Neurology & Pain Management Coding Alert

HCFA has released Program Memorandum No. B-01-28, dated April 19, 2001, outlining the supervision rules for more than 700 diagnostic tests. The memo, effective July 1, 2001, assigns specific levels of physician supervision required for neurological diagnostic tests payable under the Medicare physician fee schedule. The levels include general, direct and personal supervision. The delay in implementation is intended to allow physical therapists (PTs) (for those practices where physical therapists perform some of the diagnostic tests) time to acquire the necessary certification from the American Board of Physical Therapy Specialties (ABPTS) to perform those services without supervision.

The regulation defines these levels as follows:

General supervision means the procedure is furnished under the neurologists overall direction and control, but the neurologists presence is not required during the procedure. The training of the nonphysician personnel who performs the diagnostic procedure and the maintenance of the necessary equipment and supplies is the continuing responsibility of the neurologist.

Direct supervision in the office setting means the neurologist must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. It does not mean that the neurologist must be present in the room.

Personal supervision means a neurologist must be in the room during the performance of the procedure. Neurology coders should note that effective July 1, 2001, certain codes in the 95860-95937 range will have new supervision levels (either 21, 22, 6a, 66, or 77a).

Coding With New Supervision Levels

1 = Procedure must be performed under the general supervision of a neurologist, which means that the procedure is furnished under the neurologists overall direction and control but the neurologists presence is not required during the procedure. The training of the nonphysician personnel who performs the diagnostic procedure and the maintenance of the necessary equipment and supplies is the continuing responsibility of the neurologist. For example, an EEG performed only during sleep would be performed under neurologist direction and control. This is coded as 95822.

2 = Procedure must be performed under the direct supervision of a neurologist in the office setting, which means a neurologist must be present in the office suite and immediately available to furnish assistance and direction throughout the procedure. It does not mean that a neurologist must be present in the room. For example, testing of the autonomic nervous system function with cardiovagal innervation would be performed with a neurologist available in the office suite. This is coded as 95921.

3 = Procedure must be performed under the personal supervision of the neurologist, which means the neurologist must be in the room during the performance of the procedure. For example, functional cortical and subcortical mapping performed to provoke seizures or identify vital brain structures would require the physical presence of a neurologist in the room. This is coded as 95961 for the first hour, and 95962 for each additional hour.

4 = Physician supervision policy does not apply when procedure personally furnished by a qualified, independent psychologist or a clinical psychologist; otherwise must be performed under the general supervision of a neurologist. For example, develop-mental testing could be performed by a psychologist or under a neurologists direction. This is coded in either situation as 96110

6a = Procedure must be personally performed by a neurologist or a PT who is certified by the ABPTS as a qualified electrophysiologic clinical specialist and is permitted to provide the service under state law. The PT with ABPTS certification may personally supervise another PT, but only the PT with ABPTS certification may bill. For example, an EMG performed on one extremity could be performed by a certified PT or by a PT supervised by a certified PT. This is coded in either situation as 95860.

21 = Procedure may be performed by a technician with certification and under general supervision of a neurologist; otherwise under direct supervision of neurologist. Only TC (technical component) can be performed by technician; the professional component (PC) is always performed by a neurologist. For example, visual evoked potential testing of central nervous system could be performed by a certified technician but only the technical component. This is coded as 95930.

22 = May be performed by a technician with on-line real-time contact with a neurologist. For example, intraoperative monitoring could be performed by a technician who is in contact with an on-line neurologist. This would be coded as 95920.

66 = May be performed only by a PT with ABPTS certification and certification in this specific procedure, or performed personally by the neurologist. For example, a needle EMG using a single fiber electrode with a quantitative measurement of jitter, blocking and/or fiber density could be performed by a PT certified in that procedure. This is coded as 95872.

77a = PT with ABPTS certification may perform both the TC and PC, or under the direct supervision of neurologist may perform both the TC and PC, or a technician with certification and general supervision of neurologist may perform the TC only; with the neurologist performing the PC. The PT with ABPTS certification may personally supervise another PT, but only the PT with ABPTS certification may bill. For example, both the TC and PC components of a nerve conduction study of a sensory nerve could be performed by a certified PT. This is coded as 95904.