Otolaryngology Coding Alert

Begin by defining what constitutes each component of service.

When reporting audiological function tests, you have numerous coding guidelines to consider. You’ll also want to brief yourself on what policies exist surrounding the billing of respective audiology services, as payer requirements may vary.

Have a look at these sets of Centers for Medicare & Medicaid Services (CMS) policies within Chapter 12, Section 30.3 of the Medicare Claims Processing Manual to stay up to date on all the pertinent audiology billing rules and regulations.

Pinpoint Who Provides TC, PC Components

You should know when and where to divide audiology testing and interpretation into its respective professional and technical components (PC/TC). Contrary to some popular belief, you may bill out the audiology service with modifiers 26 (Professional component) and TC (Technical component) in any instance where an audiologist exclusively furnishes the PC, and either a physician, a nonphysician practitioner (NPP), or incident-to personnel such as an oto technician under the direct supervision of a physician furnish the TC.

Assign -TC for testing only: “The TC of a PC/TC split code may be billed by the audiologist, physician, or NPP who personally furnishes the service,” per the Medicare manual.

“‘Personally furnishing the service’ also includes a physician supervising the incident-to personnel as well as meeting the other guidelines for incident-to, such as direct supervision. The service is part of the patient’s plan of care and the incident-to personnel is an employee or contractor of the practice,” notes Barbara J. Cobuzzi MBA, CPC, COC, CPC-P, CPC-I, CENTC, CPCO, CMCS, of CRN Healthcare Solutions of Tinton Falls, New Jersey.

“There’s not much of an inherent difference when describing the TC and PC components from a radiological perspective or an audiology perspective,” states Lindsay Della Vella, COC, AAPC Approved Instructor, owner of Midnight Medical Coding in the Greater Philadelphia area. “In audiology, the TC component involves the furnishing of the service. The PC component, on the other hand, involves the interpretation of the results of the service through a formal report,” explains Della Vella.

See the Specifics Surrounding Technician Involvement

Things get a little trickier if you find an audiology technician added to the mix. When a technician furnishes the TC, the service is only deemed billable if a physician directly supervises the technician. If an NPP or audiologist supervises the technician, you should yield to the following guideline: “Audiologists and NPPs may not bill for the TC of the service when a technician furnishes the service, even if the technician is supervised by the NPP or audiologist.”

This means that only physicians can bill globally when they supervise a technician-performed TC and perform the PC themselves. CMS further elaborates on the technician’s allowed role involving audiology services: “Technicians shall not interpret audiology services, but may record objective test results of those services they may furnish under direct physician supervision.”

However, if you come across a case where a technician furnishes a service supervised by a physician, you’re not out of the clear yet. In these instances, CMS contractors will “review a technician’s qualifications and the medical record to determine whether, under the unique circumstances of that test, a technician is qualified to furnish the test under the direct supervision of a physician,” (www.cms.gov/regulations-and-guidance/guidance/transmittals/downloads/r132bp.pdf).

Tip: The American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS) Certificate Program for Otolaryngology Personnel (CPOP) certification is good proof of qualification to provide the test under incident-to supervision, according to Cobuzzi.

Remember PC Requires Provider Clinical Judgement

“The PC of a PC/TC split code may be billed by the audiologist, physician, or NPP who personally furnishes the service. (Note this is also true in the facility setting.) A physician or NPP may bill for the PC when the physician or NPP furnish the PC and an (unsupervised) audiologist furnishes and bills for the TC … A physician or NPP may not bill for a PC service furnished by an audiologist,” per the Medicare manual.

For example, If an audiology technician performs the TC of a service that does not require the skills of an audiologist, such as 92540 (Basic vestibular evaluation …), the physician, audiologist, or NPP may provide and document their work related to the PC of the service. This includes interacting with the patient to provide professional skills, being directly involved in decision-making and clinical judgment during the test, and furnishing the interpretation and written report.

Put It All Together

“If an audiologist does the PC and TC, bill global with no modifiers under the audiologist,” Cobuzzi says. “If the oto tech does the TC incident-to a physician and the audiologist does the interpretation, bill the -TC under the doctor and for the PC, bill -26 under the audiologist’s NPI [National Provider Identifier],” she continues.

When an otolaryngologist employs the technician and owns the equipment, you may bill a global service with the appropriate code if the tech furnishes the TC and the physician does the PC. You should give your otolaryngologist credit for the interpretation when they write a report similar to an audiologist’s.

Check with your payer: Remember, these are CMS rules. Non-Medicare Part B payer policies may vary, so be sure to verify with each payer what’s required. Also, check if your state has any regulations that may impact audiologic function testing.

For further study: Find the CMS Internet Only Manual, Publication 100-04, Medicare Claims Processing Manual at www.cms.gov/regulations-and-guidance/guidance/manuals/ internet-only-manuals-ioms-items/cms018912.