NPI and Audiology: An Interview with Deb Abel, AuD, Director of Reimbursement, American Academy of Audiology
American Academy of Audiology
Interview with Deb Abel AuD
Director of Reimbursement
American Academy of Audiology
June 19, 2008
Academy/Beck: Hi, Deb. Thanks for your time today. In your position as the director of reimbursement at the Academy, you're right in the middle of the states and the feds, and the practicing audiologists across the United States?
Academy/Abel: Thanks for the opportunity, Doug! Yes, in some respects you could say I'm the liaison between the Academy and the government regarding reimbursement issues. The government just doesn't know it!
Of course this can only be accomplished by a team effort-this is definitely not a one-woman show! The Academy is fortunate to have a superb coding and reimbursement committee chaired by Kadyn Williams, AuD. We also provide Academy members coding and reimbursement information, Medicare information, and HIPAA and insurance contracts information among others. My position is part of the advocacy team for the Academy, which includes government policy. The team is comprised of senior director of government relations, Phil Bongiorno, and government relations manager, Kate Thomas,
Academy/Beck: Thanks, Deb. Today I'd like to explore the new National Provider Identification (NPI) program and its relationship to audiology. What exactly is an NPI?
Academy/Abel: NPI is the National Provider Identifier number.
Academy/Beck: Where did NPI come from?
Academy/Abel: It's a federal mandate. Originally it was part of the Administrative Simplification Title of HIPAA's rules and regulations. HIPAA mandated the National Provider Identification number to provide greater efficiencies with mandated electronic transmission of health care information.
Academy/Beck: In other words, NPI allows the federal government to figure out who the real providers are by having a record of who's billing for what?
Academy/Abel: That's correct, as long as everyone bills using their own individual NPI numbers. The NPI is a personal 10-digit code that each provider keeps until the end of his or her professional days. It's the only number you need to bill claims to all third-party payers. However, for Medicare, you'll also need a Medicare Provider Identifier Number if you file claims for Medicare beneficiaries in addition to a physician referral for a medically necessary audiologic evaluation.
Academy/Beck: Deb, if I recall, I think I read something like three-quarters of all audiology-based CPT codes are not billed by audiologists?
Academy/Abel: That's right. Until the recent CMS transmittals 84 and 1470 our two core codes, 92557 (comprehensive audiometry) and 92567 (tympanometry) were billed 70% by physicians for Medicare beneficiaries!
Through use of their own NPIs, audiologists will be correctly represented as the professional performing these procedures. This adds recognition for the profession on many levels, including legislatively and with many federal initiatives we have not previously had access to. NPI provides "ownership" of the services we provide and the knowledge and skills we possess. In essence, audiologic services will be "credited" to audiologists downstream. When you appy for your NPI, you need to itemize the taxonomy code(s). Those codes "label" who you are as a professional and the services you provide. These codes are not only for diagnostic audiology, but also for the fitting of assistive technology, the assistive listening device product, as well as quantifying audiologist-hearing aid fitter. The NPI is administered by the National Plan and Provider Enumeration System (NPPES) under the Centers for Medicare and Medicaid (CMS).
Academy/Beck: OK, and who should get an NPI?
Academy/Abel: Anyone who sees patients, is a health-care provider, conducts any of HIPAA's standard transactions, and even people who send electronic health-care information. So bottom line, every audiologist who sees patients needs an NPI.
Academy/Beck: What's the process to acquire an NPI?
Academy/Abel: It's easy, just click into https://nppes.cms.hhs.gov/NPPES/Welcome.do and follow the instructions. You'll have your NPI in approximately 48 hours via e-mail.
Academy/Beck: Weren't we supposed to have filed and received our NPIs in 2007?
Academy/Abel: Yes. The national deadline was originally 2007, but it was extended a year ago from May 23, 2007, until May 23, 2008. CMS recently extended the deadline again for audiologists, to October 1, 2008, so audiologists can still obtain their NPIs and their Medicare PINs. The PINs take approximately eight weeks and as I mentioned, the NPI just takes a day or two.
Academy/Beck: Is there a penalty for being late in filing and acquiring an NPI?
Academy/Abel: Well, there's no late-fee penalty, so to speak. But, by not having an NPI while continuing to file claims for audiologic services, you're considered non-compliant in the eyes of HIPAA and without an NPI, your claims will be denied. This will limit access to billing for your services and will clearly impact your cash flow. Insurance companies also need to be in compliance when accepting claims with an NPI. And as you know, Doug, when filing a claim, you need your personal NPI as well as the NPI of the facility where you provide services. So the bottom line is, Academy members should immediately begin using their NPIs to bill third-party payers.
Academy/Beck: What's the difference between and NPI and a Medicare provider number, and why do you need both?
Academy/Abel: The NPI is for all third-party payers, including Medicare. However, if you are a Medicare provider, you will need both your NPI and your Medicare Provider Identifier Number (PIN). The 855I is the form you need to file to obtain your Medicare PIN. If you are an employee of a physician, you will also need to file an 855R to assign the benefits to your employer. Just a point to clarify here…physicians are reimbursed from the same Medicare Physician Fee Schedule (MPFS) as audiologists are, so there will be no change in the reimbursement.
Academy/Beck: What about when a technician, or someone other than an audiologist performs a test in a physician's office? Does the physician have to physically be in the office when someone besides an audiologist bills an audiology code while using the physician's NPI number?
Academy/Abel: Yes, absolutely, that's correct and is known as "direct supervision." Testing done by an audiologist does not require "direct supervision" by a physician, but direct supervision is required for the services of a non-audiologist. A physician order for the test(s) also needs to be completed for technicians and the procedures have to be itemized by the physician regarding which tests are to be performed. The technician will be limited to only those tests specified and those will be billed as "incident to" the physician. Audiologists cannot bill for another audiologist as "incident to" nor for a technician's services as "incident to."
If a technician is performing the actual test of a comprehensive ABR for example, the technician's services will be billed with the technical code (92585-TC). If the audiologist does the interpretation, the audiologist can bill the professional code (92585-26). If the audiologist performs both the test and the interpretation, they bill globally or 92585.
Academy/Beck: OK, I get it… but if you don't mind, the whole "incident to" situation seems like a mess. Can you offer a few comments on that?
Academy/Abel: There are several requirements that need to be followed to properly bill "incident to." However, audiology tests are in a category of "other diagnostic tests" and were never to have been billed "incident to." Nonetheless, audiology codes have been billed as "incident to" for years, incorrectly and rampantly. The Academy has been calling for the cessation of "incident to" billings for years, so this is an exciting and long overdue professional milestone.
Academy/Beck: Deb, before I let you run, what about automated audiometry? Is it true that physicians with automatic testing machines are not allowed to bill Medicare for auto-tests?
Academy/Abel: That's correct, Doug. Simply put, auto-tests do not require "the skills of an audiologist" and are not covered or reimbursable by Medicare.
Academy/Beck: And so the bottom line regarding CMS and auto-tests is that the compensation from CMS is based on actual "work" and "thought" being done by human professionals, not the work of a "robot"-is that a fair way to say it?
Academy/Abel: Yes, pretty much. Now that 92557 has work/cognition in the Relative Value Unit (RVU) formula, we are reimbursed to constantly evaluate and re-evaluate what needs to be done based on patient indicators; a constant ongoing thought process that includes mental stress and cognition. Automated audiometry has its place, but that place is not a line item on a Medicare bill.
Academy/Beck: Is there an NPI impact on direct access?
Academy/Abel: Yes, there is, Doug. When you look at the numbers in the database that we spoke of earlier (most audiology codes are billed by physicians), it's difficult to prove audiology as a profession deserves direct access. The percentage of procedures doesn't match our "right" to direct access.
I'd like to make sure everyone knows that direct access will still require a medical necessity rationale. The part that will change is that the physician referral requirement to diagnose and treat would go away. We're closer than we've ever been to direct access with 96 co-sponsors. I would encourage Academy members to write to their Congress people as well as support the Academy PAC!
Academy/Beck: Thanks, Deb. I appreciate your time and knowledge.
Academy/Abel: Doug, the pleasure was mine.