Audiology Update
March 2008 saw two "victories" for audiology. At the state level, Blue Cross Blue Shield of Michigan (BCBSM) will begin allowing audiologists to receive payment for "medical" audiology services, effective for dates of service on or after June 1, 2008. This is a change in that BCBSM previously only paid these services when billed by a supervising physician. "Medical" audiology translates into all the diagnostic procedures that audiologists routinely perform.
In the March 2008 issue of The Record (a BCBSM publication for providers), it lists the CPT codes that will be payable directly to audiologists. It encompasses the family of 925XX codes for diagnostics used by the vast majority of audiologists. If you are already a participating provider with the BCBSM hearing program, you do not need to do anything further. You may begin billing these codes directly to BCBSM in June. If you are not a provider, visit www.bcbsm.com to enroll, or call BCBSM Provider Enrollment at 1-800-822-2761 for more information.
There are a few caveats in this that audiologists should keep in mind:
Audiologists will be reimbursed for the "medical" audiology codes only if the patient has been referred by a provider who is legally authorized to prescribe the service.
BCBSM will not pay for medical audiology services performed by an assistant to an audiologist.
Medical audiology services are not a covered benefit for Ford, General Motors, and Delphi employees.
On a national level, The Centers for Medicare and Medicare Services (CMS) released an update to audiology coverage policies, effective April 7, 2008. The transmittal clarifies language that has been in place for years, but allows the profession of audiology to be in full compliance with HIPAA, which states that the individual providing the service must be reported on the claim by their NPI number. Medicare policy also states that "audiologists must document their names and professional identities" and that Medicare "shall not pay for audiological services incident to the service of a physician or non-physician practitioner."
For audiologists practicing in an ENT setting, this means that your services can no longer be billed "incident to" a physician’s services. Audiologists’ services are considered diagnostic in nature, and thus Medicare considers it is inappropriate to bill such services "incident to" the physician. When billing Medicare, audiologists must be identified as the provider of the service with their unique National Provider Identification (NPI) number.
In a related item, CMS has also clarified that a 4th year Doctor of Audiology student does not qualify under Medicare’s definition of an audiologist unless they hold a Master’s of Doctoral degree in Audiology. This is true even if the 4th year student hold a provisional license; Michigan does not offer a provisional license for 4th year students (but some states do).
A complete analysis of the CMS policy is available on the member section of the ASHA website. The direct link may be accessed at:
www.asha.org/members/issues/reimbursement/medicare/
To access the policy in the CMS manual, go to www.cms.hhs.gov/transmittals/downloads/R84BP.pdf
Finally, if you have any questions on what this means for you and your practice, feel free to contact me.
Legislative Issues and Audiology
MSHA continues to monitor the status of legislation of interest to audiologists. The bill to mandate universal newborn hearing screening (HB 5482, also introduced in the Senate as SB 987) was introduced by Representative Glenn Steil and has been referred to each chamber’s respective Health Policy Committee in late 2007. As of this writing, no action has been taken by either committee on these bills.
The same is true for HB 5599, introduced by Rep. Michael Sak. This bill would mandate a hearing evaluation prior to a physician referring a patient for an assessment for Alzheimer’s disease or dementia. The bill was referred to the House Health Policy Committee in January 2008, and to date no action has been taken on it by the committee.
REMEMBER--MARK YOUR CALENDARS for MAC on M.A.C. 2008. By popular demand, the event will again be held at the East Lansing Marriott Hotel in downtown East Lansing.
The MAC on M.A.C. Conference is October 23-25, 2008.
We have an agenda of excellent speakers again this year, and those already confirmed include:
Kamran Barin (Vestibular Issues)
Michael Gorga (OAEs)
Leisha Eiten (early Intervention)
Kim Cavitt (Practice Management)
Jennifer Shinn (Auditory Processing)
Lisa Hunter (Middle Ear)
Donald Schum (Hearing Aid Technology)
Have a great summer—see you at MAC in October!
Margot Beckerman, V-P for Audiology
From the February 2008 et cetera:
As our colleagues in SLP continue to work towards licensure, there continue to be legislative issues relevant to audiologists that MSHA is monitoring.
The bill to mandate universal newborn hearing screening (HB 5482, also introduced in the Senate as SB 987) was introduced by Representative Glenn Steil and has been referred to the House Health Policy Committee. While MSHA supports universal newborn hearing screening and recognizes its value in early identification and intervention, the Association has chosen to oppose the bill as it is presently written. The bill is "empty" in its mandate for follow-up when an infant fails the initial screening.
As audiologists, many of us have dealt first hand with infants who have failed repeated screenings before being referred for diagnostic testing. Ultimately, this delays intervention for infants in whom hearing loss is identified. In reviewing the 2007 Joint Committee on Infant Hearing (JCIH) Position Statement, the importance of follow-up is emphasized; a copy of this Position Statement has been provided to the Chair of the House Health Policy Committee, Rep. Kathy Angerer.
There is concern by many audiologists about the unfunded nature of this mandate if it becomes law. Noteworthy is that all Michigan birthing hospitals are presently screening newborns’ hearing without a mandate for such.
The second bill of interest is HB 5599, introduced by Rep. Michael Sak, and also referred to the House Health Policy Committee. For reasons outlined below, MSHA is also opposing this bill. This bill would mandate a hearing evaluation prior to a physician referring a patient for an assessment for Alzheimer’s Disease or dementia Additionally, it states that if hearing loss is diagnosed, the patient cannot be referred for an evaluation for Alzheimer’s or dementia "until the patient’s hearing impairment has been treated."
The language of the bill stipulates that the hearing evaluation be performed by "an individual licensed…to perform the hearing evaluation…" or "by an individual licensed in the practice of selling of fitting a hearing aid…" While the first description seems to refer to an audiologist, the latter is referring to a Hearing Aid Dealer, and the bill specifically states the section of the Occupational Code that licenses Hearing Aid Dealers. By the limitations of scope of practice for Hearing Aid Dealers (performing hearing testing for the purpose of selling/fitting a hearing aid, not for diagnostics), they are not qualified to perform the diagnostic testing that the bill seeks to mandate.
Further, there is no mention of the bill regarding funding of such services. There is concern that Medicare, which does not provide reimbursement for "routine" hearing evaluations, might interpret the mandatory evaluation as such. By mandating that treatment is required prior to an assessment for Alzheimer’s Disease/dementia, there could be a considerable delay in the patient receiving an appropriate diagnosis.
While we knew the newborn Hearing Screening Bill was in the works, the introduction of HB 5599 bill came as somewhat of a surprise. I have talked to colleagues at the Michigan Academy of Audiology, and they have indicated their intention to oppose both of these bills as well. If you would like to read the bills, they can be accessed via the website www.mighiganlegislature.gov.
MARK YOUR CALENDARS for MAC on M.A.C. 2008. By popular demand, the event will again be held at the East Lansing Marriott. Conference dates are October 23-35, 2008. We have an agenda of excellent speakers again this year, and those already confirmed include:
Kamran Barin (Vestibular Issues);Michael Gorga (OAEs); Leisha Eiten (early Intervention); Kim Cavitt (Practice Management); Jennifer Shinn (Auditory Processing); Lisa Hunter (Middle Ear); and Donald Schum (Hearing Aid Technology).
Margot Beckerman, V-P for Audiology
From the December 2007 et cetera
The 2nd Michigan Audiology Coalition ( MAC) Conference, held in October of 2007 at the East Lansing Marriott, was deemed a resounding success! Over 170 audiologists gathered for three days of learning, networking, and meeting with friends old and new. Attendance at the 2007 conference was up over 20% from last year—a statistic that "wowed" us all. As those of you who were there would I’m sure agree, it was gratifying to sit in the ballroom during the Audiology Forum luncheon and see so many colleagues—it is rumored to be the largest gathering of Michigan audiologists in one room in recent history, possibly ever!
Dates have been set for the 2008 MAC Conference. It will be held October 23-25, 2008, back at the East Lansing Marriott by popular demand. Please note that these are different dates than those announced at the conference. After initially choosing a different weekend, it was learned that was also the weekend of Yom Kippur, a major Jewish holiday, thus the decision to change the conference dates to October 23-25. For all you football fanatics, this is the weekend of the U-M vs. MSU football game, but the game is in Ann Arbor. Look for a little intrastate rivalry at the 2008 Conference!
If you would like to be involved with the planning committee or on-site activities (such as assisting at the registration desk, moderating a session, etc.), please let me know. The MAC Conference Planning Committee commits a significant amount of their own time to this project, and as the saying goes, "many hands make light work!" A huge thanks goes out to this group for making 2007 such a great success.
HEARING AID DEALER LICENSE: I have been asked recently by some of you whether or not audiologists need to renew their Hearing Aid Dealer license. The short answer is "no," but please read on. Although our Audiology license allows for hearing aid dispensing as part of the legal scope of practice for audiologists in Michigan, it does not provide for supervision of individuals licensed under the Hearing Aid Dealer license. For instance, if you supervise an individual in your practice with a Trainee license or an individual with a Salesperson license, you must maintain your Hearing Aid Dealer license. If you let your Hearing Aid Dealer license lapse, you do have a three-year period to reinstate it; after three years, you must reapply and go through the examination process again.
Speaking of the Hearing Aid Dealer licensing examination, you may be interested to know that it is being updated. In October, I sat on a panel of 10 individuals, all licensed Hearing Aid Dealers (and four of whom were also licensed Audiologists) to review the items on the examination. The goal is to eliminate obsolete questions and update the content to better assess an applicant’s knowledge of current hearing aid technology. The practical portion of the examination will
also be revised. This is still a work in progress, but roll-out of the new examination is expected to take place some time in 2008.
NEWBORN HEARING SCREENING LEGISLATION: In contact with his legislative aide, Rebecca Climie, Representative Glenn Steil, Jr. (R-Grand Rapids) there continues to be information that he intends on introducing a bill to mandate newborn hearing screening in Michigan. As of this writing, the bill is still in draft form and has yet to be introduced and assigned a bill number. As such, MSHA does not yet have an official position on this potential legislation, but we will be monitoring the status.
MEDICAID AND OUT-OF-WARRANTY HEARING AID REPAIRS: This is not really new news or new policy, but earlier this fall, Medicaid (and CSHCS) began enforcing a policy that out-of-warranty hearing aid repairs needed to have the actual invoice submitted in order to receive the Prior Authorization needed to bill for this service. In practical terms, this is problematic in that the invoice is not available until AFTER the hearing aid is repaired, creating a "glitch" in the authorization process.
After conversations many providers had with Medicaid staff, the process has been clarified, but it is still cumbersome. The provider can still send for Prior Authorization before the hearing aid is sent for repair. The provider will receive back a "pending letter" that basically authorizes the work to be done on the hearing aid. Once the hearing aid is received back from the manufacturer and the invoice is obtained, a copy of the invoice is sent back with the "pending letter" and copy of the Prior Authorization. At that point, Medicaid will issue a Prior Authorization number and the service can then be billed. It seems like a complex process, especially considering the level of reimbursement that the provider receives for this service.
There will be more to come on this as we try to work with Medicaid on this and several other issues (i.e., digital hearing aids for adults, authorization process for digital hearing aids for children, etc.). However, in a recent conversation with Medicaid policy specialists, I was "gently" reminded by them that the hearing aid benefit for adults is not federally mandated as part of the Medicaid program, and therefore coverage is subject to being eliminated. I do think it is significant to note that this has not happened given the budget crisis that the state has been facing as of late.
Margot Beckerman V-P for Audiology
From a recent et cetera, an important look at why licensure is so important:
But what does it mean? Why is the license important? What are we getting for our money when we fork over $150 per year to hold an Audiologist License?
First and foremost, a license is a consumer protection "plan," ensuring consumers of audiology services that an Audiologist meets a certain set of standards. Second, a license offers Audiologists title protection, meaning that use of the following titles are solely reserved for an individual holding an Audiologist License: Audiologist, Educational Audiologist, Industrial Audiologist, Clinical Audiologist, Hearing Aid Audiologist, Hearing Therapist, or Audiometrist. Only those holding the Audiologist License are permitted by law to use these titles.
The license also defines our scope of practice as audiologists. Prior to licensure, our scope of practice was defined by professional organizations to which we belonged such as the American Speech-Language-Hearing Association. While there is significant overlap, a review of the following is useful. It is of note that as stated below, our scope of practice is now defined legally. It behooves each of us as professionals to know the specifics of our scope of practice, as there are now legal implications for those straying from the law. Below is a synopsis from Section 16081 of the licensure law which now defines our scope of practice:
The "Practice of audiology" means the nonmedical and nonsurgical application of principles, methods, and procedures related to disorders of hearing, including all of the following:
(I) Facilitating the conservation of auditory system function.
(ii) Developing and implementing hearing conservation programs.
(iii) Preventing, identifying, and assessing hearing disorders of the peripheral and central auditory system.
(iv) Selecting, fitting, and dispensing of amplification systems, including hearing aids and related devices, and providing training for their use.
(v) Providing auditory training, consulting, education, and speech reading to individuals with hearing disorders.
(vi) Administering and interpreting tests of vestibular function and tinnitus in compliance with section 16809 and in adherence to the mandate of subsection (2).
(vii) Routine cerumen removal from the cartilaginous portion of the external ear in otherwise healthy ears except that if the audiologist, while engaged in routine cerumen removal, discovers any trauma, including, but not limited to, continuous uncontrolled bleeding, lacerations, or other traumatic injuries, he or she shall, as soon as practically possible, refer the patient to a person licensed in the practice of medicine or osteopathic medicine and surgery.
(viii) Speech and language screening limited to a pass-fail determination for the purpose of identification of individuals with disorders of communication.
Further guidelines, as alluded to in (vi) above, include the following mandates regarding vestibular function testing and tinnitus evaluation, as specified in Section 16809:
An audiologist shall administer tests of vestibular function only to patients who have been referred to him or her by a person licensed to practice medicine or osteopathic medicine and surgery.
If an audiologist administers an audiometric test for tinnitus and his or her examination of the patient reflects the presence of otologic or systemic diseases, the audiologist shall promptly refer the patient to a person licensed to practice medicine or osteopathic medicine and surgery.
The Michigan Audiologist License allows audiologists to dispense hearing aids without the need for holding a separate Hearing Aid Dealers License. This is not the case in every state, so we should consider ourselves fortunate. As part of that provision in the license, mandates from Section 16809 apply, mirroring the FDA requirements for hearing aid dispensing:
An audiologist shall comply with the federal food and drug administration medical referral guidelines for fitting and dispensing hearing instruments, 21 CFR 801.621, incorporated by reference.
A licensed audiologist may not sell a hearing instrument to a person under 18 years of age unless the person or the parent or guardian of the person presents to the audiologist a written statement signed by a licensed physician who specializes in diseases of the ear stating that both of the following exist:
(a) The person's hearing loss has been medically evaluated during the 6-month period preceding the date the statement is presented.
(b) The person may be considered a candidate for a hearing instrument.
Did you know there are specific continuing education requirements for relicensure? Stay tuned for more information on those requirements in the next issue of MSHA’s et cetera. (Or if you can’t wait, go to www.michigan.gov/mdc
Follow links for Health Professions Licensing÷ Licensing for Health Care Professionals ÷ Audiologist ÷ Administrative Rules. The language of the licensure law can also be found on the "Audiologist" section under the heading "Public Health Code.")
Margot Beckerman, VP for Audiology