Legislation in Action

Current Legislative/Regulatory Activity

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.

Related Services Shortage Task Force

All Practice Areas

the Related Services Shortage Task Force released their report in November of 2019.  Advocacy efforts to implement recommendations regarding pre-service education, recruitment and retention of related services personnel working in the school setting. Related services personnel include Educational Audiologists, Speech-Language Pathologists, School Psychologists, School Nurses, Occupational Therapists and Physical Therapists.

Senate Bill 238: Art and Music Therapy Licensure

All Practice Areas

Introduced in November, to license art and music therapists.  As the bill is currently written, it allows art and music therapists to infringe upon the scope of practice for SLPs and Auds.

House Bill 436: Dyslexia Screening for Children

Schools, Private Practice/Non-Profit Practice Areas

First Hearing in January 2020.  Establishes a program for screening and intervention by trained teachers for children with dyslexia.

House Bill 243: Proposed to Ensure Hearing Aids Coverage in Health Plans to Cover Hearing Aids Up To Age 22

Audiology, Schools, Private Practice/Non-Profit Practice Areas

Sponsor testimony was given on October 1, 2019.  Proponent testimony is scheduled for February 4th, 2020.

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:


Interstate Compact Update

 All Practice Areas

ASHA participated in a meeting with staff from the U.S. Department of Defense-State Liaison Office (DSLO) to discuss how interstate compacts will address the needs of service members and military families. DSLO staff discussed their historical involvement in promoting expedited licensure for military spouses and shared their interest in interstate compacts. Representatives from current health interstate compacts and those in development, including representatives from ASHA, discussed ways to work with the state liaison office to promote compacts. Learn more about the speech-language-hearing interstate compact.


Tell Ohio Medicaid Your Feedback on the Current State of Medicaid Services

All Practice Areas

The Ohio Medicaid Director, Maureen Corcoran, is asking for our help with the Ohio Medicaid managed care contract procurement process!  What is the procurement process?  It is the process used by Ohio Medicaid to select managed care partners via a RFI (Request For Information) format.  ODM’s first step in the process is to collect feedback on current Medicaid services, what is working and ideas for improvement. If you are a Medicaid provider, advocate or an individual receiving Medicaid, please consider submitting your thoughts and/or concerns. ODM is seeking feedback in multiple areas, including:

  • How managed care organizations communicate and support individuals and providers;
  • What benefits and services are most helpful;
  • How to best coordinate individual care;
  • How to file complaints and appeal managed care organization decisions.


Maureen Corcoran reiterates that all feedback is being considered and a deadline for feedback collection has not yet been identified. Therefore, you are encouraged to share your experience(s) with the current program or your ideas and solutions for improving the program, through the RFI webpage.


OSLHA thanks you for your time and consideration; this information will help to put individuals first throughout the entire managed care procurement process.


Contact your Representatives to Increase Access to Audiologists' Services

Audiology, Healthcare, Private Practice/Non-Profit Practice Areas

On July 25, Rep. Tom Rice (R-SC) and Rep. Matt Cartwright (D-PA), along with nine other members of Congress, introduced the bipartisan Medicare Audiologist Access and Services Act of 2019 (H.R. 4056). The bill will expand coverage to include all Medicare covered diagnostic and treatment services that correspond to audiology’s scope of practice; remove the unnecessary physician referral in order for Medicare beneficiaries to access audiology services; and reclassify audiologists from “supplier” to “practitioner” to better recognize the role audiologists play in providing hearing health care services. ASHA expects an identical bill in the Senate to be introduced in early September.

Contact your members of Congress today and ask them to cosponsor the Medicare Audiologist Access and Services Act of 2019 (H.R. 4056).


Joint Habilitation/Rehabilitation Benefit Coverage Statement & Guide Made Available by ASHA

All Practice Areas

The American Speech-Language-Hearing Association (ASHA), American Occupational Therapy Association and American Physical Therapy Association has a new resource for public and private insurers, employers, consumers, state regulators and other stakeholders to evaluate the appropriateness of rehabilitation and habilitation benefit design. The document Joint Habilitation/Rehabilitation Benefit Coverage Statement: Guide to Assessing Adequacy of Benefits outlines the principles that should be evaluated when determining whether an insurance product provides adequate coverage of habilitation and rehabilitation services and devices. Rehabilitation and habilitation address function, communication, participation, mobility, and engagement limitations that result from illness, injury, disability, or other conditions. Habilitation and rehabilitation benefits are cost effective, representing only 2% of the premium for a silver marketplace plan.

ASHA also has a guide entitled Speech, Language, and Hearing Services: Essential Coverage of Habilitation and Rehabilitation. The guide discusses steps that Ohio can take to protect individuals needing medically necessary habilitative and rehabilitative services and devices.

If you have any questions or would like to further discuss the importance of habilitation and rehabilitation coverage, please do not hesitate to contact Susan Adams (ASHA’s Director of State Legislative & Regulatory Affairs) at 301-296-5665, sadams@asha.org or Daneen Sekoni, ASHA’s Director of Health Care Policy, Health Care Reform at 301-296-5651, dsekoni@asha.org


The Dept. of Medicaid Puts Out a Request for Information to Gather Public Input

Healthcare Practice Area

The Ohio Department of Medicaid (ODM) has released a request for information (RFI) to gather public input as it begins the process to select managed care partners. ODM’s first step in the process is collecting feedback on current Medicaid services, what is working and ideas for improvement. The mission in this process is to focus on the individual rather than on the business of managed care, and this request seeks information specifically from individuals receiving Medicaid services, providers and advocates.

Feedback is being sought in multiple areas, including:

  • How managed care organizations communicate and support individuals and providers
  • What benefits and services are most helpful
  • How to best coordinate individual care
  • How to file complaints and appeal managed care organization decisions

Submit feedback through the RFI webpage.

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:

Changes to Medicare Physician Fee Schedule

 All Practice Areas

The Centers for Medicare & Medicaid Services (CMS) reversed course in their 2019 Medicare Physician Fee Schedule Final Rule [PDF] and included audiologists and speech-language pathologists as eligible professionals for the Merit-Based Incentive Payment System (MIPS). The program, which is effective January 1, 2019, requires eligible clinicians to report quality and improvement activity data to CMS that will be used to positively and negatively adjust Medicare payments. ASHA expects MIPS reporting to apply to less than 1% of ASHA members because of low volume thresholds and site of service exclusions. However, inclusion in the program has significant implications for those that must report and for the professions moving forward. To learn more, visit ASHA’s website.

ASHA Develops a New Advocacy Tool for Protecting Therapy Coverage Under the ACA

 Healthcare, Schools, Audiology, Telehealth, DD, Private Practice, CLD Practice Areas

Recent changes by the federal government give states more leeway to determine what services are covered or excluded in ACA health plans. Speech, Language, and Hearing Services: Essential Coverage of Habilitation and Rehabilitation is a tool developed by ASHA for ASHA-recognized state associations and Habilitation Advocates to use when speaking with exchange officials, insurance commissioners, and state legislators about the value of audiology and speech-language pathology services as an essential health benefit. We encourage you to use this tool as an educational resource!

CMS Issues Guidance Regarding Medicare Therapy Service (Post Therapy Cap)

Healthcare Practice Area

Read the ASHA Headline on This Topic

ASHA Releases Position Statements on Facilitated Communication (FC) & Rapid Prompting Method (RPM)

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

Healthcare, Telehealth, Private Practice Practice Areas

 Learn More about this proposal

FDA Approves Telepractice Option for Cochlear Implants

Audiology, Telehealth, Healthcare, DD, Private Practice Practice Areas

Read the FDA News Release

Medicaid and CHIP Payment & Access Commission (MACPAC) Publishes Update on Current Status of School-Based Services

 Schools, Supervision Practice Areas

Read More on This Topic

Reimbursement for Transgender Voice Therapy Services

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