Hobratschk request for HCFA to remove physician supervision requirement for speech processor programming
Hobratschk issue brief on new codes for speech processor programming
Physician letters to Hobratschk in support of revising CPT 92510
ALJ ruling obtained by Hobratschk averting programming denial for lack of physician supervision

Medicare Allows Audiologists to Bill Directly for Cochlear Implant Programming

In a major victory for audiologists and cochlear implant users covered by Medicare, the Centers for Medicare and Medicaid Services (CMS) have established new procedure codes for programming of the cochlear implant speech processor effective March 1, 2003.

Under the change sought by ASHA Director of Health Care Financing and Advocacy, Mark Hobratschk, Medicare will recognize programming as a diagnostic instead of rehabilitative service.   As a result, qualified audiologists can finally bill and receive payment directly from Medicare, without physician supervision, as they can do for all diagnostic services. 

Audiologists must bill under the following new CPT codes adopted for all payers (including Medicaid and private plans) by the American Medical Association (AMA): 

  • 92601: Cochlear implant follow-up exam (under age 7) 
  • 92602: Reprogramming of cochlear implant (under age 7) 
  • 92603: Cochlear implant follow-up exam (age 7 or older) 
  • 92604: Reprogramming of cochlear implant (age 7 or older)

Medicare will only reimburse audiologists directly for these codes when performed in the non-facility setting (i.e., not a hospital or skilled nursing facility.) Payment under the 2003 Medicare physician fee schedule is as follows: 

  • 92601: $123.15 
  • 92602: $86.48 
  • 92603: $83.02 
  • 92604: $56.73

Aural rehabilitation following cochlear implantation (the speech therapy component) will move back to the generic CPT code 92507 for aural rehabilitation, as it was prior to 1996. Payment under the 2003 Medicare physician fee schedule is $72.64 if performed in a non-facility setting, or $26.98 if performed in a facility setting (i.e., hospital, skilled nursing facility.) 

CPT code 92510 will no longer be in use. This code combined both programming and aural rehabilitation. Mark Hobratschk worked with the American Speech-Language-Hearing Association (ASHA) in developing this code back in 1995, while heading the reimbursement department for Cochlear Corporation.

Previously, audiologists could not directly bill Medicare unless they were employed by a physician or physician's group, and a physician was on the premises supervising the procedure. Since physicians are not trained or qualified to perform programming, this was rarely the case. 

Medicare's policy caused major disruptions in care for some patients, who were forced to either pay up to $300 per visit out-of-pocket (for about 12 to 20 visits in the first year after surgery), or travel great distances to find a center with physicians on-site. 

Medicare carriers traditionally did not enforce this physician supervision requirement. However, in 1999 Empire Blue Cross and Blue Shield of New York (the Part B carrier for New York City) began denying all programming claims billed by independent audiologists. This resulted in mass denials for cochlear implant users in the region, many of whom received little if any explanation from Medicare for the cause. 

Cochlear implant users from Beth Israel Medical Center and the New York University School of Medicine alerted Mark Hobratschk, who had just joined ASHA. 

Mr. Hobratschk reviewed their claims and informed the centers of the problem. He then contacted several cochlear implant centers and quickly learned that the mass denials of programming claims were spreading across the country to other Medicare carriers. Within several weeks, he was meeting with CMS officials urging new codes for programming and the removal of the physician supervision requirement, as its enforcement would only hinder access to programming services for many patients. When CMS agreed to do so if AMA created new codes, Mr. Hobratschk successfully persuaded ASHA board members in May 2001 to submit a petition to the AMA.