Answer: CMS Program Memorandum B-01-28, released April 19, 2001, outlined three levels of supervision: "General supervision" means the procedure must be performed under the general supervision of an individual meeting the definition of a physician. "Direct supervision" requires that the physician directly supervise the performance of the procedure. "Personal supervision" dictates the physician's personal oversight of the procedure.
Exceptions to the physician supervision rules allow for certain procedures to be performed by a physician or a physical therapist (PT) who is certified by the American Board of Physical Therapy Specialties (ABPTS) as a qualified electrophysiologic clinical specialist and is permitted to provide the specific service under the laws of the state in which he or she is licensed and practices.
Codes 95900 (Nerve conduction, amplitude and latency/velocity study, each nerve; motor, without F-wave study), 95903 ( motor, with F-wave study) and 95904 ( sensory) are covered by the exception to the physician supervision rule, and may be performed by a PT with ABPTS certification who can bill both the technical and professional components of the service, or under the direct supervision of a physician who would bill both components. Or, a technician with certification may perform the studies under the general supervision of a physician. In this scenario, the technician can bill the technical component, and the physician bills the professional component.
A PT with ABPTS certification may personally supervise another PT conducting these studies, but only the PT with certification may bill for the service. Under these guidelines, however, your RN cannot bill for the service.
Note that these are CMS guidelines: Rules governing supervision requirements and scope-of-practice for nonphysician practitioners, such as RNs, vary from state to state and payer to payer. Be sure to check with other payers directly for their policies and with your state laws governing PT licensing and practice.
