A Note From Aphasia Access Board of Directors

Addressing questions on reimbursement for LPAA services is a priority for Aphasia Access. Part of our advocacy strategy is to champion a dialogue with ASHA on the topic. To that end, you are asked to consider adding your name to the letter below which will be sent to ASHA's Government Relations and Public Policy Board in the coming weeks. 

The letter is below. Directly following the letter is a short (less than a minute) form that you need to complete to have your name added to this letter. If you have any questions, please contact Aphasia Access' offices at medicare@aphasiaaccess.org.

 



Dear Respected Members of the ASHA Government Relations and Public Policy Board (GRPPB),

The American Speech-Language-Hearing Association (ASHA) has always provided thoughtful, responsive leadership in addressing the ever changing landscape of healthcare and its impact on the ability of ASHA’s constituency to provide the best services possible to our clients with communication disorders. Currently, ASHA is faced with the complex problem of trying to achieve three separate but important goals:

  • Promote compliance with current Medicare legislation requiring that all Speech-language Pathologists (SLPs) become Medicare providers if providing services to Medicare beneficiaries
  • Ensure access to clients and their families who select to participate in Life Participation Approach to Aphasia (LPAA) treatment models across their various settings, be it hospial, university, private practice, or community-based.
  • Ensure appropriate clinical training to graduate students in the field of adult neurogenic communication disorders.

The goal of this letter is twofold: 1) to provide background to the problem from the perspective of two professional models of care, LPAA providers and University Clinics and 2) to request that the GRPPB advocate for a careful study of these issues in order to identify the best possible solutions for optimizing client access to aphasia services across the care continuum.

Individuals with chronic aphasia and their families have historically been an underserved group given their long-term need for ongoing support, education, and services. Universities often have the resources to provide more intensive or longer treatment trials or offer alternate service models than what is currently covered by Medicare. It is common for a client to be referred to a university clinic for additional services once they have been discharged by their third party payer, be it a private insurer or Medicare. Although university clinics that are affiliated with medical centers may have the infrastructure in place to support being Medicare providers, many other university clinics that have long been considered an invaluable community resource, may not be able to meet the 100% in room supervision criteria or afford the costs related to billing management.

In addition, it’s important to recognize that the Medicare requirement of 100% in-room supervision conflicts with the best evidence established for student supervision models. The literature shows consistently that clinical development is linked to the supervisor allowing the clinician to be more independent. This opportunity for growth and development is stifled when the supervisor is constantly in the room and has line of sight. The potential impact on student training is a significant concern and extends to a broader problem. There are some clinics that have already determined that it’s simply not feasible to become a Medicare provider and thus have decided to no longer see adult clients. How can we adequately train the next generation of clinical providers without access to adult clients?

Finally, while the value and contribution of the LPAA service delivery model has been well established in the literature and is clearly supported by ASHA in terms of supporting client-centered care, many of the skilled services that are provided through LPAA group treatment programs do not fit well into the current Medicare funding model. Since aphasia is often a chronic, life-long condition, these LPAA programs came out of the desire to provide ongoing, affordable, and relevant client-centered services to individuals who often no longer qualified for therapy from third party payers.  They were never designed with the explicit goal of Medicare reimbursement. If LPAA programs are no longer able to maintain operation because of a loss in funding from low-cost client fees, countless individuals with aphasia and their families would lose what many consider a life-line to improving their quality of life.

Some of the challenges facing many University and LPAA providers in terms of Medicare compliance include:

Barriers

LPAA

Providers

University Clinics

Group size often exceeds that which is considered reimbursable by Medicare

x

x

Client’s ability to benefit from treatment often exceeds the typical window for reimbursable services

x

x

Long term outcomes may be broader than those typically accepted by Medicare

x

x

Progress towards goals may be slower than rate typically acceptable by Medicare

x

x

Clients may benefit from ongoing participation for the duration of their lives

x

x

Administrative cost and staffing needs of Medicare billing may be prohibitive.

x

x

100% in-room supervision not economically feasible; programs were developed to meet ASHA standard of 25%  supervision

x

x

100% in-room supervision is incompatible with current best-practice guidelines for clinical pedagogy

x

x

If providing clinical clock hours, must be considered a skilled service

x

x

If unable to meet supervision or billing criteria, and opt to offer free services, loss of revenue may make programs unsustainable

 

x

If unable to see Medicare clients, will have limited or no capacity to provide direct student training for adult neurogenic communication disorders

 

x

May want to provide treatment at an intensity not covered by Medicare

x

x

May want to provide treatment models not covered by Medicare

x

x

 

ASHA’s scope of practice promotes the importance of advocacy for our clients. If this Medicare law impedes the ability to train our next generation of practitioners to competently provide services to our adult clients or results in the inability of LPAA programs or university clinics to continue to provide services to clients who are living long term with aphasia, then it is time to advocate for some type of solution. Without these programs, individuals with aphasia will likely be further disenfranchised, left sitting at home with very little hope or opportunity for connecting with others or participating in meaningful, therapeutic activities.

We are looking to ASHA to acknowledge the critical situation facing many of our University clinics and LPAA providers and provide leadership by initiating an in-depth study of the potential options to address this situation. We recognize that there are many complex factors involved in any solution, but it is absolutely vital to undertake a comprehensive study of the problem to ensure that we are providing the best possible services to our clients and training to our future providers. Actor and activist, Robert Redford, said that “Problems can become opportunities when the right people come together.” We are hopeful that ASHA will commit to gathering an informed, determined group of professionals to fully study the issues at hand and develop a plan of action.

We look forward to hearing your response.

Respectfully submitted,

  

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