Otolaryngology Coding Alert

Reader Questions:

Meet 2 Qualified Audiologist Requirements

Question: We have a licensed audiologist in our office, and I have applied for her NPI and will now apply for a PIN. In addition, we have a temporary audiologist who fills in for us who is no longer licensed but who has her master's degree in audiology. For CMS to pay us for hearing tests, will I have to obtain an NPI and a PIN for her?

Alabama Subscriber

Answer: For your filling-in audiologist to report diagnostic tests using her own national provider identification (NPI), she will have to obtain her license. While CMS Transmittal 84 revised the definition of a qualified audiologist to an individual who has obtained her master's or doctoral degree in audiology (invalidating a 4th year audiology student), the individual must also hold a license in states that offer licensing, such as Alabama.

If the temporary audiologist obtains her license and you obtain her NPI and personal identification number (PIN, for Medicare enrollment) and have benefits assigned to your ENT group (using the 855R), you would report audiological diagnostic tests (such as 92552-92557, 92561-92585, 92587-92588 or 92596) she performs directly under her NPI and direct supervision would not be required. Medicare will pay covered services that a qualified audiologist performs and bills directly at 100 percent of the fee schedule.

Until the audiologist obtains her state license, Medicare will not consider her a qualified audiologist. Starting Oct. 1, you will have to consider her a technician and bill her services incident-to the supervising otolaryngologist, provided her services meet technician requirements. To cover technician-performed audiological testing, the encounter must meet these criteria:

- The ENT will have to order the test using the specific CPT code, provide direct supervision, document his clinical decision-making and active role in the testing and provide the interpretation.

- The technician will have to sign her name and title on all performed tests and can provide only tests that your carrier considers to not require an audiologist's skill. These will probably be the technical portion of vestibular tests (92541-92548), which you would bill globally using the ENT's NPI.