Medicare covers audiological diagnostic evaluations when performed by an audiologist, but has specific requirements to services performed by students. Requirements for student supervision are limited to Part B services as described in Chapter 15 of the Medicare Benefit Policy Manual, Section 80.3.D [PDF]. The Centers for Medicare & Medicaid Services (CMS) has not issued specific rules regarding supervision of students for Part A services.
In order to enroll in Medicare and provide services to Medicare beneficiaries, audiologists must have a master's or doctoral degree in audiology, be licensed by the state, or meet standards equivalent to the ASHA Certificate of Clinical Competence (CCC-A) in those states without licensure. A Doctor of Audiology (AuD) 4th-year student with a provisional state license does not meet the definition of a qualified audiologist and therefore requires supervision, unless they also hold a master's or doctoral degree in audiology.
According to Medicare rules, when a Medicare beneficiary is being evaluated by a student, they must be 100% supervised by the qualified audiologist. For any services performed by a student, the audiologist must be in the room guiding the student, fully engaged in the evaluation, and not performing any other tasks. The documentation must be signed by the audiologist and the services provided are the full responsibility of the audiologist. For situations where the audiologist is not present or fully engaged, direct physician supervision is necessary. Direct supervision requires the physician to be onsite and immediately available, but does not require presence in the room where the procedure is performed. Services provided with direct physician supervision are billed "incident to" the physician, not the audiologist on staff. This letter from CMS verifies supervision requirements [PDF].
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