CPT 92610: Clinical Swallowing Evaluation

No. ASHA's guide to timed and untimed codes uses 92610 as one of its examples and says each such code is still reported as one unit, however long the service takes. ASHA's Medicare coding rules state that an untimed code is billed once per day, regardless of the time spent providing the service.

That means the Medicare 8-minute rule does not apply to 92610. CMS reports untimed codes with one unit regardless of the minutes spent (its example is speech-language evaluation 92521). The rule only counts minutes for 15-minute timed codes. If you also bill timed codes on the same day, use the 8-minute rule calculator for those codes only, and still record the total treatment time.

92610 reports a clinical evaluation. The other three codes report instrumental studies in which the swallow is recorded with imaging or a scope. ASHA states that 92611 reflects the SLP's work during the fluoroscopic study, and that radiologists separately report 74230 for their participation. ASHA's fee schedule analysis lists 92612 as a flexible endoscopic evaluation of swallowing and 92616 as the same evaluation with laryngeal sensory testing.

The clinical evaluation is often done first and helps decide whether an instrumental study is needed. Because they are different services, document each one as its own evaluation with its own findings.

ASHA's table of Medicare correct coding (NCCI) edits for speech-language pathology lists 92610 as a code that is paired with 92611 and 92612 to 92617 in a way that can be bypassed with a modifier when it is clinically appropriate. ASHA names modifier 59 as the one used for these edits, and notes that some payers may require a more specific set of subcategory modifiers. When a modifier applies to this pair, it goes on 92610, the code in the second column of the edit.

That table is a secondary summary and NCCI edits are updated every quarter, so confirm the current pair on the CMS NCCI tables before billing. When both evaluations are done, the note should show they were separate and distinct services.

92526 reports treatment of swallowing problems or oral function for feeding. It is a treatment code, so it does not replace the evaluation. The usual path is evaluation (92610), a plan of care, then treatment (92526), with the plan of care updated as the client progresses.

ASHA's Medicare coding rules also tell SLPs to report 92526 instead of electrical stimulation code 97032 when stimulation is provided as part of a full swallowing treatment session. Payers differ on same-day billing of evaluation and treatment, so check each payer's policy before billing both on one date.

Medicare requires the GN modifier on every code rendered under a speech-language pathology or dysphagia plan of treatment, according to ASHA's Medicare CPT coding rules. The CMS Medicare Coverage Database article on speech-language pathology billing (A52866) says the same: modifier GN identifies a service delivered personally by an SLP or under an outpatient speech-language pathology plan of care.

The same article says CPT does not define a re-evaluation code for speech-language pathology, so a re-evaluation is reported with the evaluation code. It also describes re-evaluation as not a routine, recurring service, so the note should say why one was needed.

ASHA's fee schedule analysis adds that Medicare pays for outpatient speech-language pathology services at non-facility rates, regardless of the setting.

Payers set their own documentation requirements, and ASHA advises writing for the people who will read the record, since claims reviewers often read assessments and plans. The CMS Medicare Benefit Policy Manual, Chapter 15, section 220.3, covers Medicare documentation for therapy services. The checklist below is a practical outline of what an evaluation note commonly records.