Neurology & Pain Management Coding Alert

Question: I work for a pain management clinic that’s beginning to do EMGs on leased equipment. Can we still bill both the technical and professional components, or does the owner of the equipment get to bill the technical portion even though it’s located at our physician’s office? 

We also wonder how the situation will affect credentialing. Should we credential the facility for the technical component and the physician for the professional? Or do we get credentialed for both components? 

Michigan Subscriber 

Answer: As long as the physician is paying fair market value for “leasing” the necessary equipment and paying for the necessary supplies, etc., then he could compliantly bill the global neuromuscular electrodiagnostic tests. 

There wouldn’t be any facility to “credential” since your physician is performing the test in an office place of service. The physician should have the necessary corresponding training to perform this type of testing as some payers are starting to require proof of this (such as residency or board certification related to EMG testing). Neurology and physiatry residencies frequently include this type of training and testing. 

The Novitas L32723 LCD for the JH jurisdiction, in particular, includes the following excerpt: Novitas Solutions, Inc expects healthcare professionals who perform electrodiagnostic (ED) testing will be appropriately trained and/or credentialed, either by a formal residency/fellowship program, certification by a nationally recognized organization or by an accredited post-graduate training course covering anatomy, neurophysiology and forms of electrodiagnostics (including both NCS and EMG) acceptable to this Contractor, in order to provide the proper testing and assessment of the patient’s condition and appropriate safety measures. It would be highly unlikely that this training and/or credentialing is possessed by providers other than Neurologists, or Physical Medicine and Rehabilitation physicians.

Medicare has requirements for performance of the technical component of most diagnostic testing, including EMG and NCS. Who can administer the test and any training requirements for EMG varies from NCS (nerve conduction studies). Check the most recent Medicare Physician Fee Schedule to verify who CMS stipulates can perform the technical component of the service. 

Know the codes: CPT® includes several codes for EMGs, based on anatomic site. Some common ones for neurologists include: 

• 95860 – Needle electromyography; 1 extremity with or without related paraspinal areas
• 95861 – … 2 extremities with or without related paraspinal areas 
• 95863 – … 3 extremities with or without related paraspinal areas  
• 95864 – … 4 extremities with or without related paraspinal areas
• +95885 – Needle electromyography, each extremity, with related paraspinal areas, when performed, done with nerve conduction, amplitude and latency/velocity study; limited (List separately in addition to code for primary procedure)
• +95886 – … complete, five or more muscles studied, innervated by three or more nerves or four or more spinal levels (List separately in addition to code for primary procedure).