Reader Question:
Diagnostic Supervision Rules Exempt Audiologists
Published on Tue Oct 14, 2003
Question: An audiologist performed scheduled electronystagmographies (ENGs) (92541-92542) on Medicare patients while our otolaryngologist was out of town. How should I report the services? What if an audiology technician provides the services?
California Subscriber Answer: If your audiologist meets states licensure requirements, you should report the ENGs (such as 92541, Spontaneous nystagmus test, including gaze and fixation nystagmus, with recording) appended with modifier -TC (Technical component) to indicate that you are reporting the audiologist's service only. Medicare exempts qualified audiologists from the physician-supervision requirements. So when a qualified audiologist provides audiologic diagnostic testing, you don't have to worry about the otolaryngologist's location, as long as your state doesn't have unusual scope-of-practice laws. To report the global code (92541 or 92542, Positional nystagmus test, minimum of four positions, with recording), your otolaryngologist must issue a report of his findings. Because he is out of town, he is presumably not interpreting (Modifier -26, Professional component) the tests.
On the other hand, if an otologic technician performs the tests while your otolaryngologist is out of town, you should not code the services. When a nonqualified audiologist performs the testing, general-supervision rules apply.
That means Medicare requires the physician to provide overall direction and control but does not require the physician to be in the office suite. Most coding experts interpret this to mean that the otolaryngologist must be "in town" and available by phone to address any problems. Reporting them "incident-to" the physician would violate Medicare's supervision rules.