submit claims to Medicare?

The standard CMS-1500 claim form is used. This is the same form as accepted by most private health plans. Instructions for the proper completion of the form is available on ASHA's Medicare & SLPs in Private Practice site.

If we have an established private practice, what else do we need to do to prepare for Medicare billing besides the forms mentioned?

The Medicare section on ASHA's Billing & Reimbursement site includes information on documentation, coding, and billing. We recommend you review your Medicare Administrative Contractor or carrier's Web site and look for local coverage determinations (LCDs) for speech-language pathology and dysphagia services. They are found in a stand-alone LCD section or under medical policy or medical review.

Does ASHA have a list, by region, of the Medicare Administrative Contractors (MACs) and carriers?

ASHA's site on Medicare & SLPs in Private Practice includes a link to the Medicare directory of MACs, carriers, and intermediaries [Zip]. For your state, locate "Part B" to find your MAC or carrier's Web site. Note that "Part B IVR" is the phone number for interactive voice response while "Part B CSR" connects you to a customer service representative.

Do we know yet if we will be able to see patients in their home setting or do they have to come to an office?

We will not know the answer for certain until the Centers for Medicare and Medicaid Services (CMS) publish the proposed regulations in early November 2008. Based on current physical therapy and occupational therapy in private practice regulations, we expect to see that home visits will be covered. Remember, if they are, there will be no additional payment for your transportation costs. Payment will be based on the procedure(s) performed. ASHA has also recommended that CMS add a third patient care setting, and that is the patient's natural environment when there is a necessity to treat patients where they participate in daily communication activities.

What are the Medicare qualifications for an office location?

We expect to see that the physical requirements for an office will be based on state regulations.

What is certification of the plan of care (POC) by physician?

Medicare requires the patient's physician (or nurse practitioner or physician assistant) to approve the speech-language pathology POC at least every 90 days, unless the POC duration is less than 90 days. The signed POC can be faxed but it must be included in the medical record. For initial certification, the clock starts running when the evaluation is completed.

Will a certification of plan of care be necessary for Part B providers, or is this a Part A requirement?

Physician certification of the plan of care is a Part B requirement. An overall plan of care is required for Part A acute care inpatients, but not specific to therapy.

If my company is only doing FEES, is there a need to complete a certification form (CMS-700) and/or medical necessity form? Do we just need a physician order?

The Medicare Administrative Contractor (MAC) or carrier cannot require that the CMS-700 form [PDF] be submitted, but it can require specified patient identification and clinical evaluation information similar to what is on the 700 form. A physician order is required for dysphagia instrumental assessments.

When will the reimbursement rates be available for 2009?

The Medicare Physician Fee Schedule was published by the Centers for Medicare and Medicaid services on October 30, 2008. The rates for speech-language pathology services will be posted on ASHA's Billing & Reimbursement site in the 2009 Medicare Physician Fee Schedule for Speech-Language Pathologists.

Since Medicare pays 80% of the fee, to whom and how do we bill the 20% copayment?

You must collect the 20% directly from the patient. The patient may have a Medicare supplemental insurance policy that covers that cost. Please remember that you must make a reasonable effort to collect the copayment if it is not paid at the time of service.

Do we need to have specific policies and procedures to comply with Medicare regulations?

Private practitioners/groups do not require specific written policies or procedures, unlike requirements for Medicare rehabilitation agencies and comprehensive outpatient rehabilitation facilities. However, we recommend you check with your state because there may be a requirement to have these documents by the state health department.

Does Medicare allow Clinical Fellows (CFs) to treat and would we be able to bill for their treatments?

Clinical fellows are fully qualified under Medicare, equal to certified speech-language pathologists, if they hold a form of licensure. A problem might occur in states where CFs have no licensure status (Connecticut, Hawaii, Massachusetts, Nevada, New York, North Dakota, Pennsylvania, Tennesse, and Utah).

Can speech-language pathology assistants (SLPAs) treat Medicare patients without a supervisor being in the same room?

Currently, the services of SLPAs are not covered by Medicare regardless of the level of supervision.

Please explain what defines a Medicare Certified Rehabilitation Agency. I currently have an occupational therapist (OT) working for me. Once I get signed up for OT through my corporation, can I begin to bill my speech-language pathology services before July 2009?

A Medicare-certified rehabilitation agency allows billing for SLP/OT/PT services. You may bill for speech-language pathology services before July 2009 if your practice is recognized as a Medicare rehabilitation agency. Medicare recently removed the authority for private practice OTs to bill for speech-language pathology services. For further information on rehabilitation agencies, go ASHA's page on Achieving Medicare-Certified Rehabilitation Agency Status.

Is there a clinical software program that you would recommend for helping document notes to protect from kick-backs?

ASHA has compiled a list of commercial software programs for clinical documentation. Some of the programs have a billing capacity. To request a copy, please e-mail These programs themselves do not minimize kick-backs although the capability of listing all referral sources may assist in reducing kick-back accusations. A kick-back under federal law is the offering or acceptance of any remuneration in order to induce referrals for services covered by Medicare or Medicaid.

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