On Thursday, January 31, 2019, the Centers for Medicare & Medicaid Services (CMS) officially responded to a letter from ASHA regarding recent revisions to the National Correct Coding Initiative (NCCI) Policy Manual for Medicare Services that incorrectly indicated that the procedure code for cognitive treatment—G0515 (cognitive skills development, each 15 minutes)—may not be reported by speech-language pathologists (SLPs). In response to ASHA’s request to rescind this guidance, CMS confirmed that the revision to the NCCI Policy Manual “was an inadvertent error” and noted it would be corrected in the 2020 edition of the manual.
ASHA is not aware of any Medicare Administrative Contractors (MACs) that have implemented edits based on the incorrect guidance. Therefore, denials for this reason are not expected. However, SLPs may use the official response [PDF] from CMS to address denials, if they occur based on the error.
Key statements from CMS include:
- “…CMS acknowledges that speech language pathologists frequently perform the service described by HCPCS code G0515 and that there was no intention of changing CMS policy about whether speech language pathologists may bill that code.”
- “…Until the 2020 version of the NCCI Manual is published, please feel free to use this letter to explain to other parties who may misinterpret Subsection #2 as a change in CMS policy that there has been no change in CMS policy regarding this matter.
- “…Speech language pathologists may perform the services described by HCPCS code G0515 and may bill the code.”
ASHA appreciates the clarification by CMS that reaffirms the ability of SLPs to appropriately provide and report cognitive treatment services.
The NCCI (or more commonly, CCI) is an automated edit system to control specific procedure code pairs that can be reported on the same day. It was developed by CMS for use in all Medicare Part B (outpatient) and Medicaid claims. The NCCI Policy Manual provides additional guidance in support of the CCI edit system and is updated annually.
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