Legislation in Action

Current Legislative/Regulatory Activity

60-Second Advocacy Update - May 2020

The Future of Telehealth & Medicaid

All Practice Areas

Medicaid is evaluating the current emergency rule filed on March 21 to consider the efficacy of tele- health during this COVID-19 pandemic and what emergency rules will continue, be revised, or deleted. The emergency rule will expire in July 2020.  The following questions will be included in discussions:

  • Which services will be included in telehealth?
  • Which formats will be allowed to continue: asynchronous, synchronous, phone, text, video? Will the originating site of service remain broad? (location of originating telehealth)
  • Reimbursement rates?
House Bill 679

All Practice Areas

To establish and modify requirements regarding the provision of telehealth services and to declare an emergency. 1st Hearing. If passed, this would strengthen the state’s telehealth laws by expanding the list of providers who are permitted to provide services via telehealth.  Providers include: audiologists, dieticians, licensed counselors, physical therapists, psychologists, social workers and speech-language pathologists. The definition of telehealth would also be extended to include emails and phone calls.  It would also ensure that both patients and providers have the ability to request an in-person appointment. Medical boards as well as the Departments of Insurance and Medicaid have set their own rules. This measure will hopefully lead to more consistency in telehealth services across the state of Ohio.

Call  to Action: As service providers, we need to keep data and statistics on the number of appointments, type of format used, comments from patients regarding their perception of telehealth and outcomes data from the clients/patients/students. This evidence regarding the value of telehealth will hopefully help with the adoption of permanent administrative codes.

SLP-A Compact (ASLPIC) ASHA Initiative

All Practice Areas

Monitoring for forward momentum on two inter-state impact bills introduced for other professions (e.g., psychology) given the recognition that state reciprocity is important. Kelly O’Reilly received outreach from Susan Adams (ASHA) & Gregg Thornton. The Ohio Board of Speech and Hearing Professionals remains supportive; however, the Board is not able to advocate with the general assembly. GPG will provide advice and opportunity for advocacy to work to find a sponsor in order to introduce in 2021.

Changing the Future Through Advocacy

All Practice Areas

Advocacy is one of OSLHA’s Key’s to Excellence. Due to the ever-changing scope of practice in the fields of speech-language pathology and audiology, it is important to understand the process to effectively advocate for professional issues that affect the clients, students, patients, and families that we serve.  Kelly O’Reilly, lead contact for GAC and OSLHA’s three GAC representatives, Terri Hollenkamp, Maggie Kettler and Linda Wellman did a presentation for OSLHA’s virtual convention. The presentation discusses the need for advocacy, explains the process of advocacy, describes the types of advocacy and provides references and resources for advocacy efforts on the state and national levels.

Click on this link for the Power Point Presentation with Audio

Click on this link for Handouts:

Senate Bill 308/House Bill 606: Companion Bills Regarding Immunity

All Practice Areas

Both bills address immunity to bar civil action related to deaths, injuries or losses tied to transmission of COVID-19 in cases without reckless or intentional conduct.

Part 1 addresses immunity for healthcare providers and facilities.  SLP and Audiology facilities are covered under the general definition. As originally written, Speech-language Pathology and Audiology were not included as covered providers. Kelly O’Reilly worked with the sponsors to include both SLP and Audiology in the language. The first part also covers any liability for harm to an individual because they could not get our services.

Part 2 addresses business/non-healthcare service providers, i.e., front desk staff, kitchen staff, etc..

*Both bills are expected to pass.

OSLHA Advocacy Representatives

All Practice Areas

For more information or questions on legislative or advocacy issues, contact:


To call or write your legislator, go to:  www.legislature.ohio.gov

Retroactive Corrections Being Accepted for Unintentional CCI Edit that Prevented Same-Day Billing of Videofluoroscopic Swallowing Study by SLPs and Radiologists

All Practice Areas

In a recent communication, CMS noted that corrections have been made to an unintentional edit that prevented same-day billing of 92611 and 74230.  We are pleased to report that with the reversal of the CCI edit, Speech-Language Pathologists (SLPs) and Radiologists will once again be appropriately reimbursed for each distinctly different portion of their professional collaboration during the videofluoroscopic swallowing study (VFSS).  Billing adjustments will be retroactive to January 1, 2020, and the wording will be implemented as soon as technically possible in a future edit update!!

CMS further clarified that claims for same-day billing of 92611 and 74230 must include a modifier to note that the services are separate and distinct. This means that claims for VFSS should include 92611 first on the claim, as the “column 1” code, followed by 74230 with the modifier -59 (or subcategory modifiers) appended.

Additional information on the use of CCI-associated modifiers is available on ASHA’s website.


Effective January 1, 2020, the Centers for Medicare & Medicaid Services (CMS) implemented a new National Correct Coding Initiative (CCI) edit that prevents same-day billing of Current Procedural Terminology (CPT ® American Medical Association) codes 74230 (Radiologic examination, swallowing function, with cineradiography/videoradiography) and 92611 (Motion fluoroscopic evaluation of swallowing function by cine or video recording).

Speech-language pathologists (SLPs) typically collaborate with radiologists to perform the videofluorscopic swallowing study (VFSS), also called the modified barium swallowing (MBS) study. CPT codes 74230 and 92611 describe the work required to identify the medical diagnosis by the radiologist (74230) and to evaluate swallowing function by the SLP (92611). With the new CCI edit in place, SLPs and radiologists will not be appropriately reimbursed for each distinctly different portion of their professional collaboration during the VFSS.

ASHA is engaging with CMS and the contractor that manages the NCCI program to resolve this issue. In the meantime, ASHA recommends providers continue to submit same-day claims for 92611 and 74230. Because the new CCI edit lists 92611 as the “column 1” code, it should be placed first on the claim, followed by 74230. This means that 92611 should be processed for payment, but 74230 will be denied. If CMS reverses the CCI edit, all claims submitted since January 1, 2020, can be reprocessed for payment of 74230.


The NCCI (or more commonly, CCI) is an automated edit system to control specific procedure code pairs that can or cannot be reported on the same day. CMS developed the system for use in all Medicare Part B (outpatient) and Medicaid claims. See CCI Edits for Speech-Language Pathology Services for additional information on same-day billing restrictions.

ASHA NOMS Release Date Delayed

All Practice Areas

ASHA has been working hard to develop a new National Outcomes Measurement System (NOMS), which they anticipated would be ready for launch by the end of this year. However, due to some delays the new NOMS is now scheduled to be released in 2020.

As part of the new launch, all clinicians will receive a user guide that will walk them through the updated data collection process and scoring guidelines for the new FCMs. However, clinicians will no longer need to pass a user registration test. Therefore, the new training will not be offered for ASHA CEUs. Because we anticipated the launch of NOMS at the end of the year, we did not renew the current NOMS trainings for ASHA CEUs and their approval will expire on December 31, 2019. However, clinicians who complete the NOMS training will still earn professional development hours (2.5 for adults and 1.5 for pre-kindergarten), which can be used for ongoing certification maintenance and state licensure.  For more information, please visit the ASHA Certification Maintenance page.

What does this mean for you and your clinicians?
You should continue to participate in the current version of NOMS as usual. All new NOMS users will still need to be registered for the adult and/or pre-kindergarten NOMS user training(s) in order to submit data. However, users who complete the training after December 31st will not receive ASHA CEUs but will still earn professional development hours. Please let any clinicians who have not completed the training know about this deadline.


House Bill 243 - Voice Your Support for Adequate Hearing Aid Coverage for Children

All Practice Areas

OSLHA and GAC are teaming up to collect testimony to submit in support of HB243, “Madeline’s Law”.  This bill will require health plan issuers to cover hearing aids and related services for persons twenty-one years of age and younger.  The revised bill currently covers $2,500 per ear every 48 months.  The proposal is similar to laws in Kentucky and Georgia, and 23 other states that require hearing aid coverage for children.  Gongwer News Service-Ohio reported recently on concerns about how this legislation might impact Insurance premiums and their publication may rencourage you to share your testimony in response to some of these concerns.  We would like to thank Representatives Weinstein and Russo for providing sponsor testimony on behalf of our patients, as well!

Proponent testimony has been submitted and we are awaiting the results of discussion by our House of Representatives:


Error Identified in the Recently Published NCCI (National Correct Coding Initiative) Manual

All Practice Areas
An error was identified in the 2019 NCCI (National Correct Coding Initiative) manual. This manual updates the lists all the billing codes each new year. In the 2019 manual, it states that GO515, the new cognitive billing code, is NOT valid for use by speech-language pathologists!!! THIS IS WRONG!!
ASHA met with leaders responsible for this manual. They acknowledged the error and further acknowledged that speech-language pathologists can, indeed, treat cognition. They also said that the manual cannot be corrected until they do the 2020 edition.
If you get a denial for using GO515, there is a letter that was written by CMS (Centers for Medicare and Medicaid Services) that can be submitted with your appeals to help overturn the denial. The letter is available at the following link:

CMS Proposes Overhaul to the Home Health Prospective Payment System in 2020

Healthcare, Telehealth, Private Practice Practice Areas

 Learn More about this proposal

Become a Member!

Join our Membership Community Today!

  • Full Membership (Speech & Audiology Professionals): $75
  • Associate Membership (Allied Professions, Consumers, Clinical Fellows): $45
  • Student Membership (Full-time CSD Students): $25
  • Life Memberships Available to Lifetime Membership Participants


Benefits: Members receive significant discounts off the OSLHA Convention as well as access to exclusive online continuing education programming and accessibility to reasonably priced professional liability insurance coverage, ALL Included in an annual membership. All memberships expire on June 30th.