Otolaryngology Coding Alert

You can achieve NPI reportability using these insider tips

If you think that meeting Medicare's October implementation date to directly report audiologists- services is a pipe dream, these facts will help make complying with the NPI mandate obtainable.

On Feb. 29, CMS issued Transmittal 84, which will restrict payment for audiological diagnostic services to qualified audiologists- coding services under the AuD's National Provider Identifier (NPI), effective May 23. "We have been hearing rumors that this was going to happen, but it was kind of abrupt," says Julie Keene, CPC, at University ENT Specialists Inc. in Cincinnati.

The American Academy of Otolaryngology--Head and Neck Surgery/Foundation (AAO-HNS) worked with CMS to give practices more wiggle room. "We communicated to CMS a need for clarification and a reasonable length of time to comply with the policy," said David R. Nielsen, MD, AAO-HNS executive vice president and CEO in an e-mail blast. CMS will delay the transmittals- implementation until Oct. 1 "to allow practices time to obtain an NPI for their audiologists and complete the Medicare enrollment process."

To avoid your practice's audiology services income taking a nosedive this fall, get started now with these points.

Report Audiologist-Performed Beneficiary Testing Directly

Audiological diagnostic services have their own benefit category from CMS. Audiologists can provide these services without direct supervision and should report them under their own identifier number.

CMS now puts an exclamation point on this reporting mandate. Starting Oct. 1, "Contractors shall not pay for audiological services incident-to the service of a physician or nonphysician practitioner," according to number three of the transmittal's business requirements issued to Medicare Part A and B Medicare Administrative Contractors (MACs) and carriers.

Direct audiology reporting is not new policy, says Debbie Abel, AuD, director of reimbursement for the American Academy of Audiology (AAA) in Reston, Va. CMS is clarifying "what was supposed to have been transpiring all along per the Social Security Act 1861 [42 U.S.C. 1395x], which has been in effect for nearly five years."

Use Audiologist's NPI to Get 100% Pay

You can spot codes that fall under this policy using the Medicare Physician Fee Schedule. Medicare pays for audiological diagnostic tests under the benefit for "other diagnostic tests." CMS assigns this category level 5 in the physician supervision of diagnostic procedures column, "AF" in the 2008 Excel file. A designation of "5" indicates "Physician supervision policy does not apply when procedure is furnished by a qualified audiologist; otherwise must be performed under the general supervision of a physician."

This category includes tests of the auditory and vestibular systems, tinnitus, auditory processing, and osseointegrated devices. Applicable codes include:

- vestibular function tests

92541-92548

- audiologic function tests

92552-92557, 92561-92585, 92587-92588, 92596

- auditory processing, tinnitus

92620-92627, 92640

- cochlear implant (re)programming

92601-92604.

Payment: Direct audiologist reporting does not cause the payment reduction that you typically associate with nonphysician practitioner (NPP) direct billing. "Physicians will receive the same reimbursement for audiologic services as they did before," Abel says. Both specialties use the same Medicare Physician Fee Schedule.

Meet Updated Audiologist Requirement

An AuD will no longer be a clincher as a qualified audiologist. The individual must hold a master's or doctoral degree in audiology. "Therefore, a Doctor of Audiology (AuD) 4th-year student with a provisional license from a State does not qualify unless he or she also holds a master's or doctoral degree in audiology," according to an addition to Medicare's Qualified Audiologist Definition.

Clinch These Requesting Requirements

You-ll still need to have your ENT request the audiological testing to secure payment. Your physician will have to order "an other diagnostic" test for CMS to cover it. Alternatively, an NPP may order the evaluation, where allowed by state and local law.

If the ENT or NPP designates tests using the CPT descriptor, the audiologist can provide only that test. Your physician can also order diagnostic audiological tests without naming specific tests. In these cases, the audiologist may select the appropriate test battery.

When your otolaryngologist orders diagnostic tests, and based on those tests the audiologist wants to run additional tests, the ENT must order the additional tests, says Charles F. Koopmann Jr., MD, MHSA, professor and associate chair at the University of Michigan's department of otolaryngology in Ann Arbor. "He has to be kept in the loop to determine medical necessity."

Action: Inform ordering staff that auditors will expect to see documentation that includes the following items:

Enter NPI in Box 26J

The updated CMS-1500 form lets you file dual ENT-audiologist claims. You itemize each procedure and indicate the associated provider's NPI in box 26J (Rendering Provider ID Number). Benefits for both the otolaryngologist's E/M and audiologist's services are routed to your ENT group.

Example: An otolaryngologist performs a consultation on a Medicare patient who complains of dizziness. After the exam, the physician orders a random saccade test from his employed audiologist.

The audiologist finds that the patient has Meniere's disease (for instance, 386.03, Active Meniere's disease, vestibular) with bilateral sensory hearing loss (389.11).

You report 99243 (Office consultation for a new or established patient -) for the ENT's service and 92545 (Oscillating tracking test, with recording) for the audiologist's diagnostic test by entering the E/M on line 1 and the test on line 2 as follows: