MSHA members in action.

STATE ADVOCATES FOR MEDICARE POLICY (StAMP) STATE ADVOCATES FOR REIMBURSEMENT (STARs) HABILITATION AUGUST 2, 2018

STARs:

LANGUAGE EQUALITY AND ACQUISITION FOR DEAF KIDS

LEAD-K (Language Equality and Acquisition for Deaf Kids) is a national campaign to promote language acquisition for children who are deaf and hard of hearing (DHH). LEAD-K focuses primarily on efforts to pass state legislation that would require prescriptive and duplicative efforts that may undermine the authority of IFSP/IEP team. This team focuses on ASL only typically and does not support cochlear implant, auditory perception and language therapy. According to Eileen Crowe, ASHA Director of State Associations Relations this organization is a threat to SLP’s and undermines parent choices. She is urging state associations to be aware of how quickly this association is gaining momentum and how powerful they are in moving to get legislation passed.

ASHA believes that communication access and educational placement must consider a variety of factors:

Cognitive abilities

Emotional and Social development

Academic development

Linguistic skills

Family needs

In addition, ASHA supports early access to language either visual and/or listening-spoke, as well as a parent right to choose the most appropriate language and communication modality based on evidenced based information and the needs of the family.

ASHA has been a long-time supporter of early intervention services to support the acquisition of language for communication of the child’s critical years with qualified personnel providing appropriate assessment and intervention strategies.

 

WHAT IS ASHA DOING TO COUNTER THE LEAD-K MOVEMENT?

ASHA has opposed legislation in 12 states in 2018.

ASHA has developed a white paper outlining the issue. concerns and policy statement for the Board of Director approval.

ASHA is creating a HOT Topics page for the ASHA website with a summary statement. opposition talking points, an issue brief, sample letters to legislators and sample legislation.

ASHA is developing messaging to communicate with members, state legislators and consumers.

ASHA is scheduling meetings with other stakeholder groups=American Cochlear Implant Alliance, ASG Bell. AAA and the American Academy of Pediatrics to formulate a coordinated strategy and garner support.

ASHA lobbyists met with members of the Congressional “Baby” Caucus to discuss EHDI/Parents right to choose and LEAD-K

ABA THERAPY

Members are reporting ongoing and more attempts to pass legislation by the ABA

ABA are acting as gatekeepers to insurers.

ABA has been reported recommending SLP services without an evaluation or input from a SLP.

ABA have been recommending AAC devices without an evaluation.

 

WHAT IS ASHA DOING?

ASHA has a HOT topics web page:

http://www.asha.org/Advocacy/Applied-Behavior-Analysis

Considering a media effort to address the importance of Audiology and SLP services for children with ASD.

Developing of a clinical Claims Review page on ASD for payers.

Conferring with Autism organizations about collaborative efforts.

Monitoring/opposing legislation and regulation the defines/expands the scope of practice of ABA therapist.

Monitoring autism service mandates:

http://www.asha.org/Advocacy/state/State-insurance-Mandates-Autism/

Ongoing concern is the scope of practice and use of billing codes by music therapists. Ten states now certify, register or license music therapists. The trend is for licensure which then permits use of SLP CPT billing codes.

OCCUPATION LICENSURE LEGISLATION ELIMINATION

A major trend has emerged to eliminate occupational licensure and legislation has been introduced in 8 states and passed in Missouri. Missouri will replace licensure with 3 certifications.

This legislation is moving to get rid of licensure. In Nebraska a law was passes to review 20% of occupational registry to meet least restrictive requirements.

Colorado. Kansas, Kentucky, Nevada, North Dakota, Oklahoma, Pennsylvania, Vermont, Louisiana and Nebraska along with Missouri have been faced with this legislative effort.

Seven million dollars has been allocated for the analysis of licensure requirements to develop action plans for alternative approaches to licensing for profession certification. Speech/Language Pathology and Audiology are main targets and many states are going up to Medical Doctors licenses as well.

This initiative is at the state levels. ASHA is strongly urging state associations to be aware of the danger. This will allow treatment in our professions by less skilled individuals and will undermine our ability to collect insurance and Medicaid reimbursement.

INTERSTATE COMPACT UPDATE:

Speech-language-hearing interstate compact (SLHIC)

Drafting team timeline:

Met in Washington, DC on May 21-22

Role of drafting team:

-Develops draft compact based on thoughts, ideas sand suggestions of the Advisory Group

-Use their own thoughts and expertise through the process

Finalize draft compact (2018-2019)

-Brief state legislators on compact

-Work with states to find sponsors, pass legislation.

Enactment (2020-2021)

-Reach threshold for enactment

-Set up compact commission to run compact

SPEECH-LANGUAGE-HEARING INTERSTATE COMPACT WEBPAGE:

http://www.asha.org/Advocacy/state/Audiology-and-Speech-language-Pathology-Interstate-Compact/

StAMP: 2018 CODING AND REIMBURSEMENT UPDATES

Key Components of Payment Success include:

Qualified provider

Appropriate supervision

Medical Necessity

Skilled care

Documentation

Merit-Based Incentive Payment System is here! Fee-for-service reimbursement is being discontinued. This is an outcome-based reimbursement and we all need to prepare for the change.

Fraud, waste and abuse are being followed by Medicare and private insurers. This included providing more therapy visits than needed for a specific condition or providing therapy for a condition that is not deemed medically necessary.

The following is website with further information:

https://www.cms/gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/fraud_and_abuse.pdf

  1. “CAN I BILL FOR THE 15-20 MINUTES THAT I SPEND ON PATIENT EDUCATION AND TREATMENT RECOMMENDATIONS AFTER THE EVALUATION?”

NO, NO, NO!

The time spent on service related to evaluation and treatment session are captured in the value of the CPT Code for that session.

Do not use treatment codes to capture time spent on patient/caregiver education or initial treatment recommendations.

  1. “HOW MUCH TIME SHOULD I SPEND ON AN UNTIMED CODE IN ORDER TO BILL IT?”

There is no hard and fast rule regarding length of time for an untimed code–

HOWEVER, there are underlying times associated with each CPT Code, as determined by a group of your peers, (through ASHA/AMA).

You may locate this information:

CY 2018 PFS Rule Physician Time File on CMS website.

HABILITATION:

The new is not encouraging at this time even though I have no hard and fast new item.

COMMENTS:

I traveled to Baltimore, Maryland for the ASHA Connect and attended some amazing presentations on documentation, reimbursement and preparing for an audit. I would be willing to share this in a presentation to MSHA members.

I am traveling to Boston to be a part of 3 STARs presenting on Medicaid.

Committee Chair,

Carol Morse