Otolaryngology Coding Alert

Nonphysician Practitioner Coding:

Ensure Proper Payment for Audiology and Allergy Testing

The level of supervision required for audiology and allergy tests performed by nonphysician practitioners (NPPs) varies depending on two factors: the type of test performed and the credentials of the NPPs performing the test.

Otolaryngologists and their coders frequently confuse physician supervision guidelines for diagnostic tests. It is easy to see why, notes Susan Callaway, CPC, a coding and reimbursement specialist and educator in North Augusta, S.C. "Both sets of guidelines have a lot in common," she says. "Not only do both guidelines apply to services performed by NPPs, but they also involve supervision by a physician."

In addition, an inexperienced coder may not be certain how to distinguish a diagnostic procedure, such as endoscopy or biopsy, from a diagnostic test, such as audiometry or allergy tests. The distinction is important because there are major differences between the "incident to" and diagnostic test guidelines. To determine the correct level of physician supervision for a given service, otolaryngologists need to know how to identify what Medicare considers a diagnostic test and what supervision level is required. Physician Supervision of Diagnostic Tests An extensive list of diagnostic tests is payable under the Physician Fee Schedule (PFS). These tests can be identified reasonably accurately by the number of global days in the surgical package, which is noted in field N of the national PFS Relative Value Guide. Further, an April 2001 program memorandum (Transmittal B-01-28) from CMS listed many diagnostic test codes requiring at least some physician supervision. The list includes many diagnostic tests performed by otolaryngologists, such as: Most audiologic tests from 92552 to 92596 Most allergy tests from 95004 to 95065 Vestibular function tests with recording, 92541-92548. Note: Other diagnostic procedures, such as diagnostic endoscopies or biopsies, are not considered tests, and the guidelines do not apply. Unlike incident to guidelines, which require "direct personal supervision" of an NPP while a procedure or service is performed, diagnostic test guidelines include three levels of supervision: General: The procedure is furnished under the physician's overall direction and control, but the physician's presence is not required. Under general supervision, the training of the nonphysician personnel who perform the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician. Direct: The physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. The physician does not have to be present in the room where the procedure or service is performed. Personal: The physician must be in the room during the performance of the procedure. Note: The direct personal supervision requirement for incident to billing corresponds to direct supervision for a diagnostic test. Codes listed in the [...]
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