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

The various models included practices in which otolaryngologists performed the two procedures themselves, those in which speech-language pathologists conducted them and a supervising otolaryngologist reviewed the results, and hospital-based clinics in which speech-language pathologists performed the procedures independently upon referral from a primary care physician and then reported back to that doctor.

The January ruling, said Dr. Rosen, “put a spotlight on how otolaryngologists and speech-language pathologists take care of patients with voice problems and bill for their services.” Although otolaryngologists’ opinions on the necessary level of supervision vary, many of them, including Dr. Rosen, are not comfortable with speech-language pathologists performing the two procedures without any supervision from otolaryngologists, Dr. Rosen said.

“If the speech-language pathologist sends a copy of the video to the pediatrician, the primary care physicians, the allergist, the pulmonologist, they don’t know what they’re looking at,” Dr. Rosen added. Before the January move to in-room supervision, he said “it was not uncommon in the United States for there to be no otolaryngology involvement, and the speech-language pathologist was the only person truly viewing that examination.”

In its June 16 letter to Sen. Collins, CMS reversed its decision after a review prompted by widespread objection to the January rule change. In the letter, Dr. Berwick stated that CMS will remove the supervision level effective Oct. 1. “We recognized that, while physicians perform these diagnostic procedures, speech pathologists also perform these procedures to evaluate and treat a patient’s functional/use problems,” he explained.

Initiating a Dialogue

The letter restores Medicare’s previous supervision requirement of no nationally assigned supervision level. “Thus, a properly trained [speech-language pathologist] performing videostroboscopy or nasopharyngoscopy will not need to have a physician on the premises or exercising supervision,” explained a July 13 ASHA press release. Individual Medicare administrative contractors may establish local supervision requirements for these procedures in their speech-language pathology local coverage determinations, ASHA added.

“We are pleased, but we want to assure our otolaryngology colleagues that they’re still in the picture, too,” ASHA’s Dr. White said. He pointed out ASHA’s preferred practice patterns, which state: “All patients/clients with voice disorders are examined by a physician, preferably in a discipline appropriate to the presenting complaint. The physician’s examination may occur before or after the voice evaluation by the speech-language pathologist.” Speech-language pathologists “are not doing any medical diagnostic work with these procedures,” Dr. White said. “It’s all functional in nature.”