Otolaryngology Coding Alert

Question: I have a certified audiologist in my office who performs all hearing tests including auditory brainstem response (ABR) and electronystagmography (ENG) tests. Medicare representatives and physicians at various billing courses told me that I must be present in the office to bill for these services. The June 2005 Otolaryngology Coding Alert reader question "Column 'Z' Reveals Supervision Requirements," however, points out that these services require only a level-five Medicare physician supervision. How do I clarify this matter with Medicare?


Alabama Subscriber


Answer: Otolaryngologists and coding experts often make the mistake of confusing incident-to rules with diagnostic testing supervision rules. But "because the diagnostic tests benefit set forth in 1861(s)(3) of the Act is separate and distinct from the incident-to benefit set forth in 1861(s)(2) of the Act, diagnostic tests need not meet the incident-to requirements," states Medicare Part B Reference Manual (from HGSAdministrators www.hgsa.com/professionals/refman/appendix-l-m.html).

When discussing audiologic function tests (92552-92557, 92561-92585, 92587-92588, 92597) and vestibular function tests with recording (92541-92548) supervision requirements, tell the representatives that these are diagnostic tests. Thus, the codes fall under the rules for  physician supervision of diagnostic tests, not the incident-to rules.

Key: Depending on the requirements you meet, report the tests one of two ways:

1. When you follow supervision requirements, you must bill the audiologist's services under her personal identification number (PIN).

2. If you bill the services incident-to (under the otolaryngologist's number), you must meet the incident-to criteria - you or another physician must be present in the office suite (direct supervision).

Make sure to include the ordering physician's unique PIN on the claim, regardless of guidelines.

The Otolaryngology Coding Alert reader question you refer to should have instructed reporting 92557 (Comprehensive audiometry threshold evaluation and speech recognition [92553 and 92556 combined]) with 389.1x (Sensorineural hearing loss), using the audiologist's PIN, not incident-to the otolaryngologist.

Bust this myth: Your otolaryngologist won't lose any payment this way. Medicare does not apply the 85 percent nonphysician practitioner (NPP) reduction to audiologists. To have the carrier assign the benefits to the otolaryngologist, complete an 855R.

Because an audiologist performs your ABRs (92585, Auditory evoked potentials for evoked response audiometry and/or testing of the central nervous system; comprehensive) and ENGs (92541-92546, 92548), you may want to always report audiologic tests using her PIN. Filing claims this way identifies exactly who conducts the test and avoids risking incident-to scrutiny. In short, billing under the audiologist's PIN is the cleanest submission method.