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cite as: Kander, M. (2009, June 16). Health Care/Business Institute draws 600. The ASHA Leader, 14(8), 3.
by Mark Kander
With the July 1 change in speech-language pathologists' ability to bill Medicare for services provided, all speech-language pathologists in private practice need to be aware of two critical new reimbursement scenarios.
Scenario 1: You provide services to a patient who is covered under Medicare but who pays out-of-pocket for treatment. After July 1 you may no longer provide services to this patient.
After June 1, 2009, a qualified SLP may apply to enroll as a Medicare supplier. After the application is accepted, the SLP can begin billing for services rendered as of July 1. An SLP who is not a Medicare supplier cannot treat a Medicare beneficiary, even if the patient agrees in writing to pay you directly and not seek payment from Medicare for your services. The basis for this restriction is section 15/40.4 of the Medicare Benefit Policy Manual, which states that SLPs, occupational therapists, or physical therapists may not opt out of Medicare or provide services under private contract to Medicare beneficiaries.
Caveat: You may collect out-of-pocket payment from Medicare beneficiaries who seek services that are not covered by Medicare, such as patients who have exceeded their therapy caps and do not qualify for an exemption or patients seeking help for non-reimbursable services such as voice quality and accent modification.
Scenario 2: You are an employee or contractor of a physician or physician group and you are not enrolled as a Medicare supplier as of July 1. You are subject to restrictions in your care of Medicare beneficiaries.
SLPs who do not enroll as providers remain subject to the "incident to physicians' services" rules:
- A physician must be in the office suite when the SLP renders services
- A group physician must be managing the patient (i.e., services cannot be limited to SLP services only)
- The physician's National Provider Identification (NPI) number (used for Medicare billing) is entered for each procedure code billed If you enroll as a Medicare provider, none of these restrictions apply. You enter your own NPI for each procedure code billed.
For information on how to enroll in Medicare as a private practitioner, go to the ASHA Web site. Direct specific questions to reimbursement@asha.org.
Mark Kander, director of health care regulatory analysis, can be reached at mkander@asha.org.
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