The audiologist profession is one of the fastest growing professions; however, actual audiology services is a newer area of billing under Federal law. Because of this, there is often confusion for new audiologists starting out and attempting to understand the Federal requirements regarding their services. In this post we will be discussing the basic information every new and currently practicing audiologist needs to know about Federal billing rules.
What is an Audiology Service?
The term “audiology services” means such hearing and balance assessment services furnished by a qualified audiologist as the audiologist is legally authorized to perform under State law (or the State regulatory mechanism provided by State law), as would otherwise be covered if furnished by a physician. Notice that it is only considered an audiology service if performed by a qualified audiologist. We will discuss the exception to this, but generally speaking an “audiology service” can only be billed under the Federal rules if such service is provided by a qualified audiologist. Therefore, it is important to understand what exact the Federal government deems to be a qualified audiologist.
Who is a Qualified Audiologist?
The term “qualified audiologist” means an individual with a master’s or doctoral degree in audiology who—(i) is licensed as an audiologist by the State in which the individual furnishes such services, or (ii) in the case of an individual who furnishes services in a State which does not license audiologists, has successfully completed 350 clock hours of supervised clinical practicum (or is in the process of accumulating such supervised clinical experience), performed not less than 9 months of supervised full-time audiology services after obtaining a master’s or doctoral degree in audiology or a related field, and successfully completed a national examination in audiology approved by the Secretary. There may be additional requirements depending on the state in which the services are provided though. Above all, the definition above is important as it relates to the specific audiologist requirements. If an audiologist cannot meet the above mentioned requirements, the audiologist would not meet the definition.
Can Audiology Services be Performed by Other Practitioners?
Interestingly, because audiology services are defined as diagnostic tests under the Federal rules, they can be provided by a physician, audiologist, or a non-physician practitioner such as a nurse practitioner. In addition, they can be performed by another types of licensed profession so long as the specific levels of supervision for the service are met.
Must All Audiologists Enroll as a Medicare Provider?
No. This is a little bit if a trick question as audiologists are actually always enrolled as a provider in Medicare because they cannot opt out. Further, if an audiologist works for a hospital, the hospital can bill for the facility services under the outpatient prospective payment system and for the audiologist’s professional services under the Medicare Physician Fee Schedule.
Is There a Supervision Requirement for Audiologists?
No. Audiologists do not require any physician supervision when they are providing and billing for audiology services. Although there are supervision requirements for technicians performing the audiology diagnostic tests, when such services are performed by an audiologist there are no requirements. Regardless, the individual providing the services must be qualified to provide the service. CMS does state that a technician is not allowed to perform any part of an audiology service that requires professional skills such as interpreting tests or engaging in clinical decision making.
Billing in the Outpatient Setting
Interestingly, only the hospital is able to bill for the technical component of an audiology service in the outpatient setting. Further, the audiologist can only bill for the professional service. See a list of CPT codes here. So for the exact same test that would otherwise occur in the office setting, there is now a technical component to the test because it is being performed in the outpatient setting. Thus, to increase revenue hospitals may utilize audiologists for outpatient services.
Must Audiologists Adhere to the Stark Law?
The Stark Law could be implicated because certain audiology services may be considered designated health services. However, although audiologists are doctors of audiology, they are not considered physicians under Federal law. For example, physicians only includes, MDs, DOs, DDS’, chiropractors, and optometrists.
What are the Recognized Audiology Services?
Audiology services typically include
- evaluation of the cause of disorders of hearing, tinnitus, or balance;
- evaluation of suspected change in hearing, tinnitus, or balance;
- determination of the effect of medication, surgery, or other treatment;
- reevaluation to follow up regarding changes in hearing, tinnitus, or balance that may be caused by established diagnoses that place the patient at robable risk for a change in status, including but not limited to otosclerosis, telectatic tympanic membrane, tympanosclerosis, cholesteatoma, resolving middle ear infection, Meniére’s disease, sudden idiopathic sensorineural hearing loss, autoimmune inner ear disease, acoustic neuroma, demyelinating diseases, ototoxicity secondary to medications, or genetic vascular and viral conditions;
- failure of a screening test (although the screening test is not covered); and
- diagnostic analysis of cochlear or brainstem implant and programming;
audiologic diagnostic tests before and periodically after implantation of auditory prosthetic devices.
Any services provided for the purpose of hearing-aid evaluation and fitting are not covered, regardless of how they are billed. However, if a physician refers a beneficiary to an audiologist for testing related to signs or symptoms associated with hearing loss, balance disorder, tinnitus, ear disease, or ear injury, the audiologist’s diagnostic testing services should be covered, even if the only outcome is the prescription of a hearing aid.
Audiology services can be a complex area because it includes professional services as it relates to diagnostic tests. Further, even if performed by some practitioners, only the diagnostic test portion can be billed. It is because of this complexity that it is important to remember the billing basics for audiologists and audiology services. For more resources, please checkout our audiology resource page.