|
The Centers for Medicare & Medicaid Services (CMS) revised Chapter 15 of the Medicare Benefit Policy Manual, sections 220 and 230 that impact the provision of Part B speech-language pathology services. The implementation date is June 9, 2008.
Billing for speech-language pathology services by a private practice occupational therapist or physical therapist: This provision has been deleted because many states do not allow services to be billed by practitioners who have no supervisory responsibility over the practitioner rendering the service. The contractors may interpret billing rules consistent with state and local policies. (230.3.B)
Long Term Treatment Goals: When the episode of care is anticipated to be longer than the certification/recertification period, the long-term goal may be specific to the part of the episode that is being certified. If the episode is short, measurable goals may not be achievable; documentation should state the clinical reasons progress cannot be shown.
(220.1.2.B)
Treatment Duration/Frequency: CMS recognizes that, depending on the individual's needs, it may be most efficient and effective to provide short-term intensive treatment or longer term and less frequent treatment. When a tapered frequency of treatment is planned, the exact number of treatments per week is not required in the plan because changes should be made based on assessment of daily progress. (220.1.2.B)
Plan of Treatment Dates: Notation in the medical record of the beginning date is recommended but not required. This assists the Medicare contractor in determining the dates of service for which the plan was effective. (220.1.2.B)
Certification/Recertification: A physician/NPP may certify or recertify a plan for whatever duration of treatment the physician/NPP determines is appropriate, up to a maximum of 90 calendar days. Treatment beyond the duration certified by the physician/NPP requires that a plan be recertified for the extended duration of treatment. It is not required that the same physician/NPP who participated initially in recommending or planning the patient's care certify and/or recertify the plans. (220.1.2.C)
Physician/NPP Visits: If the physician wishes to restrict the patient's treatment beyond a certain date when the physician has determined that a visit is required, the physician should certify a plan only until the date of the visit. (220.1.2.C)
Delayed Certification: An example is given of a certified plan of care ending March 30th and a new plan of care for continued treatment after March 30th is developed or signed by a speech-language pathologist on April 15th and that plan is subsequently certified; that certification may be considered delayed and acceptable, effective from the first treatment date after March 30th for the frequency and duration as described in the plan. Documentation should continue to indicate that therapy during the delay is medically necessary, as it would for any treatment. (220.1.2.D)
Progress Reports: Clarification is made that the Progress Report Period is at least once every 10 treatment days or at least once during each 30 calendar days, whichever is less. Dates for recertification of plans of care do not affect the dates for required Progress Reports. (220.3.D)
Discharge Summary: In provider settings where the physician/NPP writes a discharge summary and the discharge documentation meets the requirements of the provider setting, a separate discharge note written by a therapist is not required. (220.3.D)
Signature of the Qualified Speech-Language Pathologist: Since a clinician must be identified on the Plan of Care and the Progress Report, the name and professional identification of the supervisor responsible for the treatment is assumed to be the clinician who wrote the plan or report. When the treatment is supervised without active participation by the supervisor, the supervisor is not required to cosign the Treatment Note written by a qualified professional. (220.3.E)
Speech-Language Pathologists as Employees or Contractors of Physician Practices: For outpatient speech-language pathology services that are provided incident to the services of physicians/NPPs, even though the requirement for speech-language pathology licensure does not apply; all other personnel qualifications do apply so that the individual must meet the education and experience required for the CCC-SLP or meet the educational requirements and be in the Clinical Fellowship. (230.3.B)
Aural Rehabilitation Scope of Coverage: The coverage category, “aural rehabilitation,” is replaced by “Impairments of the Auditory System.” Auditory processing coverage includes but is not limited to services for certain neurological impairments or the absence of natural auditory stimulation that results in impaired ability to process sound. (230.3.D.3)
The complete text of CMS Transmittal 88 [PDF] is available on the CMS Web site. For further information, please contact reimbursement@asha.org.
|