Kentucky Speech-Language-Hearing-Association
 838 East High Street, Suite 263, Lexington, KY  40502
 800-837-2446  888-729-3489 fx
 

Advocacy network updates

KSHA STAR

Iam Susan Waters and I hold the State Advocate for Reimbursement (STAR) position for Kentucky. There are two areas of information that may affect private practice clinicians. First, on March 8, 2011, Governor Steve Beshear announced that Kentucky continues to forge ahead with efforts to adopt electronic health records (EHRs), with more hospitals and providers receiving monetary incentives for EHRs and linking to the Kentucky Health Information Exchange (KHIE).

Secondly, during the month of May, OptumHealth and Amerigroup Kentucky, Inc., accepted health plan applications to participate in the Medicaid/state Health Care programs. At this time, both health care groups want it to be known that these letters are only Letters Of Intent (LOI), allowing these groups to demonstrate to Kentucky’s Cabinet for Health and Family Services, Department for Medicaid Services (DMS) a possible commitment to developing a physical medicine network for these Medicaid programs.

Please contact me at susanwaters@fuse.net with any questions regarding reimbursement for private
practice services in speech-language pathology and/or audiology. I will do my best to find the answers.

Susan R. Waters, MA, CCC-SLP
KSHA STAR

SMAC Update

The State Medicare Administrative Contractor Network (SMAC) continues to have monthly phone conferences to discuss issues relevant to our members regarding Medicare. Below is a summary of recent issues discussed:

• Supervision requirements for videostroboscopy and nasopharyngoscopy
  • ASHA met with representatives of AAO-HNS and laryngologists on March 31. CMS
    was concerned that there was no formal certification process for passing the endoscope,
    however, ASHA presented the Knowledge and Skills document and the fact that SLPs have been performing these procedures since the mid-1980’s. After the meeting ASHA attendees were optimistic that CMS would remove the requirement for physician presence in the room. The decision will be published in the July 1 or October 1 CMS quarterly regulatory release according to John Warren, MD, interim director of practitioner services.
• RAC audits
  • Tips for appealing denials from Eli Research, Durham, NC.
    • Assume the RAC will not deny claims unless it is 90% sure of winning. Unless they win, they will not be paid for the work done to recover funds.
    • Fight the denial if you think you are right. If you don’t fight it, you should change your practice patterns.
    • Don’t appeal every RAC denial in an effort to “clog up the system.” Mass appeals are an admission that your current practices are acceptable without changes.
    • Lack of solid documentation is not necessarily a reason for not appealing. A late-dated entry can be added to the record. There are other ways to validate that a service was provided, such as evidence of a patient sign-in to a therapy room.
    • Look at other ways to get off the hook guidance from CMS when the services rendered may be clear now but not at the time.
    • Take your appeal to the administrative law judge – the success rate is high at this level.
• Bilateral cochlear implants
  • ASHA testified before The Medicare Evidence Development Coverage Advisory Committee on May 11.
• Additional Documentation Requests
  • Some members reported that there has been an increase in ADRs.
• TEP Update
  • CMS refuses to make exceptions to DME/prosthetic policy
• Cochlear implant programming for home health patients
  • A Medicare Administrative Contractor in Florida, First
    Coast, is rejecting independent claims by audiologists,
    insisting that the services are consolidated with other home
    health services.
• Medicare’s proposed group therapy regulations
  • An informal group of SMAC members are in the process
    of helping draft a comment letter from ASHA regarding
    Medicare’s proposed regulations on group therapy in
    skilled nursing facilities. The comments are due June 27 as
    the proposed regulations will become effective October 1,
    2011. I am participating in this group.

If you have questions regarding Medicare, please e-mail me at linda.gregory@familychoicecare.com.
Linda F. Gregory, MA, CCC-SLP
KSHA SMAC

SEAL Update

At the end of April, I participated in a conference call for ASHA’s State Education Advocacy Leaders (SEAL). The topic discussed was“Value Added Assessments.” I wasn’t sure what this was all about, but it turned out to be very interesting.

It all has to do with President Obama’s “Race to the Top Project” ideas to create a teacher accountability system and link teacher pay to performance. Many states have already adopted, or are in the process of developing laws to develop these systems.

Most states implementing these assessment programs, have begun with Regular Education Classroom Teachers, and are working their way forward to including Special Education Teachers and Related Service Providers. Essentially, this is a Teacher Evaluation System that determines if the teacher’s performance in his/her job has resulted in the desired student learning and/or achievement, which will determine IF the teacher keeps his/her job and if the teacher’s performance warrants a raise.

Some of the state SEALs on the call were reporting what their states are already doing to use or develop a similar system for speechlanguage pathologists in the schools. The state SEALs who reported that their states have already begun this process included Texas, Georgia, Wisconsin, Connecticut, Washington state and a few others. As far as I know, Kentucky is nowhere near creating this kind of teacher evaluation system.

ASHA is trying to be proactive and develop some guidelines if and when states plan to use this type of assessment for speechlanguage pathologists employed in the schools. These guidelines will be formalized soon, and should include:

• Teacher, speech-language pathologist, special education teacher, etc. Evaluations should not be based on standardized student performance tests.
• Speech-language pathologist evaluations should be different than teachers.
• Performance evaluations for speech-language pathologists should be conducted by individuals who have expertise in speech-language pathology.
• Speech-language pathologist professional evaluations in the schools should include multiple measures, such as maintaining and review of a portfolio; feedback from staff and peers; review of individual students’ IEP progress and growth; and should be consistent with SLP job descriptions.
• Whatever speech-language pathologist evaluation system is used should result in the same merit pay as teachers.
• Speech-language pathologists should be involved with the development of the speech-language pathologist evaluation process in each state and it should be consistent across the state.
  

So, if this Value Added Assessment process is ever started in Kentucky, it looks like another job for the Kentucky Department of Education – hopefully with significant input from the state Speech-Language Pathology Liaison to KDE. Guidelines from ASHA should be available this summer for the ASHA schools conference being held in Washington, DC, in July.

Sherry Hoza, MS, CCC-SLP
KSHA SEAL