Medicare Listened!!

Several weeks ago, I posted a blog on this site discussing Medicare’s definition of Computerized Dynamic Posturography (CDP), which is described by the AMA CPT code 92548. I will paste a portion of that post below.

In the interim, I worked with the American Academy of Audiology to write to Palmetto GBA (a regional Medicare administrator), basically appealing the decision to use this description.  This was part of a lengthy response to the new vestibular testing LCD (Local Coverage Determination). Well, we just got word last week that Palmetto GBA agreed with our argument and has rescinded the detailed, monopoly-creating description for CDP. There are still several aspects of the LCD we consider problematic, and we will continue to work on those. We are pleased and impressed that Palmetto GBA remained open minded, listened to what we thought was a convincing argument, and made the right decision to change their policy.  Later this year, I will cover the controversies surrounding the policies, and enforcement of policies regarding rotational chair and active head rotation testing. But for now, we will enjoy this small victory.

Here is the excerpt from the earlier post:

Recently, one of the larger Medicare administrators, Palmetto GBA, has issued a new LCD (Local Coverage Determination) for vestibular testing with a detailed description of CDP (92548):  Computerized dynamic posturography (CDP) is a test of the vestibulospinal system and assesses an individual’s ability to maintain standing balance under a variety of sensory conditions. During this test, the individual stands on two force plates which measure the individual’s postural sway. The dynamic posturography test actually consists of several different subsets of conditions that quantify the patient’s ability to use visual, somatosensory and vestibular cues to maintain standing balance. The motor coordination subtests measure the automatic postural reactions to sudden translational or pitch movements of the support surface. The third subset, the Electromyography (EMG) test, measures the integrity of peripheral and central pathways for motor innervation of the lower limbs as reflected by the onset of motor responses to rotational movements of the support surface. Responses are measured by surface EMG, and related to normal values by age. While the posturography test is a non-localizing test, patterns of performance on the various subtests are helpful in diagnosis of the etiology of vestibular dysfunction. Abnormal findings in the motor control tests or EMG test are indicative of central rather than peripheral vestibular problems. This test is not a simple balance test.  “

Here is the response I wrote for the Academy of Audiology appeal:

CPT Code 92548 (Computerized Dynamic Posturography- CDP))- The descriptor used for this code is inappropriate, and we suspect written in response to fraudulent use of this code in California around 2007.  This language has never been vetted through the CPT process, does not accurately represent CDP as performed in most vestibular specialty clinics, and is contrary to AMA and CMS guidelines, creating a monopoly for a specific manufacturer. Additionally, aspects of the CDP exam as described here are rarely performed in the clinic setting. Simply, hardly anyone does CDP as described in this LCD.  We suggest eliminating the MCT and EMG portions of the description, as there is no evidence to support their routine clinical use, while the SOT portion of the CDP exam has been studied extensively and proven beneficial in treatment planning.  Eliminating the MCT and EMG portions would also undo the monopoly created by the full descriptor, as there is more than one manufacturer of SOT capable CDP.

This outcome was very encouraging, as we have had little success in the past few years in dealing with Medicare and the steady slide in reimbursement rates.


About Alan Desmond

Dr. Alan Desmond is the director of the Balance Disorders Program at Wake Forest Baptist Health Center, and holds an adjunct assistant professor faculty position at the Wake Forest School of Medicine. In 2015, he received the Presidents Award from the American Academy of Audiology.