Technical Component = Technicians’ Work?
CPT codes used for vestibular function testing are broken down into technical components (TC) and professional components (PC) reported with the modifier 26. The technical component covers the equipment used and the cost of the technician (if applicable) performing the test and is indicated by the modifier TC (e.g, 92541-TC). The professional component covers the interpretation of the test results. To indicate that the code is for the professional component only, a modifier (26) is placed after the five-digit code (e.g., 92541-26). When the test is performed and interpreted by a qualified audiologist or physician, the test would be billed as the global component with no modifier (92541), with a value exactly equal to the sum of the assigned values of the technical and professional components combined. Additionally, if a physician directly supervises an employee technician and provides interpretation and a report, the physician may use the global component. Medicare rules state: “A technician may not perform any part of a service that requires clinical decision making. For example, a technician may not interpret test results or engage in clinical decision making.” (CMS transmittal 1975, 2010)
Physicians may additionally bill for an office visit (known as evaluation and management) if they do a chart review, physical exam and take a history from the patient on the same day (or another day) as the exam. Audiologists are not reimbursed by Medicare for evaluation and management even though they must also perform a chart review, physical exam and take a history. It is considered that these services are included in the fee to perform the vestibular test.
Audiologists are also not paid by Medicare for any treatments, including vestibular rehabilitation and canalith repositioning. Audiology is classified as a “diagnostic” profession under Medicare rules, so we get paid for the tests we do, but nothing else. It would take a change in our Medicare classification to allow payment for history taking, counseling, treatment or treatment planning. On the other hand, we can’t do our jobs without including these in our patient care.
Next week, I will wax philosophical about this issue.