How to Not Allow AAC Users To Get Help: The Impact of NCCI Edits On Our Children

I'm writing this in hopes that someone at ASHA is paying attention. I'm writing in the hopes that our voices together may add some sense to a situation which is hurting children.

When the government's NCCI (National "Correct" Coding Initiative) edits came out in 2011 they only allowed us to do SGD services on the same day as speech/language services IF we billed the codes with a modifier. Our state Medicaid program didn't restrict these two codes together and didn't give us the ability to add the modifier when we billed. Now the state Medicaid program is coming back and asking for their money back saying we shouldn't have billed the codes together without a modifier, despite the fact that their provider manual stated we could bill the codes together and, the fact that they didn't have a way for us to put a modifier into our billing with them. We are an AAC specialty clinic so this impacts 100s of thousands of dollars of payment. So far they asked for $50,000. They gave us a way to go back on EACH claim and add the modifier. There are thousands of claims. They will graciously pay us once these are done. In the meantime they won't pay their bill with us. This week they decided that they are going to review every claim since January 2011.

There are so many things wrong with this situation. Most importantly , what sense does it make that a therapist with an AAC user would NOT also need to work on receptive language? Anyone working with an AAC user knows that they are at a very high risk for receptive language delays and oral motor/feeding and speech needs. The vast majority of these children need to be seen for receptive/expressive language, speech generating device modification/treatment, oral-motor/feeding and behavioral intervention. Why in the world would we force these already overworked parents to drive to therapy 2-3 times a week simply to have these services on a different day? What is the empirical evidence that providing these service on different days benefits the patient? On the contrary, we have patients traveling up to 1 1/2 hours to see us. Making them come twice places an undue burden on their physical health and their emotional well being. To say that this is the "same service" shows ignorance about the distinction between receptive language and expressive modes of communication. To ask these already incredibly challenged patients to learn all that they need to learn in a 30 minute session is beyond ludicrous. I cannot fathom that anyone with any real experience working with AAC patients had any input into the decision to disallow this code pairing.

The NCCI edits are just incorrect in not allowing these codes to be billed together. The only purpose this is serving is to give insurance and a Medicaid/Medicare an excuse to deny services that these children really need. I hope that the purpose of the NCCI edits is not to simply save government money on the backs of handicapped children. It is utterly wrong.

I have no confidence that our voices here in our clinic in Georgia will be heard by the NCCI editors but I would hope ASHA and our community of AAC families and professionals has the ability to add some reason into this terrible oversight that is hurting ACTUAL handicapped children.

At the same time, I sincerely hope that the service we are providing these children in our private practice can continue.

Thanks for any input you can offer or in helping us spread the word about the effect the NCCI edits are having on our children.

Vicki