Published: October 24, 2013

CMS Restores Previous Supervision Requirements for Videostroboscopy and Nasopharyngoscopy

On July 18, 2011, the Centers for Medicare and Medicaid Services (CMS) officially notified the Academy that it had restored the previous supervision requirements (i.e., no supervision level assigned) for Videostroboscopy (31579) and Nasopharyngoscopy (92511) when performed by speech language pathologists. In a March meeting with CMS, Academy representatives made it clear that we support direct supervision. Background of SLP supervision level changes Effective January 1, 2011, CMS changed the supervision level for speech and language pathologists (SLP) who perform procedures using CPT code 31579 (Laryngoscopy, flexible or rigid fiberoptic, with stroboscopy) and code 92511 (Nasopharyngoscopy with endoscope) from the previous level of supervision (no level assigned) to personal supervision. CMS made this change in the Medicare Physician Fee Schedule Final Rule CY 2011 without publishing notice of the change in the proposed rule, which would have allowed for public comment. The Academy published the physician supervision change in The News and as a result, began receiving communications from many of our members, from all of the regions in the country, stating their concerns about how this change would negatively affect their practices and their ability to serve Medicare patients. After careful consideration of  AAO-HNS members’ concerns and best interests, the Academy arranged to meet with payment representatives from CMS. On Thursday, March 31, 2011, representatives from the AAO-HNS along with the American Speech and Hearing Association (ASHA) met with CMS officials at their headquarters in Baltimore, MD. CMS was provided with two journal articles co-authored by otolaryngologists and speech language pathologists and an Academy position statement addressing these services.1  The Academy representatives made it clear that we support direct supervision  and not general supervision,  meaning the physician is available, but not necessarily on the premises. Both organizations strongly urged CMS to change the supervision requirement from personal to direct supervision—that is, the physician must be “immediately available” but not necessarily in the room while the procedure is being performed.  Both societal representative groups were cautiously optimistic that CMS would make the requested change. CMS indicated that if a change were to be made, it would appear in the July proposed rule or the October quarterly CMS update 2011. In early July, the Academy became aware of a letter sent to U.S. Sen. Susan Collins, (R-ME), from Administrator Donald Berwick, MD2 stating that the supervision level would be removed from the two procedures. The reason stated was because the two procedures are considered to be diagnostic tests, which do not require the higher level of supervision by a physician. The letter stated the change would become effective October 1, 2011. On July 21, 2011, Academy President J. Regan Thomas, MD, received an official letter from CMS, informing the Academy of the removal of the supervision level for the CPT code 31579 (Laryngoscopy, flexible or rigid fiberoptic, with stroboscopy) and code 92511 (Nasopharyngoscopy with endoscope). The same reasons were cited for the change as indicated in Dr. Berwick’s letter. The Academy will respond to CMS reiterating our position that the decision to remove the supervision level completely is not desirable and that the supervision level of direct would be the correct level to assign to the two procedures. Direct supervision would be warranted to evaluate the medical necessity of the procedure and that a review and supervision of the results and recommendations would be desirable for quality of care issues. Be aware that when there is not a national supervision level assigned by Medicare, the regional Medicare Administrative Contractor (MAC) could develop a different supervision level for its particular region.  If a member becomes aware of a regional MAC that is applying a different supervision level, contact the Academy at  Healthpolicy@entnet.org. If you have any questions or concerns, please do not hesitate to contact the Health Policy staff at the Academy. References D’Antonio, LL, et al (1989). Reliability of flexible fiberoptic Nasopharyngoscopy for evaluation of velopharyngeal function in a clinical population. Cleft Palate J 26:217-225 http://digital.library.pitt.edu/c/cleftpalate/pdf/e20986v26n3.08.pdf. Bless, D. M., Hirano, M., & Feder, R. J. (1987). Videostroboscopic evaluation of the larynx. Ear, Nose and Throat J, 66:289-296. http://www.entnet.org/Practice/31579-and-92511-SLP-Sup.cfm.


On July 18, 2011, the Centers for Medicare and Medicaid Services (CMS) officially notified the Academy that it had restored the previous supervision requirements (i.e., no supervision level assigned) for Videostroboscopy (31579) and Nasopharyngoscopy (92511) when performed by speech language pathologists. In a March meeting with CMS, Academy representatives made it clear that we support direct supervision.

Background of SLP supervision level changes

Effective January 1, 2011, CMS changed the supervision level for speech and language pathologists (SLP) who perform procedures using CPT code 31579 (Laryngoscopy, flexible or rigid fiberoptic, with stroboscopy) and code 92511 (Nasopharyngoscopy with endoscope) from the previous level of supervision (no level assigned) to personal supervision. CMS made this change in the Medicare Physician Fee Schedule Final Rule CY 2011 without publishing notice of the change in the proposed rule, which would have allowed for public comment. The Academy published the physician supervision change in The News and as a result, began receiving communications from many of our members, from all of the regions in the country, stating their concerns about how this change would negatively affect their practices and their ability to serve Medicare patients.

After careful consideration of  AAO-HNS members’ concerns and best interests, the Academy arranged to meet with payment representatives from CMS. On Thursday, March 31, 2011, representatives from the AAO-HNS along with the American Speech and Hearing Association (ASHA) met with CMS officials at their headquarters in Baltimore, MD.

CMS was provided with two journal articles co-authored by otolaryngologists and speech language pathologists and an Academy position statement addressing these services.1  The Academy representatives made it clear that we support direct supervision  and not general supervision,  meaning the physician is available, but not necessarily on the premises.

Both organizations strongly urged CMS to change the supervision requirement from personal to direct supervision—that is, the physician must be “immediately available” but not necessarily in the room while the procedure is being performed.  Both societal representative groups were cautiously optimistic that CMS would make the requested change. CMS indicated that if a change were to be made, it would appear in the July proposed rule or the October quarterly CMS update 2011.

In early July, the Academy became aware of a letter sent to U.S. Sen. Susan Collins, (R-ME), from Administrator Donald Berwick, MD2 stating that the supervision level would be removed from the two procedures. The reason stated was because the two procedures are considered to be diagnostic tests, which do not require the higher level of supervision by a physician. The letter stated the change would become effective October 1, 2011.

On July 21, 2011, Academy President J. Regan Thomas, MD, received an official letter from CMS, informing the Academy of the removal of the supervision level for the CPT code 31579 (Laryngoscopy, flexible or rigid fiberoptic, with stroboscopy) and code 92511 (Nasopharyngoscopy with endoscope). The same reasons were cited for the change as indicated in Dr. Berwick’s letter.

The Academy will respond to CMS reiterating our position that the decision to remove the supervision level completely is not desirable and that the supervision level of direct would be the correct level to assign to the two procedures. Direct supervision would be warranted to evaluate the medical necessity of the procedure and that a review and supervision of the results and recommendations would be desirable for quality of care issues.

Be aware that when there is not a national supervision level assigned by Medicare, the regional Medicare Administrative Contractor (MAC) could develop a different supervision level for its particular region.  If a member becomes aware of a regional MAC that is applying a different supervision level, contact the Academy at  Healthpolicy@entnet.org.

If you have any questions or concerns, please do not hesitate to contact the Health Policy staff at the Academy.

References

  1. D’Antonio, LL, et al (1989). Reliability of flexible fiberoptic Nasopharyngoscopy for evaluation of velopharyngeal function in a clinical population. Cleft Palate J 26:217-225 http://digital.library.pitt.edu/c/cleftpalate/pdf/e20986v26n3.08.pdf.
  2. Bless, D. M., Hirano, M., & Feder, R. J. (1987). Videostroboscopic evaluation of the larynx. Ear, Nose and Throat J, 66:289-296.
  3. http://www.entnet.org/Practice/31579-and-92511-SLP-Sup.cfm.

More from October 2011 - Vol. 30 No. 10

Trauma Expertise Important in War and Peace
“As I began to travel to job interviews, fill out civilian credentialing applications, and mentally take off my uniform, I became uneasy and could not erase the thoughts of those heroes whom I served with each day in Iraq. I remembered the amazing Army medics and Navy corpsmen who would intervene under the most austere conditions and save the lives of their fellow soldiers and marines. Every time a marine or soldier came into my emergency room with an emergent cricothyroidotomy placed in the field, I marveled at how these young medics could place this small tube through a hole in the neck under fire, without suction, headlights, and all the other resources I have in the hospital. Without their daily heroics, all of the wounded I treated in my hospital would have never made it home to be with their families.”Excerpt from Invited Editorial,  Southern Medical Journal, publication pending. Joseph Brennan, MD, COL, USAF,  Chair, AAO-HNS Trauma Committee Great advances in the surgical management of head, facial, and neck trauma have been made during times of military combat. This includes the immediate care of the wounds, maintenance of airway and control of bleeding, upper aerodigestive tract endoscopy, neck exploration, and primary through tertiary reconstruction of defects.  Since the inception of otolaryngology—head and neck surgery as a formal specialty in the United States some 90 years ago, its practitioners have contributed to the body of knowledge of trauma management in a significant manner. Throughout WWII, the Korean and Vietnam conflicts, Gulf War I, and now Operation Iraqi Freedom and Operation Enduring Freedom, otolaryngologists have been in combat and near-combat medical facilities, providing advancing care of wounds to the head, face, and neck. Just as John Conley, MD, expanded his reconstructive head and neck surgery advances during WWII, so have our colleagues in more recent times. The civilian practice of otolaryngology—head and neck surgery has benefited from these experiences, where knowledge gained in caring for combat wounds has been translated to gunshot wounds, massive trauma from industrial and motor vehicle accidents, and other injuries seen in emergency rooms. Otolaryngologists were not members of the head and neck surgical teams deployed to Iraq during the first 18 months of Operation Iraqi Freedom. Oral surgeons managed facial trauma and airways and general surgeons managed neck trauma and endoscopy. Otolaryngologists had no role as part of a multispecialty head and neck trauma team composed of neurosurgery, ophthalmology, and oral surgery. However, the Air Force deployed otolaryngologists with their head and neck team in September 2004. Since that time, the surgical data collected in both Iraq and Afghanistan demonstrate that the otolaryngologist is the busiest and most productive member of this trauma team. Consequently, we have a moral and educational duty to maintain our excellence in head and neck trauma and to train our next generation of otolaryngologists to provide state-of-the-art trauma care. It is important to have an entity within the major practice and educational association of otolaryngology—head and neck surgeons that addresses the needs of its members who remain committed to trauma care of patients, and to further the education and training (or re-training) in this area of practice. With the threat of terrorism and national disasters looming as future medical emergencies, the AAO-HNS members and fellows are best served by emphasizing this traditional and very important aspect of patient care. In 2001, a group of committed  AAO-HNS members petitioned for and set up a Trauma Study Group to be convened at the Annual Meeting & OTO EXPO. These members strongly believe that our Academy should take the lead and emphasize the role of otolaryngologists in managing head, face, and neck trauma.  Beginning in September 2008, the AAO-HNS Trauma Study Group has convened at every annual AAO-HNSF meeting. Additionally, the Trauma Study Group has frequently conducted trauma research, organized and prepared miniseminars, and discussed future trauma endeavors in person, over the phone, and via email. In 2010, we successfully petitioned the Executive Committee of the Board for full committee standing of a new AAO-HNS Trauma Committee. Our proposal was accepted, and we convened our inaugural meeting of the AAO-HNS Trauma Committee September 12, 2011. All interested Academy members are invited to contact our Trauma Committee members if you would like to participate in our educational and research endeavors. The Trauma Committee is a unique group composed of both active duty military and civilian AAO-HNS liaison members who are absolutely dedicated to the care of our head and neck trauma patients.  We would welcome your participation with us: contact Rudy Anderson, staff liaison, 1-703-535-3718, randerson@entnet.org.
PCO_3rd
Primary Care Otolaryngology, Third Edition, Now Published as an E-book
The third edition of Primary Care Otolaryngology has been published on the Academy website as an e-book. This primer on fundamental topics in general otolaryngology has been extensively revised since the second edition was published in 2004.  Primary Care Otolaryngology is a concise, informative handbook on otolaryngology for medical students and allied health professionals. Reviewed and edited by AAO-HNSF education faculty, under the supervision of Karen T. Pitman, MD, chair of the General Otolaryngology Education Committee of the Foundation and Mark K. Wax, MD, this e-book offers new advice on evaluating patients. Each chapter ends with a short self-assessment exam. This edition of the popular handbook continues its goal of improving clinical judgment by teaching the basics of otolaryngology. This e-book helps readers manage uncomplicated clinical problems and recognize when to refer more serious conditions to an otolaryngology specialist. Highlights of the third edition include a new chapter on allergy, from presentation to treatment, and updates to all the chapters reflecting current clinical practice guidelines. “It will whet your appetite for further learning in the discipline that we love,” said Dr. Wax, former AAO-HNSF Education Coordinator. “The Foundation considers it a must-have for medical students, non-ENT physicians, and allied health professionals.” Originally authored by Gregory J. Staffel, MD, in 1996 as an introductory reference for medical students at the University of Texas School for the Health Sciences, it has evolved into a practical handbook for non-ENT clinicians who encounter general otolaryngology conditions. Dr. Staffel donated his book to the AAO-HNSF to be used as the basis for subsequent editions. The first edition of Primary Care Otolaryngology was published in 2001.  The e-book can be downloaded for viewing or printing at no charge from http://www.entnet.org/mktplace/primaryCare.cfm.
sujana-2011
BOG Tackles the Tough Issues in Healthcare Spending
We live, and practice, in  interesting times. As I assume the role of Chair of the Board of Governors, following an intense learning year shadowing Michael D. Seidman, MD, I look back at the efforts and accomplishments of the BOG’s socioeconomic and grassroots initiatives. I also look ahead to the challenges for 2011-2012. Healthcare spending encompasses 16 percent of our nation’s Gross Domestic Product (GDP). Therefore, as we follow state and national political discourse, it is naïve to think that our profession—one-sixth of our nation’s expenditure—will not be affected. Even though ENT makes up a fraction of the house of medicine, our Academy’s voice has been a loud one in reminding our elected officials what is real in medical care. During this summer’s heated debt crisis discussions, only one plan included reforming or replacing the untenable and flawed sustainable growth rate (SGR) formula—at a cost of $298 billion over 10 years. This was to be offset by undefined savings in federal healthcare programs, suggesting that physicians might have ended up paying for the “doc fix” via lower reimbursement. That plan didn’t go through. The debt deal that was reached did not eliminate the SGR and instead created a new level of uncertainty for physician payments. The debt deal charges a newly created Joint Select Committee on Deficit Reduction (a.k.a., the Super Committee) with identifying $1.2 trillion in savings by November 23, 2011. If the committee fails to achieve the required savings, a trigger for automatic Medicare cuts will go into effect ­- a process that insulates beneficiaries and could result in a maximum 2 percent cut in physician payments from 2013 – 2021. With no SGR reform in sight, physicians face a whopping 29.5-percent decrease in Medicare payments on January 1, 2012. Our Academy has fought each prior SGR-based planned payment cut and will fight this one. It is imperative that each practicing otolaryngologist takes this “opportunity” to educate our patients and their families about the flawed SGR and the need for its repeal. Every insurance company bases its fee schedules on Medicare; a cut in Medicare means a cut in all. It has been a year and a half since the Patient Protection and Affordable Care Act (ACA), or Healthcare Reform (HCR), became law. ACA’s rollout is planned over several years. The initial phase involved expanding coverage to adult children and eliminating pre-existing condition exemptions. One portion of ACA to which AAO-HNS is adamantly opposed is the Independent Payment Advisory Board (IPAB), which would effectively be able to set physicians’ pay without the checks and balances currently in place for MedPAC. ACA also has only minimal mention of tort reform. We will continue to push at the national and state levels for fair reform of the current torts process. The Congressional Budget Office (CBO) cites the pressing need for Comparative Effectiveness Research (CER) in guiding payment decisions by the Centers for Medicare and Medicaid Services (CMS). Our Academy has been at the forefront in designing, implementing, and fine-tuning Guidelines Panels on a variety of otolaryngology topics. The goal of these panels is to provide the best CER to help physicians, patients, and payers. BOG members are welcome to participate in this process, either as panelists or as reviewers. How can you, as an otolaryngologist, make a difference? There are many ways. Attend the BOG Spring Meeting in Alexandria, VA, in 2012 and every year. You can discuss these and other pressing BOG issues in depth. In this venue, each voice is heard. We top it all off by “storming” Capitol Hill and meeting our legislators and their staff, as we emphasize our messages for improved healthcare for all. Please mark your calendars to attend Sunday, May 6, through Tuesday, May 8, 2012. Contribute* to our ENT PAC at www.entnet.org/entpac. Our PAC is guided by our needs as otolaryngologists and is party-blind. With the funds raised by the PAC, our legislative staffers are able to gain direct access to lawmakers and keep their fingers “on the pulse” of upcoming and ongoing legislation that affects ENTs. Download the Legislative and Political Grassroots Advocacy Handbook and Toolkit, linked at www.entnet.org/Community/public/BOG_SocietyResource.cfm. Join the ENT Advocacy Network at www.entnet.org/Practice/members/entAdvocacyNetwork.cfm. Read the Grassroots Media and Public Relations Handbook, linked at http://www.entnet.org/Community/outreach.cfm, and join the Media Experts Database by sending your information to  newsroom@entnet.org. Attend the Fall BOG meeting in conjunction with the Foundation’s Annual Meeting & OTO EXPO. The committee meetings are on the Saturday before the annual meeting starts, and the General Assembly meeting is the Monday evening of the annual meeting. Contact us. Send your ideas, questions, thoughts to bog@entnet.org. I look forward to working with you and for you in this upcoming year. *Contributions to ENT PAC are not deductible as charitable contributions for federal income tax purposes. Contributions are voluntary, and all members of the American Academy of Otolaryngology-Head and Neck Surgery have the right to refuse to contribute without reprisal. Federal law prohibits ENT PAC from accepting contributions from foreign nationals. By law, if your contributions are made using a personal check or credit card, ENT PAC may use your contribution only to support candidates in federal elections. All corporate contributions to ENT PAC will be used for educational and administrative fees of ENT PAC, and other activities permissible under federal law. Federal law requires ENT PAC to use its best efforts to collect and report the name, mailing address, occupation, and the name of the employer of individuals whose contributions exceed $200 in a calendar year.
David R. Nielsen, MD, AAO-HNS/F EVP/CEO
Reflection of our Specialty’s Dedication
This year has proved to be successful for the Academy and Foundation, with remarkable advances in strength and support, in effectiveness, and in innovation during times of a slow economic recovery and uncertainty.As you review the Annual Report within this issue, you will observe the recognized growth and development of our education, research, advocacy, and member services departments. I am proud of this growth. I am also proud to note that this growth would not have been possible without the dedication and vision of you, the member. Although we are blessed with great formal leadership capacity, I am convinced that the strength of our specialty lies in the quiet and sometimes obscure or unnoticed daily dedication you demonstrate to achieving the highest level of compassionate and effective care you render in your community. We are well represented and respected at all levels and areas of leadership from the international healthcare community to the National Academy of Science, to national and state medical associations, and to our armed services. I want to specifically thank the dedicated members of the Academy for the support and effort of each of you. As our Academy continues to grow, progress, and change, we also face opposition along the way. There is little doubt that for most engaged in change, it requires great courage to demonstrate appropriate leadership. If we are to ensure that the transitions we make are correct and effective, and that we fulfill our professional obligation to our patients, it is essential that we be courageous. Everett Rogers’ publication, Diffusion of Innovations, brought the term “early adopters” into our daily lexicon, describing those who apply progressive, influential, and respected leadership for substantive and positive change. Our specialty is acknowledging change by fulfilling essential leadership roles in improving healthcare and addressing the unavoidable challenges that we as otolaryngologists face. You, as a dedicated and committed member of the Academy, are the backbone and foundation upon which successful transition to better models of delivery of care, patient safety, improved clinical outcomes, and better public health will be balanced. There is no substitute for the honor, integrity, and personal sacrifices you make daily on behalf of your patients. I want to extend my gratitude to our dedicated leadership for their contributions and service to the Academy this past year. We are excited to embark on a new journey as we welcome the new, incoming leadership, and are excited to acknowledge the positive change and growth our Academy will assume. As we begin to plan for the 2012 Annual Meeting & OTO EXPO, September 9-12 in Washington, DC, I charge all members to engage in a significant role within your Academy. There are many programs, activities, committees, and opportunities available to make the Academy an even better place in 2012. See the November Bulletin package for a new AAO-HNS/F engagement brochure. As we begin a new organizational year,  we welcome our newly elected officers and say thank you to those who are leaving. I express my personal thanks to Dr. J. Regan Thomas for exceptional leadership, collegiality, and guidance this year.  I know you join with me in warmly welcoming Dr. Rodney P. Lusk as President and look forward to his leadership. I, along with the Academy staff, join with you in committing to act with honesty, honor, and integrity in all we do clinically, politically, socially, and personally. We pledge with you to sincerely, in the original root sense of that word, “without a false step” continue our dedication to the highest quality of healthcare in the world.
RLusk
Good Stewards of Great Information
It is clear now, more than ever, that your Academy needs to be the most robust and diverse source of ENT information for physicians, patients, and the general public. It is difficult to meet the needs of these diverse users, but a website that is appropriately designed and organized can provide efficient searches for all.  We have a responsibility to be good stewards of all this content. To that end, portals will be created to provide the needed content. This is already happening through the members-only portal where content that is provided to you as a member is different from the content available to the general public. The main conduit for dissemination of all of this content has to be through our website. When lay researchers arrive at our website, they know what they are looking for but they frequently can’t find the information. Patients are looking for information regarding symptoms, diseases, and treatments. Physicians and our members need timely and accurate access to information regarding diseases and therapies on our website as well as other relevant websites and journals. Our content should be a reliable source of information that you and your patients can rely on for accuracy. Members of the Academy also need to connect with each other to do the work of the organization. My mission, as President, is to make sure that everyone who depends on the Academy for content can access the information when and where they need it. I am committed to building a website that keeps our membership and the public coming back to us for their clinical content. Our website currently enjoys a significant amount of traffic, mostly from the public. Over the last fiscal year, there were more than 2.5 million visits to our website. There are approximately 5,000 searches a month to locate an ENT physician. The good news is that lay researchers are finding our site as they search for information, and our publication readers spend considerable time, more than a quarter hour regularly within our online publications. However, the bad news is that 80 percent of the visitors go no further than the home page. We have, therefore, concluded they are not finding what they need. While we don’t have in-depth research to assess the experience of our membership, empirical evidence tells us that you are struggling to find the information as well. It is our responsibility to serve all our constituents by taking the following initiatives: Create a well-indexed site and map for improved searching. Assign appropriate tags and key words to all content. Provide a user-friendly search engine. Provide ongoing maintenance and updates for all our content. Strategically plan new clinical content. This will be an ongoing process involving all AAO-HNS/F committee’s and staff members. To paraphrase Lewis Carroll, “If you don’t know where you are going, any road will take you there!” During my tenure, we will start the journey of making our website “THE” destination for ENT or otolaryngology information for both patients and our membership. Simply put, your searches within the Academy website should be more refined than a Google search, but broader than a PubMed search. Specialists may require even more targeted searches, and we will be exploring mechanisms of providing even more targeted searches. To accomplish this, we will: Install a new search engine: Academy IT division has chosen the Google Search Appliance. Reassess all of our web content for relevancy and currency. Assign “key words” to all content to improve the search engines’ capabilities. Through collaboration of various stakeholders and Academy committees, develop new content. Our immediate goals  therefore are: By this time next year, we will deliver content that is updated and easily searchable. Explore the use of mobile apps and podcasts; both are currently under development. Develop mobile optimization of our web content that can be delivered to you whenever and wherever you need it through any device connected to the web, such as computers, tablets and or smartphones. Explore dynamic ePublishing for the Journal and Bulletin. Technology will continue to evolve, and we will have to continue to adapt. Rest assured that this is now a priority for the Academy, and our website will become a conduit for many future educational tools for our membership and the public.