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Vestibular Function Studies Conducted by Industry Technicians

In late 2003, the SLPAB was approached by a Medicare billing agent to address a dramatic increase in the number of reimbursement claims for vestibular function studies. The agent was concerned with the potential over-utilization of the studies and was seeking guidance from the SLPAB on the qualifications required of personnel who conduct the vestibular function studies. The SLPAB informed the agent that vestibular function assessment and evaluation is within the practice of audiology and as such under the Practice Act only licensed audiologists or audiology aides while under the direct supervision of a licensed audiologist may perform such studies. It was clear from SLPAB's communications with the Medicare agent that a significant number of billings were submitted to Medicare by unlicensed "technicians" who had conducted the vestibular studies.

The SLPAB discussed the issue at two consecutive public meetings, where manufacturers of testing equipment addressed the SLPAB and provided information about their technician training programs and service models. Independent of the meeting discussions, SLPAB gathered information from practicing audiologists on the duties and tasks commonly assigned to audiology support personnel and whether it was common practice to assign support personnel the task of conducting balance studies. The SLPAB's legal counsel researched the provisions of law related to the supervision requirements of support personnel including any concurrent exemptions that exist under the Medical Practices Act that would permit the use of support personnel to provide services under the supervision of a physician.

Based on the guidance from legal counsel and SLPAB discussions, it was determined that vestibular function studies must be performed by licensed audiologists or a registered audiology aide working under the direct (physically present) supervision of the audiologist. Alternately, it can be performed by a physician or personnel operating under a physician's supervision.