April 14, 2022
Speech-language pathologists (SLPs) have raised concerns about the correct way to code and bill for dysphagia evaluation and treatment services for a Medicare contractor, National Government Services (NGS), because of incomplete guidance outlined in its local coverage determination (LCD)―Speech-Language Pathology (LCD #33580)―and associated billing and coding article, Billing and Coding: Speech-Language Pathology (article #A52866). NGS is the Medicare contractor responsible for processing claims in 10 states―Connecticut, Illinois, Maine, Massachusetts, Minnesota, New Hampshire, New York, Rhode Island, Vermont, and Wisconsin.
The NGS LCD describes coverage for speech and language related services and does not provide any guidance related to evaluation and treatment of dysphagia. However, in its listing of ICD-10-CM codes that support medical necessity, the associated coding and billing article notes that ICD-10-CM codes for a dysphagia diagnosis―R13.0, R13.10, R13.11, R13.12, R13.13, R13.14, and R13.19―are only covered for Current Procedural Terminology (CPT®) codes associated with speech and language services, specifically 92507 and 92521-92524. As a result, SLPs treating Medicare beneficiaries in these states questioned whether dysphagia services were covered and, if so, how they should be billed. However, in investigating these concerns, ASHA found no pattern of NGS denials for services reported with the correct CPT and diagnosis codes associated with dysphagia.
To resolve the confusion caused by the LCD and coding article, ASHA requested a reconsideration of the LCD to incorporate coding practices that accurately reflect 1) the reason for evaluation or treatment and 2) the type of service being provided. NGS responded by indicating that the LCD was restricted to speech and language related services and had no bearing on billing for dysphagia services. As a result, ASHA recommends that SLPs continue to use the correct swallowing/feeding evaluation and treatment CPT codes to submit claims to NGS for patients with a dysphagia diagnosis. Some examples include:
Please review ASHA’s website for Medicare coding rules and general coding guidance for swallowing and feeding services.
If you have questions regarding the guidance for services billed to NGS or if you receive a denial for dysphagia services, please contact firstname.lastname@example.org.