CMS developed The National Correct Coding Initiative (NCCI) for Medicare Part B and Medicaid claims. NCCI is an automated edit system to control Current Procedural Terminology (CPT) code pairs that can be reported on the same day. The goal is to assure therapists are not billing codes considered to be a part of more comprehensive services to the same patient on the same day.
In January an inconsistency between guidance from The American Speech-Hearing Association (ASHA) and NCCI was noted – NCCI removed G0515 from acceptable use by SLPs.
NCCI Manual Chapter 11, Section H (otorhinolaryngologic Services), Subsection 2 states:
“2. Speech language pathologists may perform services coded as CPT codes 92507, 92508, or 92526. They do not perform services coded as CPT codes 97110, 97112, 97150, 97530 or G0515, which are generally performed by physical or occupational therapists. Speech language pathologists shall not report HCPCS/CPT codes 87110, 97112, 97150, 97530. 97127, or G0515 as unbundled services included in the services coded as 92507, 92508, or 92526. (CPT code 97532 was deleted on January 1, 2018)”
ASHA alerted CMS of this issue on January 16, 2019. ASHA disagreed that SLPs do not perform the service (G0515). On January 31, 2019, the medical director of NCCI responded to ASHA with a clarification stating the addition of G0515 to the sentence was an “inadvertent error.” Additionally, CMS has no intention of changing policy about whether SLPs may bill the code. The above subsection will be reviewed for the 2020 version of the NCCI manual to be published in mid-November 2019. Until that time the letter from the medical director of NCCI may be used as evidence to those who may misinterpret Subsection 2 as a change to CMS policy. SLPs may perform the services described by HCPCS code G0515 and may bill the code.
To read a copy of the NCCI’s letter in response to ASHA’s concerns, click here.