New Speech-Language Pathology Rule: Supervision of videostroboscopy and nasopharyngoscopy no longer required

Medicare requirements for physician supervision of speech-language pathologists conducting videostroboscopy (CPT 31579) and nasopharyngoscopy (CPT 92511) will move from the strictest level of oversight back to no national supervision level starting in October.

Beginning on Jan. 1, the Centers for Medicare and Medicaid Services (CMS) for the first time required personal physician supervision of these two procedures when provided to Medicare patients by speech-language pathologists; in other words, until October, an otolaryngologist must be in the room.

The decision was prompted by a speech-language pathologist’s inquiry to a CMS regional office regarding Medicare supervisory requirements. Because the two procedures are primarily diagnostic in nature, the agency ruled that their codes needed supervision levels, according to a June 16 letter from CMS Administrator Donald M. Berwick, MD, to Sen. Susan M. Collins, R-Maine. The agency selected in-room supervision.

In-Office vs. In-Room

But both the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS) and the American Speech-Language-Hearing Association (ASHA) objected to what they view as an onerous requirement. In a March meeting with CMS officials in Baltimore, both organizations urged government officials to change Medicare rules to direct supervision, meaning that a physician must be immediately available in the office suite when a speech-language pathologist performs either of the two procedures.

“We weren’t there to ask for no supervision,” said Charles F. Koopmann, Jr., MD, a professor of otolaryngology at the University of Michigan who participated in the March meeting. “I made that very clear to CMS, and ASHA agreed, that we were there to go from in-the-room supervision to in-the-office supervision and that was all,” added Dr. Koopmann, who is the AAO-HNS representative to the AMA/Specialty Society Relative Value Scale Update Committee.

The organizations argued that it is appropriate for trained speech-language pathologists to perform the procedures under in-office supervision. “We feel you need to be in the office complex but not in the room,” Dr. Koopmann explained.

ASHA made the case that speech-language pathologists perform the procedures safely and that in-the-room supervision is an inefficient use of physicians’ time. “There is not one report of one problem occurring in the years that speech-language pathologists have been doing this,” said Steven White, PhD, ASHA director of health care economics and advocacy.

The CMS decision to impose an in-room supervision rule necessitated a major change in how speech-language pathologists and otolaryngologists perform these procedures in many different medical environments across the country, said Clark A. Rosen, MD, director of the University of Pittsburgh Voice Center and chair of the AAO-HNS Voice Committee.