By Kalisha Barrett, Senior Manager Health Policy
On April 30, 2020, the Centers for Medicare & Medicaid Services (CMS) announced new rules to further expand telehealth for Medicare beneficiaries. CMS will temporarily reimburse audiologists and speech-language pathologists (SLPs) for providing telehealth services to Medicare Part B beneficiaries, in response to the COVID-19 pandemic. This expansion is retroactive to March 1, 2020 and will continue throughout the duration of the COVID-19 public health emergency (PHE).
What does this mean for enrolled Medicare providers?
- Providers may no longer enter into private payment arrangements with Medicare beneficiaries for any services that are included on Medicare’s approved telehealth services.
- If any covered telehealth services were provided to Medicare beneficiaries in a private pay arrangement since March 1, 2020, the providers should refund patients and instead submit a Medicare claim.
What does this mean for unenrolled Medicare providers?
- Providers may not enter into private pay arrangements with Medicare beneficiaries for covered telehealth services provided from March 1, 2020 and during the PHE.
- Providers should refund beneficiaries for funds collected that were associated with covered telehealth services for services provided since March 1, 2020.
- Unenrolled providers may not submit claims to Medicare for reimbursement for covered telehealth services during the PHE.
CMS added the following codes to allow audiologists to provide Medicare telehealth services to cochlear implant recipients:
| CPT Code | Code Description |
| 92601 | Diagnostic analysis of cochlear implant, patient younger than 7 years of age; with programming |
| 92602 | Diagnostic analysis of cochlear implant, patient younger than 7 years of age; with programming; subsequent programming |
| 92603 | Diagnostic analysis of cochlear implant, age 7 years or older; with programming |
| 92604 | Diagnostic analysis of cochlear implant, age 7 years or older; with programming; subsequent programming |
CMS added the following codes to allow SLPs to provide Medicare telehealth services:
| CPT Code | CPT Description |
| 92507 | Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual |
| 92508 | Treatment of speech, language, voice, communication, and/or auditory processing disorder; group |
| 92521 | Evaluation of speech fluency (eg, stuttering, cluttering) |
| 92522 | Evaluation of speech sound production (eg, articulation, phonological process, apraxia, dysarthria); |
| 92523 | Evaluation of speech sound production (eg, articulation, phonological process, apraxia, dysarthria); with evaluation of language comprehension and expression (eg, receptive and expressive language) |
| 92524 | Behavioral and qualitative analysis of voice and resonance |
As a part of CMS expansion of services, speech-language pathology services can be provided via telephone-only when the patient does not have access to audiovisual equipment.
Both audiologists and SLPs should bill the same CPT codes they would for an in-person appointment, along with the place of service code that represents the in-person service. Providers will need to append the modifier -95 (synchronous telemedicine service) to each CPT code provided via telehealth. During the PHE, Medicare will reimburse these telehealth services at the same rate as in-person services paid under the Medicare Physician Fee schedule for Part B services.
The American Speech-Language-Hearing Association (ASHA) , the American Cochlear Implant Alliance (ACIA), and the American Academy of Audiology (AAA) have published additional guidance on Medicare telehealth services during the COVID-19 pandemic. It is important to note that the professional societies were instrumental in working with CMS to advocate for expanded Medicare telehealth service for audiologists and speech language pathologists. Providers are encouraged to support their professional societies as they continue to advocate for permanent expansion of telehealth services in the regulatory framework.
To learn more about providing telehealth services, check out these additional resources:
AAA
ACIA
Covid 19 updates and resources available to providers, including template to request a Medicaid Waiver for providing speech language and audiology services via telehealth. https://www.acialliance.org/page/covid-19updates
ASHA
Providing Teleheath Services Under Medicare During COVID-19 Pandemic:
Telehealth coverage tracking by state:
https://www.asha.org/uploadedFiles/State-Telepractice-Policy-COVID-Tracking.pdf
Telehealth coverage tracking by commercial insurance plan:
https://www.asha.org/uploadedFiles/COVID-19-Commercial-Insurance-Telepractice-Policy-Tracking.pdf
Telehealth coverage tracking of Medicaid by state:
https://www.asha.org/uploadedFiles/COVID-19-State-Medicaid-Telepractice-Policy-Tracking.pdf
CMS
COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers:
https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf
Covered telehealth services during COVID 19 PHE:
https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes
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All specific references to CPT codes and descriptions are ©2020 American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association. CPT and CPT material are copyrights of American Medical Association (AMA): CPT Copyright 2020 American Medical Association, all rights reserved. CPT is a registered trademark of the American Medical Association. The information provided in this document is provided as guidelines only to address the unique nature of implantable hearing solutions technology. This information does not constitute reimbursement or legal advice. Cochlear Americas makes no representation or warranty regarding this information or its completeness, accuracy, fitness for any purpose, timeliness, or that following these guidelines will result in any form of coverage or reimbursement from any insurance company or federal health care program payer. The information presented herein is subject to change at any time. This information cannot and does not contemplate all situations that a health care professional may encounter. To be sure that you have the most current and applicable information available for your unique circumstances, please consult your own experts and seek your own legal advice regarding your reimbursement and coding needs and the proper implementation of these guidelines. All products should be used according to their labeling. In all cases, services billed must be medically necessary, actually performed, and appropriately documented in the medical record.
