As of October 1, all audiologists who provide services to Medicare patients must use their own National Provider Identifier (NPI) on claims submitted to the Centers for Medicare and Medicaid Services (CMS). No longer can audiologists performing services under the supervision of an otolaryngologist use the otolaryngologist’s NPI for billing their services.
In addition to obtaining their own NPI, all audiologists who see Medicare patients must enroll in Medicare as providers. Audiologists must obtain both NPIs and full certification as Medicare providers before Medicare will consider payment of their claims.
Although October 1 is the actual date in which these changes in audiology billing to Medicare went into effect, physicians and practices that offer audiological services have been urged since April to begin making changes issued in the transmittals by CMS that require multiple changes in the way audiology services to Medicare patients are rendered and billed.
Every other aspect of those transmittals went into effect in April, said Linda Ayers, Senior Director of Strategic Alliances at the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS), speaking during a miniseminar on Medicare Audiology Billing at the recent annual AAO-HNS meeting in Chicago. That is something some people missed. People need to be aware of all of the elements of the transmittals and if they haven’t been doing them yet, they have to do so immediately.
Among the other elements to consider are significant limitations around the use of technicians and the elimination of the use of automated computerized learning testing (otograms). For a full fact sheet on all the modifications to audiology services under Medicare billing, see www.entnet.org/Practice/upload/FAQ-for-web-082908.pdf .
Obtaining an NPI and Enrolling in Medicare
During the miniseminar, Christy Vanderbilt, CPC-Director of Business Operations and Information Systems for Oklahoma Otolaryngology Associates in Oklahoma City, and a representative of the Association of Otolaryngology Administrators (AOA), of which she is a member of the Leadership Council-provided information on how to apply for an NPI and enrollment as Medicare provider. In terms of obtaining an NPI, the process is very simple and straightforward, she said. Providers can simply complete an application on-line at the National Plan and Provider Enumeration System (NPPES) Web site at www.cms.hhs.gov/nationalprovidentstand/03_apply.asp.
More cumbersome, she said, is enrollment as a Medicare provider. In particular, she emphasized sections within two Medicare application forms that audiologists need to pay particular attention to for proper billing-Section 2 of the 855I form, which needs to be completed for each practice location where an audiologist performs services to Medicare patients, and Section 4 of the 855R, which must be completed for each practice or employer with which the audiologist contracts. This latter section is particularly important to correctly identify where Medicare should send payment for services.
Unlike obtaining an NPI, which could take only a few days, obtaining a Medicare number can take up to several months, said Ms. Vanderbilt. Even if an audiologist has an NPI, they may not have a Medicare number for months, and both are absolutely essential to receive payment.
This means that audiologists who have not yet received a Medicare number should hold their claims for filing their services until that number is assigned to them.
There is no doubt that holding the submission of claims will have a negative impact on the physicians’ cash flow, she said. However, CMS will backdate the effective date of the number so that those services can be billed retroactively.
Other Modifications to Audiology Billing
One of the issues discussed during the seminar was the modification that limits the use of technicians to perform audiology services. Under the new regulation, otolaryngologists must actively participate during any audiology test given by a technician to a Medicare patient for reimbursement of services by CMS. This generally means that an otolaryngologist must be in the same room as the technician while the exam is taking place.
According to James Denneny III, MD, an otolaryngologist in private practice in Knoxville, TN, and the immediate past president of the AAO-HNS, who moderated the miniseminar, this modification in the use of technicians has many people worried.
This has the potential to significantly restrict access in smaller towns because of the shortage of audiologists, he said.
Linda Ayers, echoing the sentiments of Dr. Denneny and all the presenters during the miniseminar, emphasized that access is the fundamental issue that has otolaryngologists concerned.
If physicians who use technicians are required to be actively involved in participation of service, meaning that they are in the room with the technician, they can’t be seeing other patients-and a physician has only so many hours in a day, she said. So particularly in rural areas where they [otolaryngologists] cannot hire an audiologist and they rely on technicians, this is going to be a major access issue.
According to Dr. Denneny, CMS is allowing Medicare Part B contractors, with whom some practices may contract, to interpret this and other modifications proposed in the transmittal. It is important therefore that physicians and practices contact their Medicare contractors to see how the contractors will interpret some of these modifications. Dr. Denneny said that the academy is attempting to contact each contractor on this issue as well.
Given the concern over the restriction on the use of technicians, along with other modifications posed in the new regulations, panel members at the miniseminar urged participants to get involved in urging needed changes to the regulations. One suggestion was for members to use the advocacy system on the AAO-HNS Web site to contact their congressional representatives. This can be found at www.entnet.org/Practice/members/Advocacy.cfm.
Despite repeated attempts at trying to get CMS to rescind-or at least delay-the implementation of the transmittals, no response has yet been given by CMS. However, Dr. Denneny still thinks there is a chance that we’ll get an audience after the election.
In the meantime, the panel urged members to understand and implement the new regulations immediately.
If practices fail to follow the transmittals and are audited, they could lose payment received and perhaps be fined, said Linda Ayers. CMS and Medicare contractors are acutely aware that audiological services are typically performed by audiologists or technicians, and regular billing of audiological services by a physician would be a red flag for an audit.
It would definitely be considered fraud because you are billing under the name of a provider who did not provide the service, she added.
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