Here's the full language from the section for people who don't open the pdf:
"
Provider Qualifications
The accuracy of cardiac ultrasound depends on the knowledge, skill and experience of the sonographer and physician. Sonographers who perform or supervise the studies must be capable of demonstrating training and experience specific to the study performed and maintain documentation for post payment audit. Physicians who perform, supervise, and/or interpret the studies must be capable of demonstrating training and experience specific to the study performed or interpreted and maintain documentation for post payment audit. A physician or a sonographer may personally perform cardiac ultrasound procedures. When a physician employs auxiliary personnel to assist him /her in providing ultrasound procedures, the services of such personnel are considered ‘incident to’ to the physicians’ services. All guidelines set forth by CMS regarding ‘incident to’ must be met.
Cardiovascular Disease/Cardiology, Cardiovascular Surgery, Anesthesia, Critical Care Medicine, and Pediatric Cardiologists are thought to have the formal training or clinical training to do these tests. Other specialties may see denials for these services. For all specialties, certification by the National Board of Echocardiography will be essential in allowing coverage for services and can be submitted in the appeals process should a denial occur."
Use this page to view details for the Local Coverage Determination for Transesophageal Echocardiography (TEE).
www.cms.gov
It's kind of strange language where, indeed, it does sound like certification would be necessary "in allowing coverage for services," but on the other hand they make mention that folks like those trained in CCM or CV surgery have the training to do these tests.... but CV surgeons and intensivists (until recently with the CCEeXAM) never take the NBE exams, let alone become certified.
I will say that I know a few other people who are cardiac anesthesiology fellowship trained from the 2000s or 2010s but who never finished their certifying process for the NBE, and the TEE billing issue has never come up even though they're testamurs in the directory. One of the cardiologists here at my hospital who performs and reads both TTE and TEE is only a testamur of the ASCeXAM. And I live in one of the 12 states listed in the LCD and I can show you my collections for 93312 TEEs for the last few years.
Additionally, if one looks at the Intersocietal Accreditation Commission
Standards & Guidelines for Echocardiography Accreditation (which any echo lab worth its salt has IAC) located here
https://intersocietal.org/wp-content/uploads/2021/07/IACAdultEchocardiographyStandards2021.pdf , you'll notice that:
View attachment 354561
There is no mention of NBE certification for medical staff. Furthermore, if you scroll up from that page you'll see that there's not even an NBE certification requirement for the
medical director of the echo lab.
All in all, I think the mention of certification in the LCD is mostly present to address situations where fraud or inappropriate billing is noticed through an audit, and in that case a person or facility would use certification in the appeals process to show appropriateness of the procedure/billing etc.