Medicare Compliance & Reimbursement

Audiologists should be heard and not seen (by your doctor).

Myth: Audiologists should bill "incident to" your physician's provider number when they furnish diagnostic tests.

Reality: Audiologists should bill for their services under their own provider numbers. They'll receive 100 percent of the reimbursement for diagnostic tests, and they don't need a physician's supervision like "incident-to" providers do.

The American Academy of Audiology encourages its members to bill under their own provider numbers instead of "incident-to," notes Jo Ann Steigerwald with Medical Business Specialists in Baraboo, WI.

"When audiological services are billed using a physician's provider number or 'incident to,' CMS data will indicate that the physician performed the service, even if the service was actually performed by an audiologist," the Academy points out. "As a result, the audiologist becomes invisible in the reimbursement process."

If an audiologist is performing diagnostic tests in your office, you don't have to meet the "incident-to" requirements. But you do have to meet the Medicare coverage requirements, as spelled out in a 2004 regulation, Steigerwald points out. An audiologist who is state licensed and certified must perform or supervise the services.

You also need a referral from a physician for audiology services. Steigerwald suggests having a form the doctor can fax to the audiologist requesting a diagnostic test. It should specify "exactly what tests need to be performed" and list the diagnosis, signs and/or symptoms under evaluation, says Steigerwald.

The physician's referral should "clearly indicate it's for making a diagnostic determination, not screening," says Stephanie Fiedler, a senior health care consultant with Loeb & Troper in New York. Also, it should be clear the doctor's not ordering tests for an already-diagnosed problem. It should say something like: "Please see Mrs. Ear to determine type and level of hearing loss." Or, "Please see Mr. Ear for testing to evaluate his recent dizzy spells."

Mistake: Some coders try to bill 99211 for audiologists' services. But Medicare won't cover evaluation & management visits by an audiologist, says Steigerwald. Other payors might cover them, but it's unclear what E/M services an audiologist would be providing.